Fraud and Corruption Control
Framework
TRIM 13/384765
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Contents
Director-General’s Foreword .......................................................................................................... 4
Introduction ......................................................................................................................................... 5
Purpose ............................................................................................................................. 5
Goals and Objectives ........................................................................................................ 5
Our Policy ............................................................................................................................................ 6
What is Fraud and Corruption? .......................................................................................... 6
Our Policy Statement ......................................................................................................... 7
Our Control Plan................................................................................................................................. 8
Ethical Leadership and Culture .......................................................................................... 9
Legislation and Governance ............................................................................................ 10
Legislation ...................................................................................................................................... 10
Governance Structures ................................................................................................................ 10
Roles and responsibilities ............................................................................................................ 11
Key Control Strategies ..................................................................................................... 12
Prevention Strategies ...................................................................................................... 13
Integrated Policy............................................................................................................................ 13
Code of Conduct ........................................................................................................................... 13
Staff Education and Awareness .................................................................................................. 13
Client and Community Awareness ............................................................................................. 14
Risk Assessment ........................................................................................................................... 14
Internal Controls ............................................................................................................................ 15
Detection Strategies ........................................................................................................ 16
Internal Reporting.......................................................................................................................... 16
Public Interest Disclosures .......................................................................................................... 16
Response Strategies ....................................................................................................... 17
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External Reporting ........................................................................................................................ 17
Investigations ................................................................................................................................. 18
Monitoring, review and continual improvement of the Fraud and Corruption Control
Framework ......................................................................................................................................... 19
Appendices ........................................................................................................................................ 20
Appendix 1: Legislation and other Instruments - Fraud and Corruption Control .............. 20
Appendix 2: Fraud and Corruption Control Roles and Responsibilities ........................... 21
Appendix 3: Fraud and Corruption Control Risk Assessment Plan ................................. 24
Appendix 4: Definitions................................................................................................................ 25
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Director-General’s Foreword
The Department of Education, Training and Employment (DETE) Fraud and Corruption Control
Framework 2013-2016 sets out the standard of accountability and transparency expected of the
department. The aim of this framework is to control opportunities for fraudulent and/or corrupt
activities and promote the department’s zero tolerance to fraud and corruption.
Thorough and effective fraud and corruption control requires commitment at all levels within the
department. Effective governance arrangements, ethical leadership and, decision making,
accountability and performance improvement underpin our fraud and corruption control methods. The
ever changing environment in which the public sector operates increases the opportunity for
fraudulent and corrupt activities. The growing convergence of the public and private sectors, and the
increase in cooperative and or strategic partnerships, have emphasised the importance of
accountability and sound governance structures, including in relation to fraud and corruption 1.
As public sector employees, we have the responsibility to undertake our roles in a transparent and
accountable way. All staff must use this framework to assist with the prevention, detection and
ongoing responsiveness to fraud and corruption. This will ensure our stakeholders have ongoing
confidence in the department’s commitment to deliver quality services to the community free from
fraud and corruption.
Dr Jim Watterston
Director-General
1
Fraud Control in Australian Agencies – Best Practice Guide 2004
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Introduction
Purpose
As a government agency the community expects the department to ensure its workforce acts legally,
ethically and at all times in the public interest. Risk of fraud and corruption is inherently linked to the
department’s activities and can undermine the achievement of the department’s objectives, damage
the credibility and public confidence in the department, affect employee morale and compromise the
delivery of its services to students, parents/carers, industry and community.
The Fraud and Corruption Control Framework 2013-2016 (FCC Framework) outlines the department’s
policy and plan for controlling fraud and corruption risks. Implementation of the FCC Framework
seeks to control the opportunities for fraud and corruption, whether committed by internal or external
parties, to ensure the protection of public monies, property and information, the rights of organisations
and individuals, and maintain the effectiveness of all departmental operations.
It is an integral part of the department’s Enterprise Risk Management Framework and aims to drive
business integrity through strong leadership, sound corporate governance, accountability, internal
control and transparency. This proactive approach enables the department to manage fraud and
corruption risk at an acceptable level in an environment that is becoming increasingly complex.
All employees, contractors and third party providers need to be aware of and committed to their
shared responsibilities to foster, develop and maintain a highly ethical organisational culture.
Goals and Objectives
The FCC Framework specifically aims to clearly articulate through the:


policy:
-
definition of the term “fraud and corruption”
-
the department’s commitment and attitude towards fraud and corruption
-
the department’s approach to controlling fraud and corruption
control plan:
-
how the fraud control structure is embedded within the department’s organisational
structure
-
the roles and responsibilities for fraud and corruption control
-
strategies to prevent, detect and respond to fraud and corruption
-
a summary of the fraud risks (internal and external) associated with the department’s
functions, the controls in place to minimise the opportunity for fraud and corruption
and their implementation details
-
protocols on how employees, contractors, third parties or members of the public can
report suspected fraud
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Our Policy
What is Fraud and Corruption?
Fraud and corruption against the department is defined as:

Fraud:
- any deliberate deceitful conduct or omission designed to gain an advantage
to which a person or entity is not entitled
- the intentional use of false representations or deception to avoid an
obligation, gain unjust advantage or in the context of public administration,
commonly known as ‘rorting the system’.

