Corruption & Collusion
- How can it happen?
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Internal/external collusion — if a staff member colludes with an external supplier to procure goods/services to get a personal benefit
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“kick-backs” — payments made by service provider organisations to their employees/executive using Commonwealth funding
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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
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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)].
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You can report any suspected fraudulent or unethical behaviour to your immediate supervisor or the NDIA Fraud Manager Craig Rogan.
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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)]