• Section 1 - Preamble
• Section 2 - Purpose
• Section 3 - Scope
• Section 4 - Policy
• Foreign Interference 
• Foreign Influence
• Research Security
• Awareness to the risks of Foreign Interference and Influence 
• Activities that heighten the risk of Foreign Interference and Influence 
• Responsibilities for reducing risk – due diligence
• Additional Roles and Responsibilities
• Section 5 - Non-Compliance

Section 1 - Preamble

(1) Charles Darwin University (‘the University,’ ‘CDU’) embraces its role as a global institution that seeks to advance knowledge and innovation internationally. In doing so, we also recognise that the complex landscape of international relations can pose unique challenges, such as foreign interference and influence.

(2) Aligned with the Australian Government's Guidelines to Counter Foreign Interference in the Australian University Sector and the Foreign Influence Transparency Scheme Rules 2018, this policy aims to safeguard the University’s core values of academic freedom, integrity, and transparency. The University must ensure that our international collaborations are conducted securely and in compliance with national and international standards, thereby maintaining the trust of our community and partners worldwide. 

(3) The aim of this policy is to protect the integrity and values of our University and to educate and engage our community about the potential risks and responsibilities associated with global engagements.

Section 2 - Purpose

(4) This policy aims to establish principles, responsibilities and risk management requirements to identify, assess, and mitigate foreign interference risks arising from international engagement, research activities, education delivery, commercial partnerships, information sharing, and other University activities. 

(5) This policy should be read in conjunction with CDU policies and procedures such as the Foreign Arrangements Procedure, Legal Agreements Policy and Procedure, Defence Export Controls Policy, Conflicts of Interest Policy and the Conflicts of Interest Procedure. These documents provide guidelines for the establishment and management of foreign arrangements such as international agreements, contracts, joint ventures, Memoranda of Understanding (MOU), recruitment processes and partnerships.

Section 3 - Scope

(6) This policy applies to all employees, students, contractors, and affiliated entities of the University. It covers all academic, research, and administrative activities, including international collaborations, data sharing, and commercial ventures, be they formal or informal.

Section 4 - Policy

Foreign Interference 

(7) Foreign interference occurs when activities are carried out by, or on behalf of a foreign actor, which are coercive, clandestine, deceptive or corrupting and are contrary to Australia’s sovereignty, values and national interests. This can include espionage, cyber operations, or other covert actions aimed at appropriating sensitive information, influencing research outcomes, or shaping the strategic direction of the University.

(8) Foreign interference can occur through various channels:

1. Cyber-attacks: unauthorised access to University networks to steal research data or sensitive information. 
2. Insider Threats: individuals within the University being coerced or willingly helping foreign actors. 
3. Academic Partnerships: collaborations or exchanges that come with obligations which influence academic freedom or research integrity. 
4. Research involving dual-use technologies: research that has potential military applications, including technologies listed under the Defence and Strategic Goods List (DSGL). This includes both:
   1. Part 1 – Munitions List: items specially designed or modified for military use.
   2. Part 2 – Dual-Use List: items generally used for commercial purposes but with potential military or weapons of mass destruction (WMD) applications.
5. Grants and Funding Coercion: the use of research funding, scholarships, or university resources as leverage to influence academic outputs or institutional decisions, particularly where these may be tied to foreign state interests.

(9) Results of foreign interference:

1. Loss of Intellectual Property: diminishing the University’s research value and global standing.
2. Compromised decision making: decision processes influenced by hidden agendas not aligned with the University’s best interests. 
3. Reputational damage: loss of trust among stakeholders, including students, Faculties, government agencies and global partners. 
4. Personal and/or institutional liability: disciplinary and/or legal action against individuals and/or the University following breaches of governance documents, contractual obligations, and/or the law.

Foreign Influence

(10) Foreign influence occurs where governments attempt to influence deliberations on issues of importance to them. Foreign influence activities, when conducted openly, transparently, and in accordance with the law, are a normal aspect of international relations and diplomacy and can contribute positively to public debate. It may occur openly through lobbying or partnerships, but it can also happen covertly through social and professional connections. 

(11) Foreign influence can become negative where it seeks to manipulate the University into making decisions that conflict with its values, interests and obligations. This can lead to skewed research findings, biased educational content, or decisions that favour a foreign entity to the detriment of the University or national interests.