Corruption:
- dishonest behaviour that may involve the misuse of position or authority, or
other acts for personal gain or advantage, or for another person or entity,
which may cause loss to the department, its clients or the general
community
- may also include other elements such as breaches of trust and
confidentiality.
Fraudulent and corrupt conduct by public officials may fall within the category of ‘official misconduct’
under Queensland’s Crime and Misconduct Act 2001 and may also be considered a criminal offence
under the Criminal Code Act 1899.
Some examples of common activities of fraud and corruption in the public sector include:
Internal
External
Collusion
 corporate card misuse, such
as payment for personal
expenses
 fictitious people on the payroll
system or delayed
terminations
 abuse of position and power,
including accepting or offering
bribes or gifts, nepotism in
staff appointments
 submitting false travel claims
 consistently recording
incorrect hours of work on
timesheet
 unauthorised use of
government vehicles
 theft or unauthorised use of
public funds or physical
resources, such as office
supplies, stationery
 customer deliberately claiming
benefit they are not eligible for
 external providers making
claims for services that were
not provided
 individuals/businesses
providing false or misleading
information or failing to
provide it when obliged to do
so
 inappropriate influence over
grants and subsidies
applications
 manipulation of a procurement
process
• inappropriate involvement
with suppliers, including
‘kickbacks’ such as
entertainment and hospitality
 unlawful or unauthorised
release of information
 knowingly making or using
forged or falsified
documentation
 conflicts of interest
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Our Policy Statement
The department is committed to excellence in fulfilling public expectations of high standard of service
performance and in meeting its statutory obligations. This includes the establishment of a fraud and
corruption prevention culture to enhance the department’s integrity and performance, and strengthen
public confidence.
The department takes a zero tolerance approach towards any fraudulent or corrupt actions by
departmental staff, contractors, suppliers, third party service providers, funding recipients and clients.
Instances of official misconduct are referred to the Crime and Misconduct Commission (CMC) and in
some instances to the Queensland Police Service for investigation and possible prosecution. The
department is committed to recovering losses incurred from fraud and corruption activities, after
considering all relevant issues.
The department applies a risk management approach, supported by organisational values and culture,
a hierarchy of governance and suite of effective controls to prevent, detect and respond to potential
fraudulent or corrupt conduct.
The department will appropriately deal with all reported allegations of fraud and corruption or refer the
matter to an applicable external agency. There is an obligation placed on all staff to report suspected
fraudulent and/or corrupt activities to their supervisor or manager, Internal Audit Branch (IAB) or the
Ethical Standards Unit (ESU) where the allegations will be assessed and suitably dealt with.
The department is committed to providing all staff and relevant stakeholder’s with appropriate
education and training in public sector ethics and fraud awareness to ensure understanding of their
respective responsibilities and obligations.
The department’s policy has been developed in accordance with the CMCs Fraud and Corruption
Control – Guidelines for Best Practice 2005 and the Australian Standard AS8001-2008 Fraud and
Corruption Control.
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Our Control Plan
The department’s plan to managing fraud and corruption control is based on a set of essential
conditions2 to establish a sound fraud control environment (Figure 1). The essential conditions
consist of an integrated response of:

Ethical leadership and culture – to develop and maintain strong ethical values and high
standards of ethical behaviour

Legislation and governance – to ensure legislation and policies are operationalised in an
accountable and transparent manner through robust governance structures

Key control strategies – set of interrelated actions to effectively prevent, detect and respond
to fraud and corruption, which are subject to a cyclical process of review and improvement.
Figure 1: Fraud and Corruption Control Framework
2
ANAO Fraud Control in Australian Government Entities – Better Practice Guide March 2011
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Ethical Leadership and Culture
Ethical leadership and the implementation and ongoing maintenance of a sound ethical culture are
critical to underpinning fraud and corruption control within the department.
Senior management must lead by example and behave in a manner consistent with the Code of
Conduct for the Queensland Public Service and the department’s Standard of Practice. Specific lines
of accountability, roles and responsibilities for senior management are further outlined in the
Legislation and Governance section.
The Code of Conduct for the Queensland Public Service and the department’s Standard of Practice
provide a set of ethics principles, values and standards of conduct for all employees. This ethical
framework guides behaviour in the workplace and is an important corruption resistance tool to
promote ethical behaviour. They work in tandem with the best practice principles outlined in the
department’s Enterprise Risk Management Framework to guide how we effectively and efficiently
manage fraud and corruption risks at all levels. Implementation of the Code of Conduct is outlined in
the Application of Key Control Strategies section.
Figure 2: Principles that underpin the Fraud and Corruption Control Framework
Enterprise Risk Management
• Creating & protecting value
• Integral part of all organisational
processes
Public Sector Ethics
• Integrity and impartiality
• Promoting the public good
• Commitment to the system of
government
• Accountability and transparency
Fraud &
Corruption
Control
• Part of decision-making
• Explicitly addressing uncertainty
• Systematic, structured and timely
• Based on the best available information
• Tailored
• Human and cultural factors
• Transparent inclusive
• Dynamic, iterative and responsive to
change
• Continual improvement
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Legislation and Governance
Legislation
The department’s framework is underpinned by legislation, Australian standards and best practice
guidelines. In particular:

