Corruption & Collusion

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Corruption & Collusion

  • How can it happen?
  • Internal/external collusion — if a staff member colludes with an external supplier to procure goods/services to get a personal benefit

  • “kick-backs” — payments made by service provider organisations to their employees/executive using Commonwealth funding

  • Acceptance of gifts/hospitality over specified amounts

Conflict of Interest

• A conflict of interest occurs when an employee is influenced, or may be perceived to be influenced, by personal interests when conducting his/her official duties

• If you have a conflict of interest, or are unsure, talk to your manager

External Fraud

  • Fraud by participants
  • Fraud by providers

External fraud — some examples

  • Examples include:
    • Community organisations receiving funds from the Agency and fraudulently misusing the money
    • Providing false or misleading financial information/reports to the Agency
    • Overcharging the Commonwealth for services
    • Submitting false invoices
    • Misuse of assets (including unauthorised acquisition or disposal)
    • Submitting audit reports that are not independent or are inaccurate

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Things to watch out for

• Things to watch out for:

  • Breeches to funding agreement/grants guidelines
  • Delays in providing reports or answering communications
  • Failure to submit reports required
  • Lack of records for invoices and purchase orders
  • Conflicts of interest in the Board/CEO
  • Complaints from ex-staff or clients
  • Poor internal controls and lack of policies in organisations
  • High staff turnover
  • Poor governance – no separation of duties, one person performing multiple roles

External fraud - penalties

  • Penalties and sanctions may include:
    • Criminal conviction
    • Imprisonment
    • Fine
    • Repayment of monies
    • Confiscation of assets

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Your role

  • Report any weaknesses in Agency business controls or processes that might facilitate fraud against the Commonwealth to the NDIA Fraud Manager [redacted — s22(1)(a)(ii)].

  • You can report any suspected fraudulent or unethical behaviour to your immediate supervisor or the NDIA Fraud Manager Craig Rogan.

  • You can provide information about suspected fraudulent or unethical behaviour impacting NDIA or the Scheme by email to [redacted — s22(1)(a)(ii)] or by calling 1800 650 717. Information may be provided anonymously.

What not to do

• DO NOT

— Attempt to investigate the fraud yourself — Alert the suspect

— Mark or unnecessarily handle documents or material — keep in original condition

— Discuss the matter with anyone, including colleagues, other than for appropriate reporting purposes

  • Helen McKenna – (02) 6146 3464
  • [redacted — s22(1)(a)(ii)]