PORTFOLIO FRAUD AND CORRUPTION PREVENTION
PLAN 2019-21
Policy Statement
The Environment, Planning and Sustainable Development Directorate, City Renewal Authority and
Suburban Land Agency (referred to collectively as the Portfolio) have a zero-tolerance policy towards
fraudulent activity or corrupt behaviours by staff, contractors, third party service providers, and
clients.
The Portfolio is strongly committed to preventing, identifying and eliminating fraud and corruption
and raising awareness within the Portfolio. To enable this we promote a culture of learning,
disclosure, transparency and accountability, where it is safe to learn from genuine mistakes and raise
questions and concerns.
The act of committing fraud or corruption within the Portfolio is a very serious matter and will not be
tolerated. Any such acts will be dealt with to the maximum extent possible within the law, and will be
reported to the Police for investigation and prosecution where appropriate.
Purpose
The Portfolio Fraud and Corruption Prevention Plan 2019-21 (the Plan) has been developed to raise
awareness of fraud and corruption. It also aims to assist Portfolio staff to prevent, detect and report
suspected fraud and corruption and guide the management of cases of alleged fraud and/or
corruption. This Plan should be read in conjunction with the Portfolio Integrity Framework
(Framework) which outlines the integrity management response arrangements, activities and
obligations required of the Portfolio and its staff. The Framework draws together relevant policies to
ensure staff are aware of their responsibilities to act ethically and appropriately recognising the trust
of the community.
Part 2.3 of the
Public Sector Management Standards 2006, requires agencies to adopt an active
preventative strategy towards the control of all breaches of integrity, including fraud and corruption.
The ACTPS
Integrity Policy 2010 (Integrity Policy) aims to prevent the incidence of fraud and
corruption through the implementation and regular review of a range of fraud prevention and
detection strategies. The Integrity Policy also requires agencies to undertake a fraud and integrity risk
assessment and review their Fraud and Corruption Prevention Plans at least once every two years.
Fraud and corruption risk management forms part of the business planning cycle and contributes to
business performance through minimisation of the Portfolio’s risks. This provides assurance to
Executives, portfolio agency Boards and relevant audit and risk committees that appropriate fraud
and corruption risk management is occurring within the Portfolio.
Scope
This Plan applies to all Portfolio staff including:
• Permanent and temporary ACT Government personnel and executives;
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• Board members of the City Renewal Authority and the Suburban Land Agency performing
their functions for their respective territory authority
• Non-government personnel including contractors and consultants acting for, or on behalf of,
the Portfolio.
Definitions
Term
Definition
Corruption (as defined in the
In relation to an employee, [corruption] means that the
ACTPS Integrity Policy 2010)
employee seeks, obtains or receives any benefit, other than
lawful salary and allowances on the understanding that the
employee will do or refrain from doing anything in the course of
their duties or will attempt to influence any other employee on
behalf of any person.
Examples of corruption include:
• Manipulating a tendering process to achieve a desired
outcome
• Unauthorised use of government facilities and time to
operate a private business
• Misusing information or material obtained during the course
of official duties
• Overstating working hours or claiming an allowance when not
eligible
• Receiving personal benefits in exchange providing
inappropriate advantage to commercial partners (e.g.
supplies, Lessees, etc) or other (e.g. levy payers, developers
etc)
• Not disclosing and/or allowing a conflict of interest to obtain a
preferred outcome.
Fraud (as defined in the ACTPS Taking or obtaining by deception, money or another benefit from
Integrity Policy 2010)
the government when not entitled to the money or benefit, or
attempting to do so – this includes evading a liability to the
government.
Fraud is not restricted to obtaining monetary or material benefit.
The benefits of fraudulent acts can either be tangible or
intangible. Examples of fraud include:
• Assisting others to obtain a benefit
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• Theft of money (cash, cheques, EFTPOS) due to the
government
• Charging personal expenditure on government credit or fuel
cards
• Unapproved use and misuse of motor vehicles and other
government assets
• Raising fictitious invoices
• Submitting false claims for reimbursement
• Releasing misleading or inaccurate information for the
purpose of deceiving, misleading or to hide wrong-doing.
Portfolio
Includes the administrative unit as determined by the
Administrative Arrangements (currently the Environment,
Planning and Sustainable Development Directorate, City Renewal
Authority and Suburban Land Agency) and their staff.