Financial Accountability Act 2009 - commits the department to protecting its revenue,
expenditure and property from fraudulent activity

Public Sector Ethics Act 1994 – sets out the ethics principles and values for public service
agencies and public officials, and provides standards of conduct consistent with the ethics
principles and values

Crime and Misconduct Commission Fraud and Corruption Control – Guidelines for Best
Practice 2005 – provide the model for development and implementation of the fraud and
corruption control policy and plan.
A full list of the applicable legislation and other instruments is outlined in Appendix 1.
Governance Structures
A rigorous governance structure within the department ensures legislative requirements are effected
in an accountable, effective and transparent way.
As illustrated in figure 3, consistent with the Enterprise Risk Management Framework, the
department’s governance structures support fraud and corruption control at the strategic, corporate
and operational level.
Figure 3: Governance Structures
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Roles and responsibilities
The table below provides a summary of the roles and responsibilities for fraud and corruption control.
A more comprehensive list of responsibilities is outlined in Appendix 2.
Role
Responsibility
Director-General

Deputy DirectorGeneral, Corporate
Services

Deputy DirectorsGeneral, Assistant
Directors-General,
Regional Directors,
Executive Directors,
Directors and
Managers
Director, Ethical
Standards Unit








All employees



Fraud and Corruption
Control Committee



Audit and Risk
Management
Committee
Internal Audit Branch


overall accountability for the prevention and detection of fraud and
corruption within the department and has a legislated responsibility to
exercise authority on behalf of the department through the Executive
Management Group (EMG) to the senior leadership team
has delegated authority as the Fraud and Corruption Control Coordinator
and acts as ‘champion’ to drive the fraud and corruption control regime
within the department
is the Chair to the Fraud and Corruption Control Committee
be ethical leaders, promote and contribute to an accountable,
transparent and ethical culture
manage risks within their area of responsibility and contribute to
improvement in control effectiveness
ensure staff have a high level of fraud and corruption awareness and
know how to report suspected fraudulent or corrupt behaviour
reports suspected official misconduct, criminal and other matters as
appropriate to the relevant authorities
develop and implement the fraud and corruption control framework
manage investigations into allegations of suspected official misconduct
takes a proactive approach to public sector ethics by promoting an
ethical culture, practice and decision making throughout the department
understand their role in contributing to fraud and corruption prevention
and the actions to be taken to prevent, detect and report any such
activity
must attend education, training and awareness programs on a regular
basis during their employment to assist them in performing their role
within the department
report alleged wrongdoing in accordance with the s.1.1(d) of the Code of
Conduct for the Queensland Public Service and s.4.1 of the department’s
Standard of Practice
advises the Audit and Risk Management Committee outlining certain
risks to the department in relation to fraud and corruption matters and
puts forward pertinent recommendations/actions regarding these
undertakes review and evaluation on the effectiveness of how the
department monitors compliance with relevant legislation and best
practice requirements for fraud and corruption control
accountable for the implementation and ongoing monitoring of the fraud
and corruption program
advises the Director-General outlining audit matters and certain risks to
the department, including potential fraud and corruption matters and puts
forward pertinent recommendations regarding these
undertakes independent and objective audit activities that adds value to
and improves operational capability and compliance within the
department
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Key Control Strategies
The department’s 10 key control strategies3 can be grouped into three key categories:

Prevent - as the first line of defence, to reduce the risk of fraud and corruption occurring

Detect - discover and investigate fraud and corruption when it occurs

Respond - take corrective action and remedy the harm caused by fraudulent and corrupt
behaviour.
Key Control
Strategy
Categories
Prevent
Detect
Purpose
Respond
Integrated
agency policy

 demonstrate the department’s
resolve to combat fraud and
corruption
Code of
Conduct

 sets out expectations and
standards of ethical behaviour
within the department
Staff
education and
awareness

Client and
community
awareness

Risk
assessment

 ensure a well-informed workforce
with a greater capacity to
recognise and respond to the
risks of fraud and corruption

 provide a comprehensive
understanding of the
department’s internal and
external vulnerabilities

 mechanisms to eliminate or
minimise risks
Internal
reporting


 mechanism for employees to
report potential fraudulent or
corrupt activities and other
alleged wrongdoing
Public interest
disclosures

Investigations
External
reporting
Communicate
Intent
 maintain public trust and forestall
potentially unacceptable practices
from external parties

