Sector profile

Strong conflict of interest (COI) frameworks

• Clear COI policy framework that identifies perceived, potential and actual conflicts of interest.
• Clear COI policy plan that details how COIs ought to be managed by staff, managers, and directors.
• Ensure staff are informed and familiar with how to declare conflicts of interest.
• Ensure the process to make a declaration is easy, fast, and accessible.
• Take proactive measures to ensure staff and contractors are aware of and understand relevant policies. 
• Require all employees and contractors to provide written acknowledgement that they understand their organisation’s conflict of interest policy.
• Clear gifts, benefits and hospitality policies and procedures that contain case studies and examples.
• Discourage any gifts, benefits, and hospitality from current and prospective suppliers.
• Strengthen recruitment and promotion processes and policies to more effectively identify and manage conflicts of interest.
• Increase awareness and compliance around declaring conflicts of interest in procurement.

Proactive information security culture and management

• Training and awareness of the corruption risks associated with information access and disclosure.
• Regular and proactive audits of employees’ access of information systems.
• System users must record a reason for accessing (or altering) sensitive information.
• Ensure maintenance of appropriate information security controls, and that staff do not share log-on and password details.

Rigorous frameworks for corruption prevention and risk management

• Establish integrity policies and corruption risk management plans, and review these regularly (for large organisations).
• Provide initial and regular training on fraud and corruption prevention (for large organisations).
• Provide guidance around who to report concerns to as well as how employees or clients can report suspected corrupt conduct to IBAC (for large organisations).
• Have a clear corruption risk management plan and raise awareness of corruption risks within the workforce (for small organisations). 
• Provide guidance around who to report concerns to as well as how employees or clients can report suspected corrupt conduct to IBAC (for small organisations).

Procurement – bidding and supplier selection

• Ensure awareness of and compliance with procurement policies and procedures.
• Ensure employees involved in procurement process make conflicts of interest declarations and that any conflicts are managed appropriately. Some agencies have made conflict of declaration forms mandatory for each employee involved in procurement decisions and included in the form an option for employees to state that they have no actual, potential or perceived conflicts.

Procurement – contract management

• Use electronic procurement systems that prevent the processing of invoices until quotes are entered into the system.
• Monitor variations in contracts and ensure variations are approved by the appropriate financial delegate.
• Ensure purchase orders are raised before receipt of an invoice, unless exceptional circumstances apply.
• Ensure invoices contain sufficient information before being paid, and that goods and services must be received before being paid.
• Undertake regular and random audits to ensure the veracity of invoices and identify unusual transactions.
• Segregate duties at various stages of the procurement process and ensure compliance.

Proactive information security culture and management

• Increased training and awareness of information security risks.
• Regular and proactive audits of employees’ access of information systems.
• System users must record a reason for accessing (or altering) sensitive information.
• Ensure maintenance of appropriate information security controls, and that staff do not share log-on and password details.

Rigorous frameworks for corruption prevention and risk management

• Establish integrity policies and corruption risk management plans and update regularly. These should include conflict of interest declaration and management policies, as well as how to handle any gifts, benefits and hospitality provided by service providers. 
• Provide initial and regular training on fraud and corruption prevention.
• Provide clear guidance on how to report suspected corrupt conduct, either internally or to IBAC directly.
• Close oversight and engagement with funded agencies to ensure compliance with policies and procedures.
• Audits and oversight of grants and other funding to ensure they are used appropriately.