Roles and Responsibilities Across the Portfolio
The following roles and responsibilities are common across the Portfolio.
Role or Position or Business Area
Responsibility
Senior Executive Responsible for
• Ensure the Portfolio has a current Fraud and Corruption
Business Integrity and Risk (SERBIR)
Prevention Plan and that this plan is reviewed at least
every two years
• Monitor the Plan’s implementation and coordinate any
risk treatments
• Act as the primary senior executive point of contact for
allegations of fraud and corruption and determine how
escalated allegations should be handled
• Promote a culture of a well-informed, engaged and
ethical workforce.
• Provide oversight and make decisions on the direction
of enquiries related to fraud and corruption
• For EPSDD, ensure that Risk Registers reflect fraud and
corruption risks and are regularly reviewed and
updated
• For EPSDD, report to the Audit Committee, Executive
Steering Committee, and Executive Management Board
on the implementation of the Plan
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Role or Position or Business Area
Responsibility
• Ensure that the Plan is brought to the attention of staff
through training sessions, intranet or other media
• Review effectiveness of fraud and corruption
prevention measures following significant functional or
structural changes.
Disclosure Officers
• Appointed under the
Public Interest Disclosure Act 2012 • Responsible for undertaking initial assessments of a
disclosure (and decide whether a disclosure is a public
interest disclosure), where and how public interest
disclosure should be investigated, and act as a central
coordination point for all matters relating to public
interest disclosures (which may be suspected cases of
fraud and/or corruption, or breaches of the ACTPS
Code of Conduct)
Executive Branch Manager, People
• Ensure HR Delegations are up to date, accurate and
and Capability
accessible by all staff
• Review HR Delegations at least once a year
• Coordinate the development and delivery of training
programs, including on fraud, corruption and ethics.
Chief Finance Officers
• Ensure Director-General/CEOs Financial Instructions
are update to date, accurate and accessible by all staff
• Review Financial Instructions at least once a year or as
required.
All staff
• Become familiar with the Plan and contribute to its
effective implementation, thereby assisting in
minimising the incidence of fraud and corruption
within the Portfolio
• Report any fraudulent activity or corrupt behaviour
within the Portfolio that they become aware of or
suspect. Reports can be made to
managers/supervisors, any executive within the
Portfolio or the SERBIR
• Ensure declarations of any conflict of interest, either
actual, potential or perceived, are made immediately
that the conflict becomes apparent
• Comply with the
Public Sector Management Act 1994,
specifically section 9 – General obligations of public
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Role or Position or Business Area
Responsibility
employees, the ACTPS Code of Conduct and the ACTPS
Values and Signature Behaviours.
Integrity Commission
• The ACT Integrity Commission is established under the
Integrity Commission Act 2018 and is scheduled to
commence on 1 December 2019
• The Integrity Commission is an independent body
which has the power to investigate corruption in public
administration and strengthen public confidence in
government integrity.
Although the Plan applies to all Portfolio staff, there are specific roles and responsibilities in positions
unique to individual agencies.
• Attachment A – Roles and responsibilities within EPSDD
• Attachment B – Roles and responsibilities within in the City Renewal Authority
• Attachment C – Roles and responsibilities within the Suburban Land Agency
Plan Requirements
The Portfolio’s approach to fraud and corruption control is based on mitigation, detection,
investigation and response.
A. Mitigation
The Portfolio endorses fraud and corruption control activities and promotes a culture of staff
reporting potential cases of fraud and corruption.
Executives should ensure that all business processes, particularly those assessed as having a higher
predisposition to the risks of fraud and corruption, are subject to a rigorous system of internal
controls that are well documented, reviewed and updated regularly and understood by staff.
1. Mitigation Measures
The Portfolio implements the following fraud and corruption mitigation measures:
• Fraud and Corruption Plan and procedures are available to staff and brought to their
attention by the SERBIR, executives and managers
• Staff training, including on fraud, corruption, integrity and ethics
• Fraud and corruption control expectations are included in the new staff induction program
and regular mandatory training
• Portfolio fraud and corruption risk assessments are conducted at least every two years
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• Business unit-specific risk assessments should include consideration of fraud and corruption
risks
• Staff are made aware of their obligations under the relevant legislation, policies and
procedures
• Conflict of interest policies and procedures are regularly communicated to staff
• The Appointments and Delegations Register as well as individual appointment and delegation
instruments, including the DG’s/CEOs’ Financial Instructions and HR Delegations, are
regularly reviewed and updated and available to all staff
• Responsibilities for fraud and corruption control are contained in role descriptions where
appropriate
• Facilitation of the annual ACT Audit Office and Audit Committees financial statements
review.
