Counter Terrorism Policy

This Policy is also available as a downloadable PDF.

Burnet undertakes activities throughout Australia and internationally in collaboration with other medical research organisations and as part of its public health and international health programs with various partners and third parties.

Organisations such as Burnet are at risk of being misused by individuals and other organisations to finance or support terrorist activity. Burnet recognises that this risk would be increased if Burnet does not exercise appropriate oversight of the delivery and operation of the projects it funds, particularly where Burnet is not able to provide direct oversight over programs/projects.

This policy sets out Burnet’s commitment to comply with Australian laws relating to counterterrorism through processes and policies that minimise the risk of support for terrorists, terrorist organisations. This policy responds to the risk of dealing with organisations and individuals associated with Terrorism.

• Parts 5.3 and 5.5 of the Criminal Code Act 1995 (“the Criminal Code”)

• Part 4 of the Charter of United Nations Act 1945 ("the UN Charter Act”).

The Attorney-General’s Department maintains a ‘List of Terrorist Organisations’ which have been proscribed by the Government as terrorist organisations under Division 102 of the Criminal Code.

Similarly, The Department of Foreign Affairs and Trade maintains a ‘Consolidated List’ of persons and entities which are subject to imposed targeted financial sanctions. The Commonwealth Department of Australian National Security maintains a list of known terrorist organisations (as classified under the Criminal Code).

Amongst other activities it is an offence under Australian Law to receive or make available funds to, or provide support or resources to listed individuals, persons, entities, or organisations, including their Personnel. The lack of intent to commit an offence is not a defence.

Burnet’s legal obligations in accepting and administering Commonwealth and/or State funding as well as funding from various other sources impose a requirement for Burnet to ensure that those funds are dispersed only for the intention for which they were awarded. Burnet must make all reasonable effort to ensure that funds are not being directed to terrorist activities.

Burnet renounces all forms of terrorism and will never knowingly support, tolerate or encourage terrorism or the activities of those who embrace terrorism and will make every effort to ensure that its resources are not used to facilitate terrorist activity. The Australian Government has an extensive legislative regime focusing on counter-terrorism and national security. National and international funding bodies impose strict obligations on funding recipients to ensure funds do not support terrorist activities.

Burnet must use best practice principles to ensure that its research, public and international health activities are conducted in the context of these laws and obligations that prohibit dealing with listed terrorist organisations and/ or proscribed persons or entities.

This policy covers all Burnet employees in the course of their work and persons representing Burnet, which includes:

• Members of the Burnet Board

• All Burnet employees, including managers and supervisors; full-time, part-time or casual, temporary or permanent staff; job candidates; student placements

• Contractors, sub-contractors, suppliers and volunteers

• Burnet honorary staff and associates

• Overseas partner organisations (where Burnet staff are placed)

• Partner organisations (engaged in overseas activities with Burnet programs), and

• Any person representing the organization at Burnet’s request.

‘All reasonable efforts’ is used to reflect the need for positive action and a common sense approach, based on the level of risk, to meet legal obligations and avoid inadvertently financing terrorist activity.

‘Funds’ refers to assets of any kind or property of any kind, whether tangible or intangible, movable or immovable, however acquired, and legal documents or instruments in any form, including electronic or digital, evidencing title to, or interest in, such property or assets, including, but not limited to, bank credits, travellers cheques, bank cheques, money orders, shares, securities, bonds, debt instruments, drafts and letters of credit.

‘Listed individuals or organisations’ means any individual or organisation which appears on one of the three proscribed lists:

• Criminal Code Act List

• Sanctions List 

• World Bank List

‘‘Suspicious activity’ is any activity where a known or suspected terrorist individual or organisation is involved, or where a known or suspected terrorist act is to occur. This includes, but is not limited to, any activity involving any listed individuals or organisations.

‘Third Party’ is any individual or organisation to which the Burnet provides funding or support to, or receives funding or support from, to carry out its usual functions, including fund raising and delivering aid. ‘Third Party’ includes, but is not limited to, partners, intermediaries, contractors, sub-contractors and service providers.

