Eleanor Dickens
Partner •
Brisbane
Queensland's Crime and Corruption Commission charts its course for 2021-2023 with the release of its new Corruption Audit Plan
Crime and Corruption Commission audits planned for 2021-2023 will focus on misuse of public resources, recruitment, and complaint management practices across a variety of Queensland public agencies.
Queensland's corruption regulator, the Crime and Corruption Commission (CCC), uses audits to examine how public sector agencies have responded to particular corruption risks, assess how robust complaint mechanism are and to examine specific concerns it has in relation to particular corruption risks.
The CCC has now released its Corruption Audit Plan for 2021-2023 which has identified the CCC's corruption risk areas of focus as being the misuse of public resources, recruitment, and complaint management practices across a variety of Queensland public agencies.
As part of its role as Queensland's anti-corruption regulator, the CCC audits public sector agencies to examine:
- how they have responded to past corruption complaints;
- how robust their complaints management and prevention frameworks are; and
- how best to control the risks of corruption.
The Audit Plan explains the CCC’s audit focus, its concerns over particular corruption risk areas, and the agencies to be audited. It outlines six areas of focus for the CCC over the next two years, which are broken up into six roughly sequential audits.
Given the purpose of the CCC's audit program, Queensland public sector agencies subject to the CCC's jurisdiction should know and understand the CCC's audit focus as set out in its released Audit Plans.
A range of public sector agencies will be subject to Audit 1, 3 and 4, including State government Departments, Local Governments, Government Owned Corporations, Statutory Authorities and Universities, highlighting the broad array of agencies that are subject to the jurisdiction of the CCC across Queensland public sector.
Audits 2, 5 and 6 are not limited to any specifically named public agencies. Instead, they may involve the auditing of any Queensland public sector agency.
We have summarised the focus of each planned audit below.
Audit 1: Misuse of Public Resources (July-December 2021)
The CCC is examining a sample of allegations involving misuse of public resources and how public agencies are reducing incidences of corruption. The audit will also use data analytics to detect fuel consumption fraud in local councils, where possible.
Audits 2 and 6: Dynamic Prevention Projects (September 2021-March 2022, January-June 2023)
The CCC conducts a "dynamic corruption prevention activity" each year. The scope of the work has not yet been published, but is likely to be associated with one or more of the CCC's targeted investigations.
Audits 3 and 4: Recruitment (January-June 2022, July-December 2022)
The CCC will build on its 2017 recruitment audit to focus on fundamental weaknesses that can enable and promote recruitment corruption within public agencies. In Part A of the recruitment audit, the CCC may examine public agencies' responses to allegations of corruption, their implemented policies and processes, and how they have raised awareness and initiated other prevention measures about the recruitment and selection of employees.
The CCC is also concerned by the corruption risks posed by inadequate employment screening (such as failing to verify applicants’ claims about qualifications, work history, discipline and criminal histories, and conflicts of interest). In Part B of the recruitment audit, the CCC will examine the adequacy of an agency's employment screening policies and processes, examine monitoring activities, and design a best practice guide to help public agencies.
Audit 5: Complaint Management Practices (September 2022-March 2023)
The CCC will examine the efficacy of agencies’ investigations, disciplinary decision-making, and the extent to which agencies minimise the risk of reprisals against complainants during these processes. It may examine how well public agencies have dealt with allegations of corruption, and consider whether policies adequately protect disclosers and the appropriateness of disciplinary outcomes.
Key takeaways for Queensland public agencies
- CCC audits planned for 2021-2023 will focus on misuse of public resources, recruitment, and complaint management practices across a variety of Queensland public agencies.
- Some audits will focus on a list of named public agencies, while others will target any number of agencies across the public sector.
- Even if a public agency is not named in the plan, it may be the subject of a CCC audit. Agencies should be particularly prepared with up-to-date complaint management practices.
- The CCC is likely to publish reports summarising the outcomes of these audits. Public agencies should carefully consider the outcomes of all published audits, as the public reports may inform the CCC's future anti-corruption efforts.
- Given that the planned audit process highlights concerns that the CCC may have in respect of particular types of corruption risks, while agencies should continue to be vigilant about monitoring all types of corruption, the CCC's audit focus can be used by agencies to further focusing these monitoring activities.
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Sam Weston
Senior Associate •
Brisbane
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