2. Staff Awareness and Training
The most effective tool to prevent fraud and corruption is a well-informed, engaged and ethical
workforce, one which is prepared to uphold sound administrative decision-making and disclose
fraudulent activities and corrupt behaviours. It is the responsibility of all staff to act honestly and
with integrity at all times, and to be vigilant in detecting possible incidents of fraud and corruption.
The EPSDD Portfolio requires all staff to complete mandatory training courses within the Essentials
Framework and Managers and Supervisors Framework, including fraud and ethics. EPSDD has
launched an e-Learning package on fraud, corruption and ethics. Legal Services and Integrity is
providing Integrity training as part of the EPSDD Learning and Development Framework.
Targeted fraud and corruption prevention awareness training can be presented to business units that
have a higher disposition to potential fraud and corruption risks.
3. Fraud and Corruption Risk Assessment
A fraud and corruption risk assessment measures the vulnerability of an organisation to fraud and
corruption and is essential for fraud mitigation and control. At least once every two years, a targeted
fraud and corruption risk assessment is conducted across the Portfolio.
In the development of this Fraud and Corruption Prevention Plan 2019-2021, a fraud and corruption
risk assessment was conducted across the Portfolio and identified four fraud and corruption risks, of
which two were high (fraudulent or corrupt conduct occurs when procuring goods or services and
failure to protect personal and corporate information) and two were medium (misuse of public
property and money and misuse of delegations, position and/or workplace entitlements) (see Fraud
and Corruption Risk Assessment Attachment D).
As part of their regular assessment of risk, business units are required to ensure that fraud and
corruption risks are identified and reported to Audit and Risk/Authority Chief Operating Officer/
Governance and Policy Area for the reported risk to be captured into the relevant Risk Register. The
most important outcome of a fraud and corruption risk assessment process is the development of an
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effective anti-fraud and corruption treatment program that specifically addresses the risks faced by
the Portfolio. Treatments should be measured for effectiveness over time.
4. Supplier Controls
In some circumstances, the provision of services to the ACT Public Services is most appropriately
provided by the private sector. The
Government Procurement Act 2001 sets out the framework
within which these services are obtained.
The Portfolio communicates and enforces its expectations, relating to fraud and corruption control
via contractual agreements with private sector providers.
The ACT Government has implemented a whole of government Accounts Payable Invoice
Automation Solution (APIAS). This system requires separation between the coding of an invoice
received (and confirmation that the goods and/or services have been received in accordance with a
contract and the amount is correct) and the financial delegate approving payment.
5. Internal Policies
The following internal policies and procedures are available to all staff via intranets and regular all-
staff emails:
• Portfolio Integrity Framework
• ACTPS Integrity Policy 2010
• Director-General’s/CEOs’ Financial Instructions
• Enterprise Agreements
• Human Resource Delegations
• Conflict of Interest Factsheet
• Purchase of Land By Portfolio Staff, Contractors and Public Sector Members Policy
• Gifts and Hospitality Policies
• ACT Government - Acceptable Use of ICT Resources Policy
• ACT Government Public Interest Disclosure Guidelines (adopted by EPSDD, the City Renewal
Authority, and the Suburban Land Agency).
B. Detection
Fraud and corruption can be detected by establishing effective accounting and system controls and
by recognising variations from standard practice. In addition, staff cooperation, observation and
initiative are important in preventing and detecting fraud and corruption in the workplace.
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1. Fraud and Corruption Signals
Managers and staff should be alert to the common signs of fraud and corruption. Signals for
potential fraud and corruption may include:
• Implausible excuses and reasons for unusual events or actions
• Senior staff involved in routine process work such as purchasing, ordering and receiving
goods
• Staff evidently living beyond their means, who have access to funds, or control or influence
over service providers
• Excessive staff turnover
• Staff who do not take holidays for extended periods
• Potential conflicts of interest not declared
• Undue secrecy, or excluding people from available information
• Staff who treat controls and standard practices as challenges to be overcome or defied
• Unauthorised changes to systems or work practices
• Missing documentation relating to client or agency financial transactions
• “Blind approval”, where the person signing does not sight supporting documentation.
