corruption prevention procedures australia

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CORRUPTION PREVENTION PROCEDURES

State of NSW, Department of Education and Training, Audit & Risk Management

Directorate, 2006

Copies of this document may be made for use in connection with DET activities on thecondition that copies of the material shall be made without alteration and must retainacknowledgement of the copyright.

Any enquiries about alterations, or about reproduction for other purposes, includingcommercial purposes, should be directed to Audit & Risk Management Directorate on 029244 5210 in the first instance.

Unique identi fier : PD/2004/0009/V01


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Corruption Prevention Procedures

Contents

1. Procedures and Standards 3

1.1 Responsibi lity Structures 3

1.2 Current Corruption Risk Assessment 3

1.3 Employee Awareness 4

1.4 Customer and Communi ty Awareness 4

1.5 Corruption Report ing Systems 5

1.6 Detection Systems 5

1.7 External Notifi cations 6

1.8 Investigation Standards 7

1.9 Conduct and Disciplinary Standards 7

2. Related Documents and Forms 8

3. For Further Information 10

4. Appendices 10

4.1 Appendix 1 STRATEGIES 10

4.2 Appendix 2 DEFINITIONS 13

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1. Procedures and Standards

1.1 Responsibili ty StructuresAll staff have a role in corruption prevention. There are some positions, groups andcommittees with specific responsibilities. The following groups have responsibilitieslisted in sections 1.2 to 1.9 below:

DET Board of Management & TAFE Commission Board

DET Audit & Risk Management Committee

Investigations Committee

Audit & Risk Management Directorate

Employee Performance and Conduct Directorate

Nominated Disclosure Officers

All State Office Directors and Senior Officers

TAFE Institute Management (Directors, Associate Directors and Managers)

Regional Directors, Deputy Regional Directors and School Education Directors

All principals, managers and supervisors (includes all of the above)

All staff

1.2 Current Corrupt ion Risk Assessment

Corruption can occur whenever a person supplies or has access to resources orinformation or has responsibility for decision making. Since this describes almost anyworkplace activity, all activities should be designed with an awareness of the corruptionrisks which arise in the activity and the management controls that can reduce the riskto an acceptable level.

The Audit & Risk Management Directorate has a key role in assisting management toidentify and control risks including risks of corrupt conduct through regular audits andcontrol risk assessments. However, it is the manager responsible for the operation whohas ultimate responsibility for the control of the operations activities. Management isrequired to establish a risk management framework that is integrated with the internalcontrol system.

Resources useful in the identification of corruption risks and controls include:

AUS 210 The Auditors Responsibility to Consider Fraud and Error in an Audit of aFinancial Report, Auditing Standard, Australian Accounting Research Foundation

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AS 8004-2003 Corporate governance - Whistleblower protection programs forentities, Standards Australia

HB 405-2004 Disclosure and Transparency Frameworks, Standards Australia

HB 408-2006 Corporate governance culture, Standards Australia

AS 8001-2003 Fraud and Corruption Control, Standards Australia

AS/NZS 4360: Risk Management Standard, Standards Australia

Audit & Risk Management Directorate Intranet site - publications

DET Business Continuity Planning

DET Statement of Business Ethics

TAFE NSW Best Practice Guide Fraud & Corruption Prevention

TAFE NSW Institute Internal Control Checklist

1.3 Employee Awareness

Staff who have responsibilities for resources, decision making or information need tobe aware of the behaviours that could result in corruption, either actual or perceived.All supervisors need to be aware of the corruption risks in the activities they supervise.

This understanding can be developed through:

Staff familiarising themselves with the relevant conduct standards (see 1.9.1below) including the current Code of Conduct that have been issued by theDepartment

Involvement of supervisors and managers in risk assessment activities includingthose conducted in conjunction with the Audit & Risk Management Directorate

The use of staff meetings and training sessions to identify the corruption risksinherent in an activity or workplace and the controls in place to address them

Including questions on ethics issues and ethical practice in staff selectioninterviews

Providing corruption awareness and ethics training

Including reference to the Corruption Prevention Policy in staff induction resources

Providing corruption awareness publications including resources on the DET

intranet.

