Defined decision-making powers
Clearly document decision-makers using delegations, authorisations and instructions. Clearly defined decision-making powers increase transparency and reduce the opportunity for fraud and corruption.
Why this countermeasure matters
A lack of clarity for decision-making powers can lead to:
- high levels of non-compliance or errors due to inconsistent practices
- common use of shortcuts and workarounds
- a lack of transparency over actions and decisions
- poor management of fraud and corruption risks
- fraudsters not obtaining approval or obtaining approval from someone who is not the appropriate decision-maker
- fraud or corrupt activity going unnoticed or unchallenged
- unknown and unaddressed systemic fraud or corruption.
How you might apply this countermeasure
Some ways to implement this countermeasure include:
- Accountable Authority Instructions
- financial delegations, such as requiring international travel up to $30,000 to be approved by the Department Secretary
- HR delegations, such as for approving leave and entitlements
- procedures that define who can make decisions, such as requiring approval by a manager or central delegate to change a vendor’s bank account
- clear responsibility for decision making in joint or multi-agency programs.
This countermeasure is most effective when combined with system workflows to make sure all requests, claims or activities are only approved by the appropriate decision-maker.
How to check if your countermeasures are effective
Here are some ways to measure the effectiveness of this type of countermeasure:
- confirm instruments of delegation exist, are current, and align to relevant legislation, policies and guidelines
- undertake testing or a process walk-through to confirm that processes cannot be avoided
- review a sample of approval decisions to determine whether processes and workflows are followed on all occasions
- identify how the requirement to follow specified decision-making processes are communicated to staff
- confirm that someone cannot bypass the process when subject to pressure or coercion.