2. Reporting
If a staff member becomes aware of possible fraud and corruption, they are obliged to report their
concerns. In the first instance, it is generally best to report any concerns to an immediate supervisor.
Suspected cases of fraud and corruption relating to human resources matters (such as obtaining a
staff entitlement fraudulently or corrupt conduct during a recruitment process) should be reported
to People and Capability Branch, However, staff members may raise their concerns with any member
of the Executive and/or the SERBIR.
Staff should report suspicions to only those people who absolutely need to know. This protects
people from allegations that may not be proven and prevents the possible destruction of evidence.
3. Public Interest Disclosure
The
Public Interest Disclosure Act 2012 (PID Act) supports the reporting, assessment and
investigation of reported wrongdoing by an ACT public servant, including fraud and corruption. The
PID Act and procedures adopted by agencies provide a method of investigating allegations, while
protecting the individual who has made the disclosure from any reprisals.
Members of the public, as well as current and former ACT public servants may make a public interest
disclosure to any ACT government agency.
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Disclosable conduct includes activity or conduct (or combination thereof) by an individual or an ACT
Public Sector entity that is any of the following:
• Is illegal
• Misuses or wastes public money or resources
• Is misconduct
• Is maladministration
• Presents a danger to the health or safety of the public
• Presents a danger to the environment.
4. Financial Reporting and Data Analysis
EPSDD Strategic Finance, Suburban Land Agency Strategic Finance and the City Renewal Authority
Finance undertake monthly budget monitoring to track spending against budget and aim to identify
any inconsistencies as soon as possible. All staff involved in the expenditure of government funds
have a responsibility to ensure expenditure is lawful. This includes payment of funds, execution of
contracts and internal budget management.
The ACT Audit Office and agencies’ audit committees also conduct annual reviews of financial
statements.
5. Internal and External Audit
All areas of the Portfolio are expected to comply with their respective policies and procedures and
are subject to review under their respective internal audit programs, as well as external audits
undertaken by the ACT Audit Office.
C. Investigation and Responses to Fraud and Corruption
Initial investigation into reported fraud or corruption will be made by the SERBIR who will determine
whether there is any basis for further action. The SERBIR may appoint an officer within the Portfolio
to undertake enquiries or may acquire the services of external experts to assist in the conduct of any
inquiry. The SERBIR may refer the matter to the police for investigation and potential prosecution.
During investigation processes allegations are assessed to determine whether there is any merit to
further investigation and/or referral. The presumption of innocence applies, meaning that people
alleged to have committed fraud and/or corruption are innocent until proven. People suspected of
committing fraud or engaging in fraudulent conduct will be afforded natural justice.
In addition, a staff member committing fraud or engaging in corrupt conduct may be in breach of the
Public Sector Management Act 1994 – section 9 – and may be subject to separate disciplinary action.
Possible outcomes of disciplinary action range from receiving a warning about the conduct to
dismissal. The SERBIR may refer alleged breaches of the Public Sector Management Act to People and
Capability, in the first instance. The Professional Standards Unit in CMTEDD undertakes all
investigations if required, after completion of a preliminary assessment by the delegate.
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Following the discovery of fraud or corruption, the SERBIR will determine if an internal control review
is required. An internal control review will include a reassessment of the adequacy of the internal
control environment (particularly those controls directly impacting on the fraud or corruption
incident and potentially allowing it to occur) and will consider whether improvements are required.
Where improvements are required, these should be implemented as soon as practicable.
1. Advice to Line Area Managers
Line Area Managers are leaders in the Portfolio and are required to display high levels of integrity
and probity in their work. They have an obligation to apply the Public Sector Management Act, the
Code of Conduct and ACTPS Signature Values and Behaviours, and to make their staff aware of their
obligations and appropriate behaviour.
Fraud and corruption allegations or suspected cases of fraud or corruption can be extremely sensitive
and cause disruption in the workplace. Allegations of fraud and corruption are allegations until
confirmed, and the presumption of innocence applies. Discretion is to be maintained and
information on fraud and corruption investigations should be on a strict need to know basis. Who
needs to know will vary from case-to-case. All public servants are bound by the
Information Privacy
Act 2014 and therefore individuals who have made allegations of fraud and/or corruption or are the
subject of an investigation are to have their privacy protected, in accordance with the Information
Privacy Act and Information Privacy Policy.