Internal
controls



 responsibility for receiving and
managing all allegations of
wrongdoing received under
Public Interest Disclosure Act
2010

 process to ensure allegations of
fraud and corruption are actioned
appropriately and investigated
competently

 mechanism for the DirectorGeneral to report any suspected
fraudulent or corrupt activity to
the appropriate external agency
Limit
Opportunities
Reinforce Zero
Tolerance
The 10 elements are outlined in the Crime and Misconduct Commission’s Fraud and Corruption Control
Guidelines for best practice 2005
3
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Application of the Key Control Strategies
Prevention Strategies
Integrated Policy
The department is committed to improving governance arrangements through strong leadership,
responsible and ethical decision making, transparency and accountability, and performance
improvements. The framework should be read in conjunction with:

Legislative Framework

Corporate Governance Framework

Enterprise Risk Management Framework

Developing Performance Framework
Code of Conduct
There is an expectation of all departmental employees to make decisions ethically and with integrity.
The Code of Conduct for the Queensland Public Service provides a clear set of ethics principles,
values and standards of conduct for all employees that supports and guides ethical behaviour when
delivering government services to the people of Queensland.
The department has developed an agency specific Standard of Practice, supplementary to the Code
of Conduct, which provides a clear statement of what is expected of all staff in supporting ethical
standards of conduct. The Standards of Practice also provides advice and guidance for employees in
making ethical decisions, especially in circumstances where the ‘correct’ or ‘best’ course of action
may not be clear.
To assist in the resolution of alleged inappropriate workplace behaviour, employees should seek
advice from their supervisor or manager when appropriate, or contact the ESU.
Staff Education and Awareness
A well informed workforce will increase the department’s capacity to detect, prevent, and respond to
the risks of fraud and corruption. It is the responsibility of all managers to support the implementation
of the plan and the responsibility of all staff to ensure they have fulfilled the necessary training
requirements under the plan.
Mandatory public sector ethics education and training is required to be completed by all new
employees through the DETE induction program. Ongoing ethics related education and training is
required by all employees at regular intervals during their employment with the department. The
public sector ethics education and training module includes:

ethical decision making training and awareness, including Code of Conduct

internal controls training

fraud and corruption (public interest disclosure) training and awareness.
The public sector ethics education and training is available to employees through a variety of delivery
modes:

face-to-face training

on-line ethical decision making training available on the Learning Place
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
train-the-trainer package

TAFE institutes, on-line, through the institutes learning management system (LMS)

ethics related resources published on the intranet site, One Portal, developed by ESU and
available to all employees

DETE induction website (mandatory induction).
Client and Community Awareness
It is important the department sends a clear message about its policy for fraud and corruption control
to the wider community and external providers, who have direct dealings with the department, such as
contractors, suppliers, third party providers, funding recipients and its clients.
The department emphasises its integrity and commitment to high standards of probity in all its
dealings, including zero tolerance towards fraud and corruption by promoting this through:

making the fraud and corruption control framework publically available on the DETE internet

gaining P&C commitment and ensuring a documented process for reporting potential
fraudulent and/or corrupt activities

provisions incorporated into the department’s standard contract arrangements

the provision of a fraud reporting hotline - 1800 727 031

publication of pertinent complaint data through the DETE Open Data Strategy.
The FCC Framework and other relevant policies and procedures are published on the department’s
internet site to enable all community members’ access.
Risk Assessment
Fraud and corruption risk assessment is an integral part of the department’s overall risk management
framework and provides the department with an understanding of its fraud and corruption
vulnerabilities and possible strategies to eliminate or minimise those risks. Fraud and corruption risk
assessments are carried out in accordance with the department’s Enterprise Risk Management
Framework. The department’s enterprise risk management procedure and process, risk assessment
criteria, facts sheets and tools to support the completion of fraud and corruption risk assessments are
located in the department’s Policy and Procedure Register.
Fraud and corruption risk assessments are to be conducted by each division on their specific
functions/processes every two years. The department has identified a number of functions/processes
considered to be high areas of vulnerability to fraudulent and corrupt activity. As a minimum, fraud
and corruption risks are to be identified and assessed for the following areas:

accounts receivable

recruitment

corporate card

payroll

purchasing

timesheets

asset management

funds and grants management

accounts payable

information management

procurement

regulation

contract management
Potential fraud and corruption risks are identified as risks to the department’s functions/processes and
as such are classified under the Enterprise Risk Management Framework as operational risks. To
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ensure visibility of the fraud and corruption risks across the department, they are to be recorded as
operational risks in the Enterprise Risk Assessor (ERA), the department’s online risk register.
As required under the enterprise risk management procedure:

risks are required to be assessed at the inherent (risks level without controls), controlled (level
of risk with controls in place) and if required treated level (level of risks with controls and
treatments in place)

unacceptable controlled risks (i.e. high or extreme) are required to be treated

unacceptable treated risks (i.e. high or extreme) must be escalated to a senior level of
management for oversight

