Fraud and Corruption Prevention Policy

This policy outlines the Department of Creative Industries, Tourism, Hospitality and Sport (the Department)’s approach to the prevention, detection and reporting of suspected and actual instances of fraud and corruption. The Department has zero-tolerance for fraud and corruption.

Listen

On this page

Scope

This policy applies to all Departmental employees (ongoing, temporary, and casual and those on secondment to the Department), including Destination NSW (DNSW), as well as contractors, subcontractors, trainees, work experience students, volunteers and all persons engaged to perform work for, or on behalf of, the Department in either a paid or unpaid capacity.

This policy applies anywhere the Department may undertake business. Some Australian laws may apply to your conduct outside of Australia, in addition to the operation of relevant local laws. The Department’s suppliers, service providers and non-government organisations (NGOs) are expected to have similar fraud and corruption control measures in place to prevent, detect and respond to fraud and corruption.

Definitions

Corrupt conduct has the meaning defined in Section 8 of the Independent Commission Against Corruption Act (ICAC Act). It includes deliberate improper acts or omissions, improper use of influence or position, and/or improper use of information. Corrupt conduct can include but is not limited to:

bribery (employees must refer to the Anti-Bribery Policy)
blackmail
theft (including data and information theft)
embezzlement
revenue or tax evasion
currency violations
fraud.
a government agency, administrative office, or teaching service
a statutory body representing the Crown
a local government authority
a body required to keep certain accounts under the Government Sector Audit Act 1983(NSW)
or over which the Auditor-General has powers of audit.

Examples of fraud and corruption

Fraud is when a person acts dishonestly while causing an actual or potential benefit or loss by deception or some other dishonest activity. For example, misuse of assets (including information).

A public official is defined in section 3 of the ICAC Act as an individual having public official functions or acting in a public official capacity. People working in the Parliament, government departments, statutory authorities, and local councils in NSW, as well as NSW magistrates, judges, local councillors, and members of Parliament are all public officials.

A public authority is defined in section 3 of the ICAC Act and can include:

The following list is not exhaustive but includes some of the more common examples of fraud and corruption found in the public sector:

theft of equipment, consumables or supplies and information.
unauthorised use of computers, confidential information, departmental property.
abuse of position by seeking bribes or gifts.
abuse of power in recruitment, procurement, grants, and contract management.
misuse of systems including falsifying timesheets and payment claims.
destroying or altering records, or unauthorised amendment of payroll records.

Responsibilities

The Department is committed to a ‘speak up’ culture. Annexure A sets out the processes for reporting suspected fraud and corruption.

All employees must:

comply with this policy and must not engage in fraud and corrupt conduct
act honestly in their use of public resources and maintain the highest ethical standards
act in accordance with the DCITHS Code of Ethics and Conduct
take practical steps to avoid or manage the risks associated with fraud and corruption in the workplace, and report all suspected cases using the options listed in Annexure A
act in a manner that promotes and encourages the reporting of fraud and corrupt conduct
comply with workplace policies, procedures and internal control systems that mitigate fraud and corruption risks
actively participate in DCITHS-issued training in relation to fraud and corruption prevention
ensure suppliers, tenderers, contractors and consultants are aware of their ethical standards obligations during engagements.

Managers

have a responsibility to receive and deal with reports of fraud and corrupt conduct as set out in the Public Interest Disclosure Policy
are accountable for effectively managing fraud control and corruption prevention by completing and updating risk management plans within their area of responsibility as required by the Risk Management Policy for the Department. Destination NSW employees should refer to the relevant risk management policy on the DNSW intranet.
have a responsibility to ensure all employees are aware of their responsibilities and this policy
encourage employees’ input into planning and implementation of anti-corruption measures
support and promote a zero-tolerance culture for fraud and corruption within the Department
embed workplace policies, procedures and internal control systems that mitigate fraud and corruption risks.
have a responsibility to ensure all employees comply with the Fraud and Corruption Prevention Policy as well as the Code of Ethics and Conduct.
provide oversight and ensure Department policies, procedures and internal control systems are appropriately resourced and implemented to prevent, detect and respond to fraud and corruption.