Burnet acknowledges that Australian legislation prohibits dealing with listed terrorist organisations and/or proscribed persons.

Burnet acknowledges its obligations under these laws and will exercise all reasonable care and make every reasonable effort to ensure that its funds and program activities are not misused to support terrorism or terrorist activities.

Burnet will use best practice principles/due diligence (when it conducts its activities with collaborators, partners and other third parties) to ensure its funds are used only for the purpose for which the funds were awarded and are not used to support terrorism or terrorist activities.

Best practice principles/due diligence will include using regulated financial institutions for financial transactions with its collaborators and third parties as set out in the Counter Terrorism Procedures guide.

Burnet will confirm the identity, credentials and good standing of all Third Parties that receive funding support and will check that these organisations and their key personnel are not on the prohibited lists maintained by the Australian Government. Third Party due diligence will be re-verified at least annually, or more frequently where there are material changes to project scope, ownership, funding source, or country of operation.

Burnet will use its best endeavours to ensure that overseas recipients of Burnet funds will adopt policies and procedures that enable them to comply with relevant anti- terrorist legislation.

Burnet will report any known or suspected terrorist links or terrorism related activity to the relevant national authority.

Any Burnet staff member or student who is or proposes to engage in any activity or partnership with a foreign government, foreign university, foreign business or any other foreign organisation or entity as part of their Institute business must undertake an evaluation, where is reasonably practicable, of the risk of foreign interference, foreign influence and/or statutory reporting or regulatory obligations that is posed by the proposed activity or partnership.

The Board is responsible for the review and endorsement of this policy. The Board and Finance Audit Risk Committee will receive a periodic report from the Chief Operating Officer on compliance with this policyt. This policy will be formally reviewed at least every two years, or earlier if legislative or operational changes occur.

The Executive through the COO is responsible for the implementation and review of this policy.

All Burnet employees, students & representatives covered by this policy are required to comply with this policy and associated procedures.

The Chief People Officer (Melbourne Office) or their delegate ensures that all board members and Melbourne-based employees are checked against the DFAT proscribed lists prior to employment.

Human Resources Managers (for PNG, Myanmar and Vanuatu offices) ensure that all locally based suppliers and employees are checked against the DFAT proscribed lists prior to employment, and employees complete induction and refresher training

Working Group Heads, Activity Leads and Activity Managers are responsible for confirming the identity, credentials and good standing of all research partners/collaborators and will check that these organisations and their key personnel are not on the prohibited lists proscribedby the Australian Government.

Human Resource managers are responsible for ensuring that all employees, contractors and relevant Third Parties complete counter-terrorism awareness training at induction and refresher training every two years. Training completion rates will be included in the annual compliance audit.

• Part 3, Section 102.6, 102.7 and 103.1 of the Criminal Code Act 1995

• Australia’s Counter-Terrorism Laws

• Australian NGO Accreditation Guidance Manual, November 2025Criterion E2.1 ANGO regularly assesses the financial and risk management systems and capacity of partners (fiduciary assessment) before contracting 3

• Australian Council for International Development Code of Conduct Section 8.2. WE ENSURE THAT FUNDS AND RESOURCES ENTRUSTED TO US ARE PROPERLY CONTROLLED AND MANAGED

• Safeguarding your organisation against terrorism financing (Australian Government 2009)

• ACNC Checklist: protecting your charity against risk or terrorism financing

• Defence Trade Control Act, 2012

• Part 4 of the Charter of United Nations Act 1945 (UN Security Council Decisions that Relate to Terrorism)

• The United Nations Security Council Resolution 1373 (2001) to combat terrorism

• Charter of the United Nations (Dealing with Assets) Regulations 2008

• Australian Human Rights Commission: A Human Rights Guide to Australia’s Counter Terrorism Laws (2008)

• Attorney General Department’s List of Terrorist Organisations

• Department of Foreign Affairs & Trade’s Consolidated List

• Australian National Security Criminal Code Act List

• Burnet Counter Terrorism Procedures