Line managers provide support to their staff and may wish to encourage staff who have made an
allegation or are the subject of an allegation to seek assistance from the Employee Assistance
Program.
2. Records of Reports
All reports of fraud or corruption are recorded on the Fraud and Corruption Incident Register for
each entity within the Portfolio, which is maintained by Legal Services and Integrity, Authority Chief
Operating Officer (COO), Agency Secretary and Governance Manager. These registers are updated
regularly to reflect the outcome of investigations into each incident.
Legal Services and Integrity prepares a report for the SERBIR for EPSDD’s Audit Committee on
allegations of fraud and/or corruption and their assessments and investigations. A summary of each
incident is also recorded in Annual Reports.
The City Renewal Authority COO and Suburban Land Agency Secretary and Corporate Area provide
reports to their respective Audit and Risk Committees and Boards and include summaries of each
incident in their Annual Reports.
Monitoring and Review
The Director-General’s/CEOs’ Financial Instructions, and all delegations and other authorisations
must be reviewed at least annually (or as required) to ensure they remain appropriate to business
needs and are being used appropriately.
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As the Portfolio’s functions change and evolve, new systems, processes and contracting
arrangements are introduced or modified then the risk of possible fraud or corruption increases.
Every change presents the possibility of new or altered business risks and every change must
therefore be subjected to the risk assessment process. This includes an assessment of any change in
fraud and corruption risks and addressing fresh or revised measures to control or management those
risks.
The SERBIR (for EPSDD), Authority COO (for the City Renewal Authority) and Agency Secretary and
Governance Manager (for the Suburban Land Agency) will provide reports as required to their
respective audit committees on the implementation of the Plan. In addition, the respective audit
committee may initiate audits designed to measure or monitor the implementation of the Plan or
associated aspects of fraud and corruption.
The Plan must be reviewed at least once every two years, including undertaking a fraud and
corruption risk assessment.
Records Management
Documents created or used during the management of an alleged fraud or corruption incident will be
stored in an electronic document and records management system (EDRMS) in accordance with the
Territory Records Act 2002. Access to relevant files should be restricted in accordance with the
relevant permissions policy. Personal information will be collected, used and disclosed in accordance
with the
Information Privacy Act 2014 and the Information Privacy Policy.
Data and statistics, with personal information removed, may be generated to assist with reporting on
the management of allegations of fraud and corruption and their investigations.
Evaluation
Outcome Measures
Method
Responsibility
What will be measured to
How will this be done?
Who is responsible for evaluation?
determine achievement - has
the plan purpose occurred?
Staff are aware of fraud and
All staff survey
Legal Services and Integrity
corruption risks and how to
Attendance at ‘Fraud and
People and Capability
identify potential instances of Ethics’ and ‘Integrity’ training
fraud and corruption and how sessions
to report
Undertaking eLearning on
MyLearning, which includes an
assessment of the participants’
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Outcome Measures
Method
Responsibility
What will be measured to
How will this be done?
Who is responsible for evaluation?
determine achievement - has
the plan purpose occurred?
knowledge and understanding
of fraud, corruption and ethics
Executives and managers
regularly and actively
addressing fraud and
corruption prevention in
business units
Staff are aware of Fraud and
All staff survey
Legal Services and Integrity
Corruption Prevention Plan
All staff emails
SERBIR
Accessible on intranet
Attendance at ‘Fraud and
Ethics’ and Integrity training
sessions.
Undertaking eLearning on
MyLearning, which includes an
assessment of the participant’s
knowledge and understanding
of fraud, corruption and ethics.