1.4 Customer and Community Awareness

Corrupt conduct can be reduced through the education of customers and communityabout acceptable standards of behaviour of DET staff and of the customers andcommunity members themselves. As expectations about the giving and receiving ofgifts and bribes can differ from one culture to another, it is important that governmentagencies explain their expectations to the community.

Any attempt by a member of the public to corrupt a DET staff member would be corrupt

conduct under the ICAC Act. When detected, such attempts must be reported by DETto the ICAC.

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Useful resources for raising customer and community awareness include:

ICAC pamphlets designed to be issued to the public

Information on fraud and corruption prevention issued (eg in contract documents)to suppliers of goods and services (DET Statement of Business Ethics).

Warning signs located at the time/place where fraud or corrupt conduct is known tobe a risk.

1.5 Corruption Reporting Systems

The requirement to report suspected corrupt conduct is found in the DET Code ofConduct and DET complaints policy Responding to Suggestions, Complaints andAllegations.

If staff become aware that any staff member has been subject to or engaged in corruptconduct, as defined in clause 6.2 of this policy, it must be reported immediately. Staffare also encouraged to report other forms of corrupt conduct as well asmaladministration and serious waste of public funds.

The DET procedures for internal reporting of corrupt conduct are contained inResponding to Suggestions, Complaints and Allegations and Protected Disclosures -Internal Reporting Policy (see section 1.6 below) or on the DET Policies Websiteathttp://detwww.det.nsw.edu.au/policies/index.shtml.

Protected Disclosures

The legislative requirements for protecting staff who make disclosures of corruption,maladministration and serious and substantial waste are contained in the ProtectedDisclosures Act 1994.

The DET policy onProtected Disclosures - Internal Reporting applies that legislation toDET and TAFE NSW and in particular lists those positions which can receive aprotected disclosure.

The Employee Performance and Conduct Directorate provides information kits andtraining for Nominated Disclosure Officers on appointment and/or request.

Human Resources Directorate manages the Complainant and Witness SupportProgram for staff involved in making protected disclosures.

1.6 Detection Systems

Detection systems are one of a number of elements that contribute to establishing acorruption control environment for the Department of Education and Training.

The department has established early warning systems to alert it to possible corruptionproblems.

The department undertakes regular reviews and checks to detect irregularities both asa routine part of regular line management and independently of line management via

the Audit & Risk Management Directorate.

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Basic data mining tools are used routinely by line management and advanced datamining tools are used by the Audit & Risk Management Directorate.

1.7 External Notifications

The obligation to refer criminal matters to the police is contained in section 316 of the

Crimes Act 1900.

Section 9 of the Personnel Handbook issued by Premiers Department states thatwhere it is reasonably believed that an officer has committed a criminal offence, thematter should be referred to the Police. In such cases generally the Department wouldinvestigate sufficiently to form this view leaving further investigation to the Police.

The requirement that the Director-General/Managing Director refer suspected corruptconduct to the ICAC is contained in section 11 of the ICAC Act 1988.

The requirements to report suspected child protection breaches to the Department ofCommunity Services and the NSW Ombudsman are contained in Departmental policy

documentResponding to Allegations Against Employees in the Area of ChildProtection as well as section 27 (mandatory reporting provisions) of the Children andYoung Persons (Care and Protection) Act 1998.

Actions required Groups responsible

Refer complaints of criminaloffences to the NSW Police

Victims of crimes should report those crimes tothe Police.

All DET staff are required by law to report seriouscrimes (punishable by 5 or more years gaol) tothe Police.

All staff have the right to report suspected corruptconduct to ICAC, alleged maladministration to theOmbudsman and suspected waste to the AuditOffice if they do not wish to report it internally.

Only the Director-General/Managing Director canofficially refer departmental matters to the ICAC.

The Director, Employee Performance andConduct prepares this advice for the DG/MD.

Refer matters to ICAC, theOmbudsman and the AuditOffice of NSW

The Director, Employee Performance andConduct prepares advice on child protectionmatters for the DG/MD.