review of the risks is to be commensurate with the level of risk exposure or when there is
significant change to operations, but at least biannually as part of the department’s structured
operational planning and review process.
Judgement on the effectiveness of the controls is critical to assessing the controlled level of risk. Key
risks and control activities identified through the fraud and corruption risk assessment are listed in
Appendix 3: Fraud and Corruption Control Risk Assessment Plan.
Internal Controls
An internal control system consists of structure, policies, procedures, processes, tasks, information
systems and other tangible and intangible activities that combine to record and manage the risks of
the department. The department’s internal control framework places a strong emphasis on
accountability, integrity, best practice management of resources, operational performance,
compliance and ‘corporate health’.
Some of the key controls the department has in place to meet the requirements of the Financial and
Performance Management Standard 2009 includes:
Role
Internal Control Examples
Lines of accountability
Governance committees, organisational structure, delegations of
authority, Strategic Plan and annual operational plans, Annual Report,
Service Delivery Statement
Resource management
Budget management, Establishment Management Framework
Suitably qualified staff
Position descriptions, merit based recruitment and selection processes,
pre-employment screening, training, Developing Performance
Framework
Information, communication
and technology systems
SAP, One School (transactions, records, operating programs and
systems producing ICT information), TRIM (Data collection and
exchange), OnePortal intranet and DETE internet (internal and external
communications), MyHR (human resources recording and reporting),
information systems standards, assets registers (physical resources)
and reporting mechanisms, including adequate audit trails
Policy and procedures
Financial Management Practice Manual, School Accounting Manual
and other procedures published in the department’s Policy and
Procedure Register
Investigations into cases of fraud and corruption show strong links between the incidence of fraud and
corruption and poor internal control systems. As a result the assessment of internal control
effectiveness is a crucial step in the fraud and corruption risk assessment process.
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The Internal Audit Branch supports the department’s efforts to establish and maintain systems
integrity through an established audit program. The audit program includes periodic risk based
assessments of the department’s business units using best practice methodologies to assess levels
of compliance with existing internal controls.
Detection Strategies
Internal Reporting
Reporting suspected wrongdoing is vital to the integrity of the department and the Queensland public
sector. Research studies and surveys consistently show that staff members form the single most
compelling source in detecting fraud and corruption 4. All departmental staff have an obligation to
report suspicious actions or potential wrongdoing in accordance with the Code of Conduct. Students,
clients, parents, caregivers, concerned members of the public or anonymous persons who do not
wish to be identified can also make a complaint about fraud and corruption.
The department’s complaint management system includes policies and procedures and an
information system to capture all stages of reported complaints from initial receipt, assessment,
through to investigation, follow up and resolution, and notification of the outcome to the discloser.
Data can be further used to provide the department with information for other reporting purposes, and
facilitate continuous improvement to its fraud and corruption resistance through analysis of trends,
areas of risk and control weakness.
Avenues to report suspected wrongdoing, including fraud and corruption are outlined in the following
departmental procedures, located in the department’s Policy and Procedure Register:

Managing Employee Complaints

Complaints Management – state schools

Information privacy complaints

Making and Managing a Public Interest Disclosures under the Public Interest Disclosure Act
2010
Employees should report suspected wrongdoing to their immediate supervisor or manager, in the first
instance. Should staff be reluctant to report any concerns immediately or feel appropriate action has
not been taken by the supervisor or manager who received the complaint, alternative reporting
options include:

a more senior manager

Director, Ethical Standards Unit

Executive Director, Internal Audit Branch

Fraud and Corruption Hotline 1800 727 031

directly to the CMC
Public Interest Disclosures
A public interest disclosure (PID), in general terms, is a disclosure of information of public interest,
involving wrongdoing within the public sector, made to a proper authority. Under the Public Interest
Disclosure Act 2010, a proper authority is defined as a public sector entity or a member of the
Legislative Assembly. A PID can be made by any person whether a public officer (employee) or a
member of the public. The department is dedicated to promoting the public interest by facilitating
4
CMC Fraud and Corruption Control Guidelines for Best Practice, 2005
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disclosures of wrongdoing and ensuring PIDs are correctly assessed and when appropriate,
thoroughly investigated and dealt with in accordance with Public Interest Disclosure Act 2010.
The department’s procedure Making and Managing a Public Interest Disclosure under the Public
Interest Disclosure Act 2010 describes:
 the types of information that establishes a PID;
 the roles and responsibilities for making and managing a PID;
 process guidelines to assist a person wanting to make a PID; and
 how a PID is managed once reported.
As with all internal reporting of suspected wrongdoing, the department:
 exercises due process and natural justice in its management of PID’s;
 makes all attempts to preserve confidentiality;
 provides appropriate protection to the person who made the PID;
 maintains all necessary records securely; and
 reports in an appropriate manner.
Response Strategies
External Reporting
The Queensland government’s public sector integrity framework includes three independent statutory
bodies for integrity building, the Crime and Misconduct Commission, the Queensland Ombudsman’s
Office, and the Queensland Audit Office, supplemented by the law enforcement role of the
Queensland Police Service.
These government bodies provide a range of external channels to report suspected wrongdoing,
including fraud and corruption.
In some instances external reporting is a legislative obligation placed on government agencies. The
role of each of the four government bodies and the department’s legislative reporting obligations to
them is as follows:
Government Body / Role
Departmental Reporting Obligations
Crime and Misconduct Commission (CMC)
 Director-General, or delegate notifies the CMC if the
department suspects a report of wrongdoing
involves official misconduct under the Crime and
Misconduct Act 2001
 receives complaints about possible
misconduct and determines the most
appropriate action to deal with them
Queensland Audit Office (QAO)
 provides independent audit services to
the Queensland Parliament and all state
public sector entities and local
governments
 Director-General, or delegate reports any suspected
material loss (money lost >$500; and property
valued >$5000) which may have occurred as a
result of official misconduct or the commission of a
criminal offence in accordance with the Criminal
Code Act 1899, Crime and Misconduct Act 2001,
Financial and Performance Management Standard
2009, or other Act
Queensland Police Service (QPS)
 Director-General, or delegate reports:
 suspected fraud and or corruption arising out
of criminal conduct under the Criminal Code
Act 1899, or other Act
 uphold and enforce the law in
Queensland
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
Queensland Ombudsman