Executives and managers
promote the Plan
Related Documents
-
ACT Integrity Policy 2010
-
Portfolio Integrity Framework (under development)
-
SERBIR Roles and Responsibilities
-
Conflict of Interest Factsheet
-
Conflict of Interest - Land Purchase from City Renewal Authority and Suburban Land Agency,
including from a Territory Joint Venture or under a Territory Sponsored Program
-
Public Interest Disclosure Act 2012
-
Public Interest Disclosure Guidelines 2019
-
Information Privacy Act 2014
-
The Portfolio’s Information Privacy Policies and Annexes
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Public Sector Management Act 1994
-
ACTPS Values and Signature Behaviours
-
ACTPS Code of Conduct
-
ACT Public Service Enterprise Agreements
-
Human Resources Delegations
-
Gifts and Hospitality Policies
-
Director-General’s/CEOs’ Financial Instructions
-
ACT Government - Acceptable Use of ICT Resources Policy
Version history
Version
Date
Amendment details
0.1
08/07/2019
Draft policy
1.0
31/10/2019
Endorsed policy
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Attachment A
Roles and Responsibilities for the Environment, Planning and Sustainable Development Directorate
Role or Position or Business Area
Responsibility
Director-General
• Foster and develop the highest standards of ethical
behaviour
• Ensure adequate fraud and corruption controls are in
place
• Ensure the wide dissemination of the Plan
• Ensure that all staff undertake regular training in fraud
and corruption awareness and ethics and the
ACTPS
Code of Conduct
• Ensure procedures are in place for the detection,
investigation and prosecution of offences should they
occur
• Appoint a Senior Executive Responsible for Business
Integrity and Risk (SERBIR)
• Appoint Disclosure Officers
Deputy Directors-General
• Foster and develop within EPSDD the highest standards
of ethical behaviour
• Assist the Director-General, audit committee, and the
SERBIR in fulfilling their responsibilities arising from the
Plan
• Promote a sound knowledge of the Plan, including that
staff attend awareness sessions
• Act as a point of contact for staff reporting fraud or
corruption matters, and referring the allegations to the
SERBIR.
Executives
• Foster and develop the highest standards of ethical
behaviour
• Assist the Director-General, Deputy Directors-General,
Audit Committee, and the SERBIR in fulfilling their
responsibilities arising from the Plan
• Promote a sound knowledge of the Plan, including that
staff attend awareness sessions
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Role or Position or Business Area
Responsibility
• Act as a point of contact for staff reporting fraud or
corruption matters, and referring the allegations to the
SERBIR
• Ensure business unit risk assessments are undertaken,
including consideration of fraud and corruption risks
• Review effectiveness of fraud and corruption
prevention measures following significant functional or
structural changes
Executive Branch Manager,
• Manage the development, maintenance and
Governance, Compliance and Legal
implementation of policies, procedures and advice on
Services
fraud and corruption prevention and control
Audit Committee
• Provide oversight of risk management processes
enabling effective identification of possible business
and financial risks, including fraud and corruption.
• Review processes and procedures through the internal
audit program
Senior Director, Legal Services and
• Assist and support the DG, CEOs and SERBIR in fulfilling
Integrity
their responsibilities
• For EPSDD, record all allegations of fraud and
corruption which occur and advise the SERBIR
• Prepare and deliver training and materials on fraud and
corruption prevention
• Provide advice to staff on fraud and corruption
prevention
Security Executive, Officer and
• Assist in the identification of potential evidence, such
Adviser
as building access logs and CCTV footage
Legal Services and Integrity
• Assist and support the DG, CEOs and SERBIR in fulfilling
their responsibilities
• Provide advice to staff on fraud and corruption
prevention
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03/10/2019
SLA Board –
25/10/2019
Fraud and Corruption Prevention Plan 2019-2021
Attachment B
Roles and Responsibilities for the City Renewal Authority
Role or Position or Business Area
Responsibility
City Renewal Authority Board
• Approve the Authority’s risk management policies and
frameworks, including the Fraud and Corruption
Prevention Plan
• Ensure the efficient and effective financial
management of the resources for which the Authority
is responsible (including ensuring expenses occurred by
the authority are properly authorised).
Chief Executive Officer
• Foster and develop the highest standards of ethical
behaviour
• Ensure adequate fraud and corruption controls are in
place
• Ensure the wide dissemination of the Plan
• Ensure that all staff undertake regular training in fraud
and corruption awareness and ethics and the
ACTPS
Code of Conduct
• Ensure procedures are in place for the detection,
investigation and prosecution of offences should they
occur
• Appoint Senior Executive Responsible for Business
Integrity and Risk (SERBIR)
• Regularly advise the City Renewal Authority Board
about the operation and financial performance of the
Authority
• Appoint Disclosure Officers.