DG/MD must report to the Audit Office of NSWany serious discrepancies that might affect theannual financial audit and the Annual FinancialStatements.

Refer matters to the Audit Officeof NSW

The Director of Audit & Risk Managementprepares this advice for the DG/MD

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Actions required Groups responsible

Reporting and referral of childprotection matters

All DET staff must report suspected risks of harmto children and young persons to the school

principal or workplace manager.Child Protection referrals to DoCS are theresponsibility of school principals and workplacemanagers.

Refer Child Protection mattersto the NSW Ombudsman andthe Commission for Childrenand Young People as required

Director Employee Performance and Conduct

1.8 Investigation Standards

Alleged or suspected corrupt conduct will be investigated by the appropriate DETsection or referred to the appropriate external agency for investigation.

Investigation policies and standards relevant to DET staff are found in:

the documents listed in section 1.9.2 below

Responding to Suggestions, Complaints and Allegations 2001

Responding to Allegations Against Employees in the Area of Child Protection,2004

Employee Performance and Conduct Directorate Investigation Manual

Further advice can be found in:

The Complaint Handlers Tool Kit, NSW Ombudsman 2000

Internal Investigations, ICAC 1997

If alleged corrupt conduct involves criminal activity it will be subject to the standards ofthe relevant police.

If alleged corrupt conduct is investigated by the ICAC, or another external agency suchas the Ombudsman or the Audit Office of NSW, then their investigation standards willapply.

1.9 Conduct and Disciplinary Standards

1.9.1 Conduct Standards

The main source of conduct standards for DET employees is the currentDET Code ofConduct.

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Other legislation and DET policy documents that set out conduct standards in areasthat have high risk of corrupt conduct include:

Legislation

Ombudsman Act 1974

Protected Disclosures Act 1994

Public Finance and Audit Act 1983

Public Sector Employment and Management Act 2002

ICAC Act 1988

NSW Crimes Act 1900

Treasurers Directions

DET Policy

DET Purchasing, Tendering and Contracting Handbook

Protecting and Supporting Children and Young People Revised Procedures(December 2000)

School Manual on Financial Management

TAFE Accounting Manual

Use by Employees of Employer Communication Devices

1.9.2 Disciplinary Standards

The disciplinary standards for DET employees are contained in various acts,regulations and determinations including:

Education Legislation Amendment (Staff) Act 2006

Education Teaching Services Regulation 2001

Public Sector Employment and Management Act 2002

Public Sector Employment and Management (General) Regulation 1996

TAFE Commission Act 1990

TAFE Disciplinary Determination 1996

These documents set out the behaviours that constitute a breach of discipline and howthat breach will be dealt with.

2. Related Documents and Forms

The Corruption Prevention policy site under the heading Related Information containssome related documents.

Other related documents include: DET Business Continuity Planning

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DET Statement of Business Ethics

Education Teaching Services Regulation 2001

Responding to Allegations Against Employees in the Area of Child Protection

Internal Investigations, ICAC 1997

Protected Disclosures Internal Reporting Policy

NSW Public Service Personnel Handbook

Public Sector Employment and Management (General) Regulation 1996

Responding to Suggestions, Complaints and Allegations 2001

School Manual of Financial Management

TAFE Accounting Manual

TAFE NSW Institute Internal Control Checklist

Technical and Further Education Commission Act 1990

The Complaint Handlers Tool Kit, NSW Ombudsman 2000

Treasurers Directions

3. For Further Information

This document is the responsibility of the Audit & Risk Management Directorate.Further information for staff can be found on the DET Audit & Risk Managementintranetsite or obtained from the Director of Audit & Risk Management (9244 5150) orthe Manager, Corruption Prevention (9244 5210). Suggestions about the updating ofmaterial in this document should be made to the Director of Audit & Risk Managementor the Manager, Corruption Prevention.

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4. Appendices

4.1 Appendix 1 - STRATEGIES

Responsibi lity Structures The Audit & Risk Management Committee to ensure currency of the departments

policy on corruption prevention.

