Tip-offs and Public Interest Disclosures
Put in place processes for staff or external parties to lodge tip-offs or Public Interest Disclosures.
Why this countermeasure matters
A lack of discreet and confidential ways for staff or external parties to report fraud and corruption may lead to:
- a dysfunctional workplace culture
- fraudsters feeling more confident their actions will not be detected
- fraud or corrupt activity going unnoticed or unchallenged
- less action and accountability to prevent, detect and respond to fraud and corruption
- unknown and unaddressed systemic fraud or corruption.
- individuals being unable to self-report, leading to further fraud or non-compliance.
How you might apply this countermeasure
Some ways to implement this countermeasure include providing a way for individuals, third parties and staff to confidentially lodge:
- a fraud tip-off using a dedicated reporting line
- a fraud tip-off using an online form through an internal or external website
- a Public Interest Disclosure if they suspect wrongdoing within the Commonwealth public sector.
How to check if your countermeasures are effective
Here are some ways to measure the effectiveness of this type of countermeasure:
- confirm that a consistent process exists for reporting fraud and corruption
- confirm that the process for reporting fraud and corruption is easy to locate and use
- analyse data related to tip-offs and look for trends
- confirm that the options for reporting fraud and corruption are clearly communicated
- consider if the process supports the person reporting fraud and corruption
- confirm if the processes are compliant with the Public Interest Disclosure Act 2013 (Cth), the Commonwealth Fraud Control Framework and other national frameworks and Guidelines
- analyse case studies to determine if processes are effective
- review unsuccessful tip-offs such as those that did not provide anything useful and analyse why that was the case
- confirm that processes cater for all different types of fraud and corruption
- confirm that processes cater for different sources such as external individuals, staff, vendors and other organisations.
This type of control is supported by:
Adequately resourced prevention and compliance areas enable entities to perform effective countermeasures.
Allow clients, staff and third parties to lodge complaints about actions or decisions they disagree with. This may identify fraud or corruption as a cause for complaints, such as a failure to receive an expected payment.
A positive workplace culture can encourage ethical and supportive behaviours while discouraging fraudulent or corrupt activities. Staff will be less able to rationalise fraudulent or corrupt activities where a positive workplace culture exists. A culture built on honesty, transparency and integrity is a key organisational strength that can serve to reduce the risk of fraud. If weak countermeasures are the fuel, a bad culture can be the spark that ignites fraud and corruption.
Establish governance, accountability and oversight of processes by using delegations and requiring committees and project boards to oversee critical decisions and risk. Good governance, accountability and oversight increases transparency and reduces the opportunity for fraud.
Train and support staff to identify red flags to detect fraud, know what to do if they suspect fraud and know how to report it. Fraudsters can take advantage if staff and contractors are not aware of what constitutes fraud and corruption.