Executives
• Foster and develop the highest standards of ethical
behaviour
• Assist the CEO, Audit and Risk Committee, and the
SERBIR in fulfilling their responsibilities arising from the
Plan
• Promote a sound knowledge of the Plan, including that
staff attend awareness sessions
Reference
Endorsed by
Issued
Review Date
Area Responsible
Page
Number
TBC
EMB –
February
Governance, Compliance
16 of 19
24/09/2019
2021
and Legal Services
CRA Board –
03/10/2019
SLA Board –
25/10/2019
Fraud and Corruption Prevention Plan 2019-2021
Role or Position or Business Area
Responsibility
• Act as a point of contact for staff reporting fraud or
corruption matters, and referring the allegations to the
SERBIR
• Ensure business unit risk assessments are undertaken,
including consideration of fraud and corruption risks
• Review effectiveness of fraud and corruption
prevention measures following significant functional or
structural changes
Chief Operating Officer
• Ensure that Risk Register reflect fraud and corruption
risks and are regularly reviewed and updated
• Report to the CEO, Audit and Risk Committee, and the
Board on the implementation of the Plan
• Monitor the Plan’s implementation and coordinate any
risk treatments
• Assist and support the CEO and SERBIR in fulfilling their
responsibilities
• Record all allegations of fraud and corruption which
occur and advise the SERBIR
Audit and Risk Committee
• Ensure a risk management framework is established,
implemented and maintained in accordance with ACT
Government requirements
• Provide oversight of risk management processes
enabling effective identification of possible business
and financial risks, including fraud and corruption
• Monitor a register of audit recommendations, including
those relating the fraud and corruption prevention
measures
• Review processes and procedures through the internal
audit program.
Reference
Endorsed by
Issued
Review Date
Area Responsible
Page
Number
TBC
EMB –
February
Governance, Compliance
17 of 19
24/09/2019
2021
and Legal Services
CRA Board –
03/10/2019
SLA Board –
25/10/2019
Fraud and Corruption Prevention Plan 2019-2021
Attachment C
Roles and Responsibilities for the Suburban Land Agency
Role or Position or Business Area
Responsibility
Suburban Land Agency Board
• Review and approve Agency’s relevant policies and
procedures, including the Fraud and Corruption
Prevention Plan
• Ensure the efficient and effective financial
management of the resources for which the Agency is
responsible
Chief Executive Officer
• Foster and develop the highest standards of ethical
behaviour
• Ensure adequate fraud and corruption controls are in
place
• Ensure the wide dissemination of the Plan
• Ensure that all staff undertake regular training in fraud
and corruption awareness and ethics and the
ACTPS
Code of Conduct
• Ensure procedures are in place for the detection,
investigation and prosecution of offences should they
occur
• Appoint Senior Executive Responsible for Business
Integrity and Risk (SERBIR)
• Appoint Disclosure Officers
Executives
• Foster and develop the highest standards of ethical
behaviour
• Assist the CEO, Agency Board, Audit and Risk
Committee, and the SERBIR in fulfilling their
responsibilities arising from the Plan
• Promote a sound knowledge of the Plan, including that
staff attend awareness sessions
• Act as a point of contact for staff reporting fraud or
corruption matters, and referring the allegations to the
SERBIR
• Ensure business unit risk assessments are undertaken,
including consideration of fraud and corruption risks
Reference
Endorsed by
Issued
Review Date
Area Responsible
Page
Number
TBC
EMB –
February
Governance, Compliance
18 of 19
24/09/2019
2021
and Legal Services
CRA Board –
03/10/2019
SLA Board –
25/10/2019
Fraud and Corruption Prevention Plan 2019-2021
Role or Position or Business Area
Responsibility
• Review effectiveness of fraud and corruption
prevention measures following significant functional or
structural changes.
Agency Secretary and Governance
• Ensure that Risk Register reflect fraud and corruption
Manager
risks and are regularly reviewed and updated
• Report to the CEO, Agency Board, Audit and Risk
Committee, and the Board on the implementation of
the Plan
• Monitor the Plan’s implementation and coordinate any
risk treatments
• Assist and support the CEO and SERBIR in fulfilling their
responsibilities
• Record all allegations of fraud and corruption which
occur and advise the SERBIR
Board Audit and Risk Committee
• Provide oversight of risk management processes
enabling effective identification of possible business
and financial risks, including fraud and corruption
• Conduct annual review of the Fraud and Corruption
Control Plan for the Agency
• Review processes and procedures through the internal
audit program
Reference
Endorsed by
Issued
Review Date
Area Responsible
Page
Number
TBC
EMB –
February
Governance, Compliance
19 of 19
24/09/2019
2021
and Legal Services
CRA Board –
03/10/2019
SLA Board –
25/10/2019