Directors, principals and managers to ensure effective operation of appropriatefinancial and administrative controls, and management oversight in their schools,institutes and offices.

The Employee Performance and Conduct Directorate to advise on the need toinvestigate allegations or instances of apparent corrupt conduct and reportoutcomes to management and to the Investigations Committee.

The Audit & Risk Management Committee to provide advice to the Director-General/Managing Director on the effectiveness of the departments corruptionprevention policy and strategies.

Corruption Risk Assessment

Audit & Risk Management Directorate to continue undertaking structured riskassessments as part of its three year planning process.

Audit & Risk Management Directorate to continue evaluating the risk of corruptconduct, including fraud, during the planning and conduct of individual audits.

Directors, principals and managers to analyse corruption risks in their area of

responsibility and implement adequate controls to reduce risks to acceptable levels(where possible by eliminating opportunities for corrupt conduct).

Employee Awareness

Directors, principals, managers and supervisors ensure staff develop sufficientawareness of corruption risk and corruption prevention strategies through trainingcourses.

Audit & Risk Management Directorate and other State Office Directorates (withrespect to their area of operation) publish materials of known corruption risks andcontrols on the DET intranet.

Directors, principals, managers and supervisors include questions on ethics issuesand ethical practices in staff selection interviews.

Directors, principals, managers and supervisors include corruption preventionstrategies in performance reviews, where appropriate.

Directors, principals, managers and supervisors include reference to the Code ofConduct and Corruption Prevention Policy in staff induction resources.

Customer and Community Awareness

Directors, principals and managers provide corruption prevention messages innewsletters, letters, invoices, contracts etc.

Principals arrange for school council members to be invited to attend financial andethics training courses where appropriate.

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Audit & Risk Management Directorate continue to publish corruption preventionand ethics material on the Audit & Risk Management intranet and internet sites.

Finance and Administration Directorate continue to publish selected corruptioncontrol topics in publications to schools.

Audit & Risk Management Directorate continue to promote, and keep current, theDET Statement of Business Ethics.

Corruption Reporting Systems

All staff must report corrupt conduct and are encouraged to reportmaladministration or serious waste. A separate policy exists on ProtectedDisclosures Internal Reporting which explains how staff can report theseconcerns as a protected disclosure.

Directors and above ensure that all cases of suspected corrupt conduct arereported to the Employee Performance and Conduct Directorate and liaise withthem to determine who should investigate.

Principals and workplace managers to report all allegations against DETemployees in the area of child protection to the Director, Employee Performanceand Conduct.

Employee Performance and Conduct Directorate to report all cases of corruptconduct to the Investigations Committee and the Director-General/ManagingDirector.

Employee Performance and Conduct Directorate to maintain a confidentialdatabase of all complaints and allegations received in relation to corrupt conduct.Manager, Corruption Prevention to be provided with a copy of this database on amonthly basis.

Protected Disclosures

Employee Performance and Conduct Directorate to maintain policy documents andensure that Nominated Disclosure Officers are aware of their responsibilities byproviding information kits.

Employee Performance and Conduct Directorate to provide individual or grouptraining for new Nominated Disclosure Officers.

Nominated Disclosure Officers receive, forward and act on disclosures made tothem in accordance with the policy.

Human Resources Directorate manage the Complainant and Witness SupportProgram for staff involved in making protected disclosures.

Directors, principals, managers and supervisors ensure that staff who makedisclosures do not suffer detrimental action by staff under their supervision.

All staff to ensure that staff who make disclosures do not suffer detrimental actionwith respect to their own behaviour.

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External Notifications

Directors, principals and managers who are aware that a serious crime has beencommitted must report it to the local police if it has not already been reported tothem.

Director-General/Managing Director officially refers allegations of corrupt conductto the ICAC.

Director of Audit & Risk Management prepares advice for the DG/MD to enablehim to report to the NSW Auditor-General any serious discrepancies that mightaffect the annual financial audit and/or the Annual Financial Statements.

All staff have the right to report suspected corrupt conduct to the ICAC, allegedmaladministration to the NSW Ombudsman and suspected serious and substantialwaste to the NSW Auditor-General if they do not wish to report it internally.