oversight agency for all public
interest disclosures made to the
Queensland government
any suspected material loss (money lost
>$500, or property valued >$5000) which may
have occurred as a result of official
misconduct or the commission of a criminal
offence in accordance with the Criminal Code
Act 1899, Crime and Misconduct Act 2001,
Financial and Performance Management
Standard 2009, or other Act
 Director-General is to:
 report on all PIDs made to the department
 ensure organisational commitment in
managing PID’s
 develop, implement and maintain a
management program under the Public
Interest Disclosure Act 2010 and Public
Interest Disclosure Standard No.1
The department also maintains reporting protocols with the Public Service Commission through the
Director, ESU in relation to the integrity and accountability of the department.
Investigations
Investigations undertaken within the department may involve matters of suspected fraud, corruption,
misappropriation, maladministration, theft and other matters where the conduct of an employee, if
substantiated, could amount to official misconduct and may result in the initiation of disciplinary action,
including dismissal.
The department has an obligation to facilitate effective and efficient initial assessment and referral of
all reports of alleged wrongdoing, which could amount to official misconduct to the CMC. After the
CMC’s initial assessment, they may choose to investigate, or refer the matter back to the department
for investigation.
Investigations into allegations of official misconduct, including fraud and corruption, are conducted in
accordance with the CMC’s Facing the Facts – A CMC guide for dealing with suspected official
misconduct in Queensland public sector agencies. The adoption and application of this guide
ensures processes are carried out in accordance with the CMC’s requirement for conducting
administrative investigations objectively, thoroughly and without prejudice.
When an investigation into alleged official misconduct, including fraud or corruption, is deemed
necessary:

all employees are obliged to respect the rights of all involved and maintain confidentiality
pending a full investigation into an alleged wrongdoing

managers and supervisors must ensure due process and encourage confidentiality

any person disclosing alleged wrongdoing shall be advised of the outcome of investigation as
soon as practicable

the outcome of departmental investigations may be subject of review by the CMC.
To strengthen prevention and awareness measures, designed to reduce or eliminate fraudulent and
corrupt behaviour throughout the department, outcomes of investigations where complaints of alleged
fraud and/ or corruption have been substantiated may be published, when appropriate to do so and
when confidential records can be maintained.
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Monitoring, review and continual improvement of
the Fraud and Corruption Control Framework
Effective monitoring and reviewing of the FCC Framework is an important part of the department’s
accountability to its stakeholders and provides a mechanism for ongoing building of the department’s
resilience to fraud and corruption.
Some of the processes that support the review and continuous improvement of the FCC Framework
include:


review of the FCC Framework every two years (or in the event of a significant change
occurring within the department) including:
-
control strategies, to ensure appropriate balance between prevention and detection
strategies
-
control appropriateness and effectiveness of design and operation
-
update of the fraud and corruption risk assessment to ensure significant existing and
emerging fraud and corruption risks are captured and managed
review of individual fraud and corruption cases to identify cause, areas of control weakness,
where possible measure the loss/cost of fraud and identify lessons learned.
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Appendices
Appendix 1: Legislation and other Instruments - Fraud and
Corruption Control
Instrument Type
Legislation and other instruments
Primary Legislation
Criminal Code Act 1899
Crime and Misconduct Act 2001
Financial Accountability Act 2009
Information Privacy Act 2009
Integrity Act 2009
Public Interest Disclosure Act 2010
Public Sector Ethics Act 1994
Public Service Act 2008
Right to Information Act 2009
Whole of Government
Policy
Queensland Treasury Financial Accountability Handbook 2012
Standards, guidance
and better practice
Australian National Audit Office Fraud Control in Australian Government
Entities – Better Practice Guide 2011
Australian Standard 8001-2008 Fraud and Corruption Control
Code of Conduct for the Queensland Public Service 2011
Crime and Misconduct Commission Facing the Facts 2007
Crime and Misconduct Commission Fraud and Corruption control: guidelines
for best practice 2005
Department’s Standard of Practice
Independent Commission Against Corruption Fighting Fraud: Guidelines for
state and local government – Booklet 2002
Queensland Treasury a guide to Risk Management 2011
Queensland Treasury Financial Management Tool 2012
Queensland Treasury Financial and Performance Management Standard
2009
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Appendix 2: Fraud and Corruption Control Roles and
Responsibilities
Role
Director-General
Responsibility
 overall accountability for prevention and detection of fraud and corruption
within DETE
 legislated responsibility to exercise authority, on behalf of the department
 manage the department’s operations ensuring service delivery is effective
and economical, and in the process avoids waste and extravagance
 manage public resources of the department efficiently, responsibly and in a
fully accountable manner
 define goals and objectives in accordance with its mandate and governance
framework
 implement policies and priorities responsibly
 ensure impartiality and integrity in the performance of the department’s
functions
 ensure accountability and transparency in the department’s operational
performance
 maintain accurate records and accounts, and report on these as required
 promote continual evaluation and improvement of department’s management
practices
Deputy Director- 
General,
Corporate