Research Security

(12) Research security refers to the protection of research, researchers, intellectual property, sensitive information, technology and research outcomes from unauthorised access, misuse, exploitation, coercion, theft or foreign interference.

(13) Research security considerations should be incorporated throughout the research lifecycle, including:

1. funding applications;
2. recruitment and appointment of researchers;
3. collaboration arrangements;
4. visiting researcher programs;
5. data access and management;
6. publication activities;
7. commercialisation activities; and
8. technology transfer arrangements.

Awareness to the risks of Foreign Interference and Influence 

(14) Being aware of the risks of foreign interference and influence, effectively managing those risks, and implementing suitable security measures for sensitive information and knowledge help mitigate the risk of such information being exploited.

(15) Members of the University community must comply with all applicable Commonwealth, State and Territory laws. Certain activities associated with foreign interference, corruption, espionage, sanctions breaches or defence export control breaches may expose individuals and the University to disciplinary, civil or criminal consequences.

(16) All members of the University community, including Council members, employees, affiliates, and students, are bound by Australian law. If a bribe is offered to a public official or if there are irregularities in financial accounting records intended to conceal a bribe, it may result in an investigation by the Australian Federal Police and could lead to criminal charges, potentially resulting in imprisonment. Such actions would also be considered corrupt conduct.

(17) Failure to disclose foreign affiliations, appointments, funding arrangements, talent program participation, or competing commitments may increase foreign interference and research integrity risks and may adversely affect compliance with funding body requirements.

(18) Employees, affiliates and students who become aware of suspected foreign interference, coercion, suspicious approaches, inappropriate influence attempts, sanctions concerns, research security concerns or related cyber incidents must report such matters through appropriate University channels.

(19) The University’s Conflicts of Interest Policy, Conflicts of Interest Procedure, Gifts and Benefits Policy, Responsible Conduct of Research Policy and External Employment Policy and Procedure, provide further information on managing any conflict of interest or undue influence concerns.

(20) The University’s Information and Communication Technologies Acceptable Use Policy, and Information Security and Access Policy offer additional details regarding responsibilities related to cybersecurity. 

Activities that heighten the risk of Foreign Interference and Influence 

Defence Trade Controls Act 2012 

(21) The University, through its Research and Innovation (RI) team, provides support to academic researchers in meeting their obligations under the Act, such as those concerning national security and defence-related research. However, ultimate responsibility and liability rest with the individual conducting the research. Each researcher must fully understand the potential strategic defence risks associated with their projects and proactively seek assistance by contacting Research and Innovation to arrange for necessary permits or approvals.  See the Defence Export Controls Policy for more information.

Autonomous Sanctions

(22) Working with individuals, countries, or organisations that are on sanction lists can significantly impact a broad range of University activities. The level of vigilance in managing these risks must be proportional to the level of international engagement. This is particularly critical when the engagement is either new or subject to changes. Employees are required to:

1. regularly refer to the Department of Foreign Affairs and Trade (DFAT) website to understand the current governing regimes and the geopolitical nuances that may affect international engagements; and
2. check the DFAT Consolidated List before initiating any new engagement or when existing engagement evolves. It is mandatory for employees to check if any of the entities or individuals involved are listed on the Consolidated List maintained by DFAT. 

Critical and Emerging Technologies

(23) Certain technology areas may present elevated foreign interference, research security, export control, cybersecurity or national security risks. Enhanced due diligence and risk assessment should be applied to activities involving:

1. artificial intelligence (AI);
2. advanced computing;
3. cyber security technologies;
4. biotechnology;
5. defence-related technologies;
6. dual-use technologies;
7. sensitive datasets; and
8. other technologies identified by the Australian Government as strategically significant.

Responsibilities for reducing risk – due diligence

Assessment of Foreign Arrangements

(24) All employees and students from within the faculties or TAFE, organisational units, research centres and institutes must evaluate whether a proposal to engage in a foreign arrangement meets the criteria set out in the Foreign Arrangements Procedure. 