Secretary

exercise leadership and promote a culture of ethical conduct
reinforce the Department’s zero tolerance for fraud and corruption
provide notification of corrupt conduct to the ICAC in accordance with section 11 of the ICAC Act

Audit and Risk Committee (ARC)

ensure that there is an appropriate fraud and corruption control framework in place, including processes, controls and systems to capture and effectively investigate fraud related matters (as required by the Treasury Policy Paper 20-08 Internal Audit and Risk Management Policy for the General Public Sector (TPP20:08)).
review and oversee fraud and corruption prevention activities and advise the Secretary on the adequacy of activities and outcomes
consider the management of fraud risk areas as part of its internal audit plan

Ethics & Integrity

lead the implementation of this Policy to support the prevention, detection and response to fraud and corruption risks with the Chief People Officer.

Policy

1. Fraud and Corruption Control Framework

The DCITHS Fraud and Corruption Control Framework governs fraud and corruption prevention, detection, and response by the Department. The framework aligns with Treasury Circular TC18-02 Fraud and corruption control policy. The framework incorporates the attributes of fraud control under the stages of Foundation; Prevention; Detection; and Response, as follows:

1.1 Foundation

This Policy sets out the appropriate structures and responsibilities required for the prevention and detection of fraud and corruption.

1.1.1 Ethical Framework

The Department maintains policies, procedures and guidelines that collectively underpin a culture of integrity and ethical conduct, including:

1.1.2 Awareness

All employees are required to:

undergo pre-employment or probity screening as required, and
complete the Department’s Code of Ethics and Conduct training and all other mandatory training required to understand their responsibilities under this policy.

1.1.3 Business relationships

Employees who engage third parties to provide goods, services or labour to the Department are required to conduct all procurement and business relationships with honesty and fairness in accordance with this policy. The Department may conduct supplier due diligence activities including probity and audit checks to ensure compliance with standards.

The Department’s approach to bribery and corruption will be communicated to all suppliers, contractors, and business partners at the outset of the business relationship with them and as appropriate thereafter through the Statement of Business Ethics.

1.2 Prevention

The Department will prevent fraud and corruption by maintaining effective financial and operational controls, delivering targeted training for employees, and by encouraging a “speak up culture” to support employees to report incidents of potential and actual fraud and corruption.

Risk Assessment

Employees are encouraged to familiarise themselves with the DCITHS Risk Management Framework.

Destination NSW employees should refer to the relevant risk management policy on the DNSW intranet.

1.2.1 Conflicts of interest and disclosure

A conflict of interest may arise in situations where there is a conflict between public duty and private interest. Employees must declare any conflicts of interest (potential, actual or perceived) by completing the Declaration of Interests and Senior Executive Private Interests Form, and those interests are to be managed in accordance with the DCITHS Code of Ethics and Conduct and Conflicts of Interest Policy.

Senior executive

Public service senior executive (PSSE) officers must disclose in writing any private financial, business, personal or other interests or relationships that have the potential to influence or could be perceived to influence a person’s decision or advice given as set out in the DCITHS Code of Ethics and Conduct and the Conflicts of Interest Policy.

1.2.2 Employee screening

Employee screening should be risk-based and appropriate to the role and with consideration to relevant risks, legislative requirements, qualifications and licenses, and role requirements. It may include reviewing an employee’s service and conduct history and criminal record, among other actions. This must occur for employees as circumstances change, for example when they are promoted or moved to a different role.

1.2.3 IT systems, physical and digital asset security and management

The Department has a responsibility to have in place appropriate measures to prevent the theft or misuse of valuable physical and digital assets and identify systems, processes, and mechanisms that will reduce the risk of fraud and corruption occurring.

The Chief Information Security Officer should regularly assess the Department’s exposure to technology-enabled fraud and strengthen cyber security practices where necessary. All employees need to be alert and vigilant to technology-enabled fraud and report cases to Information Technology.

Refer to the IT Acceptable Use Policy and the Information Security Policy for more information.

Financial systems

The Department will implement robust processes, controls, and reporting in relation to expenditure, cash management, and banking, investments, and transfers of money. The Department has a responsibility to ensure appropriate controls into the suite of procurement processes.

1. 3 Detection

1.3.1 Reporting

All staff are required to report any instances of suspected fraud or corruption. Staff can make reports of fraud and corruption in accordance with the Public Interest Disclosure Policy and Annexure B of this policy.

All suspected instances of fraud and/or corruption which come to the attention of a manager no matter where located, must be reported to either the Secretary, the Disclosure Coordinator, or a Disclosure Officer as set out in the Public Interest Disclosure Policy and Annexure B. Where there are reasonable grounds to suspect corruption or a criminal offence has occurred or is about to occur, the Deputy Secretary, Corporate Services must report the matter to the appropriate external body. The Department will ensure all reported allegations of fraud and/or corruption are reviewed and dealt with appropriately.