Services






Deputy DirectorsGeneral,
Assistant
DirectorsGeneral,
Regional
Directors,
Executive
Directors,
Directors and
Managers
delegated authority as the Fraud and Corruption Control Coordinator and acts
as ‘champion’ to drive the fraud and corruption control regime
Chair of the Fraud and Corruption Control Committee
oversee the implementation and management of the fraud and corruption
control framework
take steps to ensure that all areas assume appropriate responsibility for fraud
and corruption control and perform their functions according to the framework
and relevant legislation
ensure all areas of operation take the appropriate steps to implement
effective risk management practices, including risk assessment of fraud and
corruption in accordance with the enterprise risk management framework
ensure the scope and nature of the education, training and awareness
programs are comprehensive and designed to assist employees, contractors
and clients to recognise, detect and prevent fraud and corruption
provide advice to the Director-General and the EMG as necessary on fraud
and corruption matters
provide accurate and timely advice to the Audit and Risk Management
Committee through the Internal Audit Branch on any fraud and corruption
matters
 be ethical leaders and display high personal standards of behaviour
consistent with the Code of Conduct for the Queensland Public Service and
the department’s Standard of Practice
 have a visible adherence to the department’s ethical framework and promote
adherence by all employees
 contribute to effective risk management strategies in accordance with the
department’s enterprise risk management framework and ensure risk
management practices are adhered to throughout their area of control
 develop strong internal controls to assist with fraud and corruption prevention
in their area of responsibility
 ensure all employees are made aware of and attend appropriate education,
training and awareness sessions to allow for a skilled and knowledgeable
workforce, including public sector ethics education, training and awareness,
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Role
Responsibility
internal controls and financial or procurement training
 ensure effective employee communication on the process for identifying and
reporting on potential fraudulent and corrupt activities
 ensure where a public interest disclosure is made, the procedure for making
and managing a public interest disclosure is adhered to
 follow the mandatory internal or external reporting requirements for reporting
suspected official misconduct, including fraud or corruption
All employees





contribute to the development of improved systems, policies and procedures
to enhance the department’s resistance to fraud and corruption including:
 safeguarding assets and other resources under their control
 having a clear understanding of their obligations regarding any losses,
deficiencies and shortages that may be identified while at work
 ensuring all personal claims are accurate with no deliberate omissions
(recording accurate hours of work on timesheets)
fulfil their obligation to report wrongdoing in accordance with section 1.1 (d) of
the Code of Conduct for the Queensland Public Service and section 4.1 of the
department’s Standard of Practice
actively seek education and training to learn and maintain knowledge and
skills required to undertake their duties
gain an understanding of the policies, procedures and guidelines that pertain
to their role and work within the requirements of these
follow the requirements for internal reporting of suspected fraud and
corruption
There is an obligation placed on all employees, contractors and anyone
associated with the department to understand that managing fraud and corruption
is as much a part of their responsibility as it is of the managers and senior
leaders of the department.
Audit and Risk 
Management
Committee
advises the Director-General outlining audit matters and certain risks to the
department, including potential fraud and corruption matters and puts forward
pertinent recommendations regarding these and reviews:
 governance processes to ensure all matters relating to alleged fraud and
corruption or unethical conduct are dealt with appropriately
 currency, comprehensiveness and relevance of the enterprise risk
management framework, policy and procedure for identifying, monitoring
and managing significant business risks, including the identification and
management of risks related to fraud
 submit recommendations to the Director-General to approve the internal
audit plan, reviewing its scope and progress and any significant changes
to it, including any potential difficulties or restrictions on the scope of
activities
 review the internal audit plan annually to ensure it covers key fraud and
corruption risks and that there is appropriate coordination with the
external auditor, Queensland Audit Office
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Role
Responsibility
Director, Ethical  ensure the ESU fulfils the legislative function on behalf of the DirectorStandards Unit
General to investigate all allegations of suspected official misconduct
 ensure a proactive approach to public sector ethics by promoting an ethical
culture, practice and decision making through education and training
programs
 implement, maintain and review the fraud and corruption control framework
 ensure the fraud and corruption control framework undergoes a biennial
review or more frequently as required
 develop strategies in consultation with other key areas to achieve an effective
fraud and corruption regime
Ethical Standards
Unit

