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Elements and Performance Criteria

1. Identify organisational needs and obligations
   • Research obligations of the organisation based upon the concept of fraud and corruption as both ethical and law enforcement issues that impede effective performance of the organisation’s core business.
   • Identify all formal internal and external reporting requirements.
   • Identify organisational data analysis and information needs for fraud and corruption detection in line with privacy, confidentiality and law enforcement policy and legislative requirements.
   • Reflect a strategic management approach to the prevention of corruption/fraudulent activities in the needs identification.
   • Identify organisational responsibility for the coordination, monitoring, implementation, ongoing review and promotion of the organisation’s strategy and agree upon in consultation with senior management.
   • Identify organisational responsibility and agree upon for the protection of persons who provide information under legislation related to public interest disclosures, protected disclosures or whistleblowing legislation.
2. Benchmark fraud/corruption control strategy
   • Identify performance indicators.
   • Use best practice examples in the development of benchmarks.
   • Use standards-setting organisations where appropriate to assist in the identification of benchmarks relative to the organisation’s needs and core business.
3. Assess stakeholder and environmental considerations
   • Incorporate client entitlements including right to privacy, confidentiality, freedom from reprisals and freedom of information.
   • Consider issues, including profile of clients, corporate history and culture and staffing profile.
   • Consider constraints of operating environment, including staff shortages, geographical spread of staff and budgeting constraints.
   • Consider client and community expectations.
   • Identify management perspectives through consultations with those with relevant responsibilities in terms of the organisation’s business, and those with overall responsibility for oversight and implementation of fraud/corruption control in the organisation.
4. Develop organisation’s fraud/corruption control strategy
   • Achieve balance between compliance requirements and operational pressures.
   • Identify strategies to enable constant updating of the fraud/corruption control strategy to incorporate changing and newly identified risks.
   • Incorporate key factors, including the organisational environment and core business.
   • Recommend internal and external strategies based on assessment of relevant factors.
   • Incorporate internal and external quality assurance into the strategy and allocate responsibility for maintaining quality assurance.
   • Obtain acceptance of the strategy by authorities within the organisation and ensure it meet the requirements of the relevant standards-setting organisations.
5. Implement fraud/corruption control strategy
   • Develop initiatives required to minimise fraud and corruption in consultation with stakeholders.
   • Identify timeframe for implementation of strategy based upon an understanding of resource ramifications.
   • Identify areas within the organisation responsible for actions to minimise fraud and corruption.
   • Develop procedures for the reporting of information and the protection of persons who provide information under public interest disclosures, protected disclosures or whistleblowing legislation.
   • Undertake consultations with relevant personnel to facilitate a shared understanding of responsibilities.
6. Analyse and review effectiveness of strategy
   • Structure review to incorporate key features of the strategy underpinning the need for the strategy to be holistic and comprehensive.
   • Monitor and review to accommodate lessons learnt during application of the strategy.
   • Establish feedback and reporting mechanisms to provide information to senior management about effectiveness of the strategy measured against objectives, and to provide advice regarding changes to management practices.
   • Incorporate results of analysis and review to improve fraud and corruption control.
7. Identify organisational needs and obligations
   • Research obligations of the organisation based upon the concept of fraud and corruption as both ethical and law enforcement issues that impede effective performance of the organisation’s core business.
   • Identify all formal internal and external reporting requirements.
   • Identify organisational data analysis and information needs for fraud and corruption detection in line with privacy, confidentiality and law enforcement policy and legislative requirements.
   • Reflect a strategic management approach to the prevention of corruption/fraudulent activities in the needs identification.
   • Identify organisational responsibility for the coordination, monitoring, implementation, ongoing review and promotion of the organisation’s strategy and agree upon in consultation with senior management.
   • Identify organisational responsibility and agree upon for the protection of persons who provide information under legislation related to public interest disclosures, protected disclosures or whistleblowing legislation.
8. Benchmark fraud/corruption control strategy
   • Identify performance indicators.
   • Use best practice examples in the development of benchmarks.
   • Use standards-setting organisations where appropriate to assist in the identification of benchmarks relative to the organisation’s needs and core business.
9. Assess stakeholder and environmental considerations
   • Incorporate client entitlements including right to privacy, confidentiality, freedom from reprisals and freedom of information.
   • Consider issues, including profile of clients, corporate history and culture and staffing profile.
   • Consider constraints of operating environment, including staff shortages, geographical spread of staff and budgeting constraints.
   • Consider client and community expectations.
   • Identify management perspectives through consultations with those with relevant responsibilities in terms of the organisation’s business, and those with overall responsibility for oversight and implementation of fraud/corruption control in the organisation.
10. Develop organisation’s fraud/corruption control strategy
    • Achieve balance between compliance requirements and operational pressures.
    • Identify strategies to enable constant updating of the fraud/corruption control strategy to incorporate changing and newly identified risks.
    • Incorporate key factors, including the organisational environment and core business.
    • Recommend internal and external strategies based on assessment of relevant factors.
    • Incorporate internal and external quality assurance into the strategy and allocate responsibility for maintaining quality assurance.
    • Obtain acceptance of the strategy by authorities within the organisation and ensure it meet the requirements of the relevant standards-setting organisations.
11. Implement fraud/corruption control strategy
    • Develop initiatives required to minimise fraud and corruption in consultation with stakeholders.
    • Identify timeframe for implementation of strategy based upon an understanding of resource ramifications.
    • Identify areas within the organisation responsible for actions to minimise fraud and corruption.
    • Develop procedures for the reporting of information and the protection of persons who provide information under public interest disclosures, protected disclosures or whistleblowing legislation.
    • Undertake consultations with relevant personnel to facilitate a shared understanding of responsibilities.
12. Analyse and review effectiveness of strategy
    • Structure review to incorporate key features of the strategy underpinning the need for the strategy to be holistic and comprehensive.
    • Monitor and review to accommodate lessons learnt during application of the strategy.
    • Establish feedback and reporting mechanisms to provide information to senior management about effectiveness of the strategy measured against objectives, and to provide advice regarding changes to management practices.
    • Incorporate results of analysis and review to improve fraud and corruption control.

Performance Evidence

Evidence required to demonstrate competence must satisfy all of the requirements of the elements and performance criteria. If not otherwise specified the candidate must demonstrate evidence of performance of the following on at least one occasion.

undertaking analysis and strategic development

incorporating essential attributes of an effective fraud/corruption control policy into the strategy

consulting with senior management regarding the integration of the fraud/corruption control strategy with the broader corporate objectives

using liaison and communication styles to suit different audiences and purposes

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Knowledge Evidence

Evidence required to demonstrate competence must satisfy all of the requirements of the elements and performance criteria. If not otherwise specified the depth of knowledge demonstrated must be appropriate to the job context of the candidate.

the concepts of fraud/corruption risk management

risk management standards and techniques

agency corporate objectives and policy planning processes

the relationship between the fraud/corruption control strategy and the corporate goals and management practice of the agency

external reporting requirements

risk profile of the agency

control framework operating in the agency

jurisdictional fraud/corruption control requirements

legislation and procedures relating to public interest disclosures, protected disclosures or whistleblowing

public sector legislation, policies and procedures including antidiscrimination and diversity legislation, work health and safety, and environment

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