School principals and workplace managers are responsible for referring childprotection matters to the Department of Community Services (DoCS).

Director, Employee Performance and Conduct refers child protection matters to theNSW Ombudsman and the Commission for Children and Young People, asrequired.

Investigation Standards

Employee Performance and Conduct Directorate, or line management underdelegation, conduct internal investigations depending on the nature andseriousness of the matter.

Employee Performance and Conduct Directorate maintain documentation ofinvestigation standards and oversee their application.

Employee Performance and Conduct Directorate maintains a secure database ofall suspected corrupt conduct, other than child protection matters, for referral to theICAC.

Employee Performance and Conduct Directorate maintains a secure database ofall corrupt conduct relating to child protection issues.

Conduct and Discipl inary Standards

Employee and Performance Conduct Directorate publishes and maintains acurrent departmental Code of Conduct.

Audit & Risk Management Directorate publishes and maintains the DepartmentsCorruption Prevention Policy.

Relevant state office directorates and TAFE Institute management publish otherdocuments that describe any additional required standards of conduct in theirworkplaces.

Directors, principals, managers and supervisors develop and maintain staffawareness of the required standards of conduct.

All staff familiarise themselves with relevant documents, policies and procedures.

Employee Performance and Conduct Directorate and TAFE Institutes implementdisciplinary action when required.

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Monitoring, Evaluation and Reporting Requirements

Directors, principals, managers and supervisors monitor and evaluate compliancewith this policy on an ongoing basis.

Audit & Risk Management Directorate, the ICAC, NSW Ombudsman and NSW

Auditor-General conduct reviews and audits of departmental work sites of theadequacy of local corruption prevention strategies.

Audit & Risk Management Directorate incorporates corruption resistance surveysof departmental work sites in the annual audit plan.

Audit & Risk Management Committee monitors the effectiveness of departmentalcorruption prevention strategies.

4.2 Appendix 2 - DEFINITIONS

Corrupt conduct

Corrupt conduct occurs where:

any person adversely affects the honest and impartial exercise of official functions(eg offer, provision or acceptance of a bribe to/by a DET staff member), or where

a DET staff member:

- is dishonest or partial in the exercise of official functions (for example byimproperly awarding a benefit to a relative or friend); or

- breaches public trust (for example by using DET assets for private purposeswithout proper authority to do so); or

- misuses information or material for personal gain or gain by another person(for example by improperly releasing personnel details or examinationquestions);

and

the matter is sufficiently serious to constitute a criminal or disciplinary offence.

Corruption Prevention

Corruption prevention includes all organisational features designed to resist or limitcorrupt and/or fraudulent practices. These features include accountability and effectiveand efficient administration. Corruption prevention focuses on improving systems andprocedures, changing the attitudes of staff and improving the overall integrity andperformance of the organisation. It involves management commitment, staffcommitment, resources and networking.

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Corruption Risk Assessment

Corruption risk assessment is the overall process of corruption risk analysis and riskevaluation.

Fraud

Fraud is the use of deceit to obtain unfair advantage to the detriment of others. It mayinvolve money, equipment or academic standing.

Internal Contro l

Internal control is defined as a process, implemented by directors, management andother personnel to provide reasonable assurance of the achievement of the following:

Effectiveness and efficiency of operations including business objectives and

safeguarding of resources.

Reliability of financial reporting including operating information.

Compliance with applicable laws, regulations, policies and procedures.

Maladministration

Maladministration is defined as conduct that involves action or inaction of a seriousnature that is contrary to law, unreasonable, unjust, oppressive, improperlydiscriminatory and based wholly or partly on improper motives.

Risk Management

Risk management is the systematic application of management policies, proceduresand practices to the task of establishing the context, identifying, analysing, evaluating,treating, monitoring and communicating risk.

Serious and Substantial Waste

Serious and substantial waste refers to the uneconomical, inefficient or ineffective useof government resources, authorised or unauthorised, which results in significant lossor wastage of public funds or resources.