as CMC liaison officer report suspected official misconduct, criminal and other
matters to the appropriate external agency:
 Crime and Misconduct Commission
 Queensland Police Service
 Queensland Ombudsman
 Queensland Audit Office

conduct investigations into reports of suspected official misconduct, including
fraudulent or corrupt practices
manage and coordinate all public interest disclosures made to the department
and ensure adequate support and certain protections are afforded the
discloser in accordance with Public Interest Disclosure Act 2010
develop and maintain ethics related policies and procedures for building and
sustaining integrity and accountability; for example, Standard of Practice,
public interest disclosure procedure and guidelines, conflicts of interest,
notification of other employment, bullying, lobbying and the fraud and
corruption framework
develop public sector ethics related education and training material to
promote an ethical culture and performance; such as the ethical decision
making awareness, internal controls and fraud awareness
provide advice and direction to employees on the correct protocol for
reporting matters to external agencies




Internal Audit
Branch





provide independent appraisals, examination and evaluation of the
department’s activities and assist management with the detection of
suspected fraud and corrupt activities
manage the department’s ‘fraud and corruption hotline – 1800 727 031’
undertake scheduled audits, which include examining established controls to
determine if these are robust enough to reduce the risks of fraud and
corruption, including the identification of work practices that may lead to
fraudulent and corrupt activities
undertake targeted audit activities to specifically identify any indication that
fraud may have occurred, be alert to opportunities that could allow fraudulent
activities
report in writing any suspected activities of fraudulent or corrupt practices
identified during an internal audit function to the Director, ESU for assessment
and possible investigation or referral to the appropriate external agency
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Appendix 3: Fraud and Corruption Control Risk Assessment Plan
The fraud and corruption control risk assessment plan is being developed in consultation with key stakeholders and will be inserted upon completion.
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Appendix 4: Definitions
Term, abbreviations and
acronyms
Code of Conduct
Definition
The Code of Conduct for the Queensland Public Service
outlines a set of ethics principles, values and standards of
conduct all public service employees are expected to work
within and how they should conduct their relationships with
others
The Code applies at all time when employees are performing
their official duties including when they are representing the
Queensland government at conferences, training events, on
business trips and attending work related social events
Corruption
Dishonest behaviour that may involve the misuse of position or
authority or other acts for personal gain or advantage, or for
another person or entity, which may cause loss to the
department, its clients or the general community
It may also include other elements such as breaches of trust
and confidentiality
Employee
Fraud
For the purposes of this framework and in accordance with the
Code of Conduct for the Queensland Public Service an
employee is defined as:

any Queensland public service agency employee whether
permanent, temporary, full-time, part-time or casual;

any volunteer, student, contractor, consultant or anyone
who works in any other capacity for a Queensland public
service agency
Any deliberate deceitful conduct or omission designed to gain
an advantage to which a person or entity is not entitled
The intentional use of false representations or deception to
avoid an obligation, gain unjust advantage or in the context of
public administration, commonly known ‘rorting the system’
Fraudulent conduct by departmental employees may fall within
the category of official misconduct under the Crime and
Misconduct Act 2001
The offence of fraud is set out in section 408C of the Criminal
Code Act 1899
Fraud and Corruption Risk
Assessment
The application of risk management principles and techniques
in the assessment of the risk of fraud and corruption
A fraud and corruption control risk management assessment
guide has been developed to assist all managers to undertake
an assessment of the work environment to ensure appropriate
and effective identification, analysis, reporting, managing and
treating of all potential acts of fraud and/or corruption
Misconduct
The Public Service Act 2008, section 187 (4) defines
misconduct to mean inappropriate or improper conduct in an
official capacity or inappropriate or improper conduct in a
private capacity that reflects seriously and adversely on the
public service
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Term, abbreviations and
acronyms
Official misconduct
Definition
Official misconduct is defined in section 15 of the Crime and
Misconduct Act 2001 as conduct that could, if proved, be:

a criminal offence; or

a disciplinary breach providing reasonable grounds for
terminating the person’s servicers, if the person is or was
the holder of an appointment
Official misconduct is summarised as any serious misconduct
relating to the performance of an employee’s duties that is
dishonest or lacks impartiality, or involves a breach of trust, or
misuse of officially obtained information
The conduct must be a criminal offence or a breach of
discipline serious enough to warrant dismissal
Standard of Practice
The Standard of Practice is an agency-specific, supplementary
document to be used in conjunction with the Code of Conduct
for the Queensland Public Service and outlines standards of
conduct that relate specifically to the department’s employees
in the same way as the Code
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