Due Diligence and Risk Mitigation 

(25) All employees and students from within the Faculties or CDU TAFE, organisational units, research centres or Institutes who are proposing to engage in a foreign arrangement are responsible for ensuring that due diligence and risk mitigation assessments are conducted across all its activities and operations. This includes, but is not limited to: overseas travel, international visits to the University, visiting scholar appointments, collaborations, recruitment (including HDR students), secondments, exchanges, partnerships, and scholarships. All assessments should align with the University Foreign Interference Taskforce (UFIT) Guidelines to Counter Foreign Interference whenever a risk is identified.

(26) CDU will provide ongoing education and training to all employees and students on how to identify and respond to activities at risk of foreign interference. This will include awareness programs, decision-making guidance, and scenario-based learning modules, as recommended in national guidelines.

Additional Roles and Responsibilities

(27) The Vice-President Global and External Relations:

1. notifies the government of existing, proposed, and confirmed foreign arrangements, subsidiary arrangements under foreign arrangements, and substantial variations to previously noted foreign arrangements as per the Foreign Arrangements Procedure;
2. serves as the University’s central point of contact for all declarations or advice from the Minister for Foreign Affairs or DFAT regarding the commencement, continuation, alteration, or cessation of the University’s foreign arrangements; 
3. establishes and maintains a register of all notified arrangements, including universities considered non-autonomous and all common arrangements that should or should not be notified; and
4. collaborates with the Chief Information and Digital Officer and Director Risk and Assurance to conduct appropriate threat, risk, and security assessments as required by Governance, and Information and Communication Technology (ICT) security requirements.

(28) The Chief Information and Digital Officer:

1. integrates foreign interference risk considerations into the University’s information security risk framework, ICT system access reviews, compliance management protocols and incident response plans; and
2. works collaboratively with Legal, Governance, and Procurement teams to ensure ICT-related procurement activities address foreign interference risks. Where relevant, this includes conducting due diligence on third-party vendors or partners, such as:
   1. assessing ownership and management structures;
   2. verifying business registration and background; and
   3. reviewing legal issues related to intellectual property.
3. incorporates foreign interference threat vectors into cyber-threat modelling and enterprise information security risk management;
4. oversees the sharing of IT network data relevant to foreign interference risk with the Australian Government, including under cyber incident reporting requirements; and
5. supports initiatives to embed cybersecurity as a whole-of-organisation responsibility.

(29) The Deputy Vice-Chancellor Research and Community Connection:

1. ensures that foreign interference risks are considered in all research collaborations, grant applications, and other research-related agreements;
2. makes required notifications under the Foreign Arrangements Procedure;
3. ensures compliance with United Nations (UN) and Australian Autonomous Sanctions regimes for higher degree by research (HDR) students;
4. seeks assistance from the Chief Information and Digital Officer and the Vice-President Global and External Relations in ensuring security risks are addressed for defence research collaborations;
5. advises researchers on completing Defence Export Control System permits where applicable under the Defence Trade Controls Act 2012 and in compliance with the Defence Export Controls Policy; and
6. ensures compliance with all Australian sanctions laws in University research activities, assesses sanctions permit requirements, and notifies the Vice-President Global and External Relations of any contraventions.

(30) The Dean of Graduate Studies:

1. ensures that foreign interference risk is considered in research education collaborations, and other related agreements managed by Research and Innovation.
2. ensures compliance with United Nations (UN) and Australian Autonomous Sanctions regimes for higher degree by research (HDR) students.

(31) Director CDU Global:

1. considers foreign interference risks in all international collaborations, agreements, MOUs, partnership proposals, and related agreements; and
2. makes required notifications under the Foreign Arrangements Procedure.

(32) The Director Student Engagement:

1. assists in identifying and engaging at-risk student groups to provide them with foreign interference information and education at point-of-need.

Section 5 - Non-Compliance

(33) Non-compliance with governance documents is considered a breach of the Code of Conduct - Employees or the Code of Conduct - Students, as applicable, and is treated seriously by the University. Reports of concerns about non-compliance will be managed in accordance with the applicable disciplinary procedures outlined in the Charles Darwin University and Union Enterprise Agreement 2025 and the Code of Conduct - Students.

(34) Complaints may be raised in accordance with the Complaints and Grievance Policy and Procedure - Employees and Complaints Policy - Students.

(35) All employees have an individual responsibility to raise any suspicion, allegation or report of fraud or corruption in accordance with the Fraud and Corruption Control Policy and Whistleblower Reporting (Improper Conduct) Procedure.