The Department is committed to an open environment where all staff can confidently report any suspected improper conduct without fear of detrimental action. The Department endeavours to protect staff making reports from any form of detrimental action.

The Department will not tolerate detrimental action against its staff for making a report under this policy.

1.3.2 Internal audit systems

The Chief Risk Officer has oversight of the organisation’s risk framework and providing the necessary oversight and reporting on risk management practices within the Department.

The Department’s Chief Audit Executive oversees the Annual Internal Audit Plan that includes assessing the adequacy and effectiveness of internal controls and reporting on deficiencies and weaknesses that require corrective action.

Internal audits/reviews regularly examine samples of medium and high-risk processes across the Department to assess the adequacy of controls and to detect irregularities. Outcomes of audits/reviews are reported to the ARC.

The Department’s internal audits are reviewed by the ARC. The Deputy Secretary, Corporate Services will monitor the implementation of recommendations from Internal Audit to safeguard the Department against fraud and corruption.

1.4 Responding

1.4.1 Action on discovery

A fraud and corruption event needs to be responded to promptly and appropriately, and should include the immediate completion of a risk assessment. Where a serious allegation is made, and until an investigation is complete, action must be taken to minimise the harm or potential for harm to the Department or its employees.

1.4.2 Investigations

All reports of alleged fraud and corrupt conduct will be dealt with appropriately and treated confidentially.

In most cases, the Department will investigate whether the alleged fraud or corrupt conduct occurred, who was involved, who was responsible, and whether the people involved, or the agency, engaged in serious wrongdoing and what corrective action may be appropriate.

1.4.3 External reporting

The Department has statutory obligations to report instances of fraud and corruption to external agencies as set out below:

Crime

Section 316 of the Crimes Act 1900 outlines the duty to notify the NSW Police Force of serious crimes.

Corrupt conduct

Section 11 of the ICAC Act outlines the duty of the Secretary, as the principal officer of a Public Sector agency, to report to the ICAC any matter that they suspect on reasonable grounds concerns or may concern corrupt conduct.

Financial statement discrepancies

The Secretary, with the assistance of Chief Financial Officer, must report any known incidences that materially impacted the Department’s Annual Financial Statements to the Audit Office of NSW as part of the annual audit process. The Chief Financial Officer must advise the Chief Audit Executive of any financial statement discrepancies.

Public interest disclosures

Section 78 of the Public Interest Disclosure Act 2022 requires an annual return to the NSW Ombudsman which includes information about receiving, actioning and promoting Public Interest Disclosures.

1.4.3 Disciplinary actions

Substantiated allegations of fraud and/or corruption, or attempted fraud and/or corruption, may result in disciplinary action and/or criminal prosecution.

Individuals found to have committed an offence under any relevant legislation may also be subject to penalties and actions as prescribed by the legislation.

Contact

Further information about this policy can be obtained by:

contacting Ethics & Integrity
visiting the website of the NSW Independent Commission Against Corruption or the website of the Public Service Commission.

Variation

The Department may vary this policy from time to time as appropriate.

Policy Owner	Last revision/Approval date
Chief People Officer	30 June 2025
Chief People Officer	September 2024
Deputy Secretary, Corporate Services	1 October 2023

Annexures

Annexure A

Reporting Fraud and Corruption

You can make a report inside the Department to:

the Secretary
the Disclosure Coordinator or a Disclosure Officer set out in Annexure A of the Public Interest Disclosure Policy
the Ethics & Integrity Team by emailing ethics@dciths.nsw.gov.au
your manager — this is the person who directly, or indirectly, supervises you. It can also be the person who you directly, or indirectly, report to. You may have more than one manager. Your manager will make sure that the report is communicated to a disclosure officer on your behalf or may accompany you while you make the report to a disclosure officer.
the Department’s external Integrity Hotline (includes an anonymous report option). This service is provided by Core Integrity and reports can be made by:
- Phone: 1800 303 406
- Online: Use the online portal or scan the QR Code:
- Email: DCITHSIntegrityHotline@coreintegrity.com.au
- Post: PO Box 730, Milsons Point 1565

Where employees do not wish to use internal reporting options, reports can be made directly to the relevant integrity agency listed in Annexure B of the Public Interest Disclosure Policy.

Where relevant, a report of fraud or corruption may also be dealt with in accordance with the Public Interest Disclosure Policy as well as this policy.

Top