Corruption risks and behaviours


Know your risk areas

ACT Government directorates and agencies are responsible for a range of functions. Some functions are more vulnerable to corruption, particularly if appropriate measures are not taken to address risks.

Functions that involve high levels of autonomy or discretion, coupled with limited accountability and oversight, have a greater corruption risk.

Important note: The below is not a comprehensive list of corruption risks. Some areas will have different risks that need specific treatment or prevention measures.

Consider corruption risks across your organisation, at both the operational and strategic levels. Consider the circumstances around how functions are performed, including the environment, context and people involved.

Regularly assess of your prevention measures to check that they are fit for purpose.

Functions that are at a higher risk of corruption
Working in an area that receives cash payments
Planning, managing, or deciding on large-scale procurement activity
Inspecting, regulating and monitoring compliance with, or adherence to, standards and requirements
Issuing qualifications or licences to individuals, groups or other entities which demonstrate proficiency in, or enable the undertaking of, certain activities
Allocating monies or other benefits, including funds, grants, subsidies, financial assistance, welfare or concessions
Issuing, or reviewing the issue of, fines or other sanctions
Assisting or caring for vulnerable people
Making decisions or judgements concerning individuals, or deciding on disputes involving multiple parties
Approving land rezoning or land development applications
Having regular contact or interactions with criminal or higher-risk entities while performing normal duties
Having regular interactions with the private sector, other than for the routine purchasing of goods and services
Having access to, or being responsible for dispensing, controlled substances

Any function, duties or projects where:

  • public officials are afforded high levels of discretion in decision making
  • oversight is limited or not possible or where the nature or location of duties limits opportunities for direct accountability
  • time and resourcing pressures require modification or non-adherence to normal due diligence requirements
  • public officials are detached from their agency’s usual integrity measures (e.g. reporting and support measures) for an extended period
  • contemporary skills and knowledge obtained while performing public duties is highly valued and/or would provide significant competitive advantage to commercial entities
  • expectations/requirements regarding proper conduct/process are vague, ambiguous and/or may be subject to a significant degree of varied interpretation and/or discretion (grey area) or “wriggle room"
  • a public official is afforded additional access (for example ICT administrators, payroll officers) to systems and/or information.

Corruption risk factors and behaviours

Below are some corruption risk factors and behaviours observed through our investigations. It’s important to be able to identify the types of corruption risks within your organisation.

Corruption riskDescription
Conflict(s) of interest

A conflict of interest exists when a public official’s personal interests do, or could, inappropriately influence the performance of their official duties. A conflict of interest may also exist when it could reasonably be perceived that a public official’s personal interests could be favoured over their official duties.

Having an actual, potential or perceived conflict of interest does not automatically constitute corrupt conduct. The potential for corruption increases where conflicts of interest are undeclared, played down, mishandled, exploited or hidden.

The likelihood of corrupt conduct occurring increases when public officials decide to self-manage the risk associated with an actual or potential conflict of interest. This prevents an agency from resolving or addressing the risk appropriately.

The significant discretion and authority senior public officials have makes them particularly vulnerable to allegations of corrupt conduct. This may result in questioning the legitimacy of important decisions if conflicts of interest are not declared or are mismanaged.

Undeclared relationships and associations

A declarable relationship or association exists when a public official has a connection (or a perceived connection) with one or more entities. This includes people, groups and organisations that does, could, or may be perceived to influence the performance of their official duties.

Undeclared relationships, including those involving workplace colleagues or other personal and professional associations, may increase the risk or add weight to allegations of cronyism and nepotism. This is particularly true in recruitment or procurement processes.

Serious and organised criminal entities target public officials for access to information to further their illicit activities. These entities may use intimate relationships, family connections, professional associations or cultural and social links to exploit, leverage or compromise public officials.

Gifts and benefits

A gift or benefit is any item or service – regardless of monetary value – offered by clients, customers (including potential clients or customers) or other associates of a public official which relates to the performance of their official duties.

The motivations behind the giving of gifts and benefits can vary. The risk of compromise increases where the gift giver expects or demands something in return from the public official. This could look like favourable actions or decisions.

Even low-value gifts and benefits may expose public officials to compromise where there is an expectation, or perception, that they are being used to generate favourable relationships.

Some entities, including serious and organised criminals, may target and exploit public officials by giving gifts or benefits. This is part of sophisticated grooming or manipulation technique. This risk may increase when public officials have regular or ongoing contact with criminal entities. For example, a person working in a Corrections environment.

Unauthorised disclosure of information

An unauthorised disclosure occurs when a public official, intentionally or inadvertently, makes information available or accessible to others without having the authority to do so. The unauthorised disclosure of information may constitute corrupt conduct. It can also be a criminal offence.

Through their work, public officials can have access to sensitive (personal, commercial and other) information. The value of this information may be considerable for certain external parties. For example, businesses may seek information to gain a commercial advantage over competitors.

Criminals also place a high value on information. They can use it to exploit people or vulnerabilities in systems and processes to further their criminal enterprises.

Motivations for the disclosure of information vary. Reasons can include seeking a personal benefit (monetary or otherwise); a loyalty or obligation to familial, social or cultural groups; or a response to a perceived social injustice (a ‘noble cause’ disclosure).

Inadvertent disclosures may occur when public officials share work-related information online. This may happen when using social media, or discussing their duties in an unsecured environment, including with family and friends.

The unauthorised disclosure of information can cause substantial operational, financial and reputational damage to the integrity of government.