Investigation into the conduct of a principal officer of two non government organisations and others (Operation Tarlo)

Findings, opinions and statements 2

Allegations are not findings. A commission's finding or opinion of corrupt conduct or misconduct is not a finding that a person is guilty of a criminal offence, and the commissions say so in their reports.

1. serious corrupt conduct

   Finding

   The Commission found that Ms Sharobeem engaged in serious corrupt conduct by:

   Report, page 9, Summary of investigation and outcomes

2. serious corrupt conduct

   No finding

   No findings of serious corrupt conduct were made against any other person.

   Report, page 11, Summary of investigation and outcomes

Recommendations 12

1. Recommendation 1

   That the South Western Sydney Local Health District (SWSLHD), in conjunction with relevant non-government organisations (NGOs), develops additional outcomes-based key performance indicators (KPIs) that reflect the critical objectives of the services that it funds. Where possible, measurement of these KPIs should not be based solely on information self-reported by NGOs.

   NSW Health and the Department of Family and Community Services - allegations concerning the former CEO of the Immigrant Women’s Health Service and the Non-English Speaking Housing Women’s Scheme Inc (Operation Tarlo), Recommendations for corruption prevention

2. Recommendation 2

   That the SWSLHD adopts a coordinated and holistic framework for monitoring its funded NGOs that incorporates and links NGO governance capability, performance measures and financial reporting. This should entail less reliance on self-reported information.

   Report, page 10

3. Recommendation 3

   That the SWSLHD considers allocating additional staff to manage the NGOs it funds. Considerations for setting adequate staffing levels could include the nature of the service, the vulnerability of the client groups, and the potential governance and financial risks that could arise.

   Report, page 10

4. Recommendation 4

   That the SWSLHD requires funded NGOs to provide it with copies of audit management letters from external auditors.

   Report, page 10

5. Recommendation 5

   That the SWSLHD conducts an initial, thorough review of its funded NGOs, focusing on financial competence and whether adequate governance arrangements are in place to ensure probity around funding arrangements.

   Report, page 10

6. Recommendation 6

   That the SWSLHD develops risk metrics and conducts regular risk assessments of funded NGOs. The risk metrics should have regard to the risks that small NGOs can be prone to, including: limited staff numbers perverse incentives to falsify client data, either to enhance reputation or to lobby for increased funding · volunteer boards with limited time and skills to properly oversee the financial and administrative practices of the NGO and that members of these boards may not be aware of their responsibilities as managers of the CEO and/or other senior staff poorly segregated financial practices and controls CEO/coordinators with limited skills in managing staff, and in overseeing financial practices and systems.

   NSW Health and the Department of Family and Community Services - allegations concerning the former CEO of the Immigrant Women’s Health Service and the Non-English Speaking Housing Women’s Scheme Inc (Operation Tarlo), Recommendations for corruption prevention

7. Recommendation 7

   That the SWSLHD checks and, wherever possible, verifies the qualifications, and continued registration(where relevant), of NGO employees. This should adopt a risk-based approach by focusing on qualifications that are: mandatory to perform the service required for the provision of medical, psychological and allied health services or linked to the provision of any other services that could bring risks to the NGOs’ clients, and to the NGOs themselves. These checks could take the form of spot checks, risk-based checks or randomised checks on NGO staff members.

   NSW Health and the Department of Family and Community Services - allegations concerning the former CEO of the Immigrant Women’s Health Service and the Non-English Speaking Housing Women’s Scheme Inc (Operation Tarlo), Recommendations for corruption prevention

8. Recommendation 8

   That SWSLHD considers requiring funded NGOs to maintain an internal reporting or whistleblowing program that aligns to better practice (such as AS 8004-2003), and/or guidance issued by the NSW Ombudsman. Among other things, this should facilitate reporting directly to the SWSLHD or a similar representative body.

   Report, page 11

9. Recommendation 9

   That the NSW Department of Family and Community Services (FACS) considers requiring funded NGOs to provide it with copies of audit management letters from external auditors.

   Report, page 11

10. Recommendation 10

    That FACS, in conjunction with relevant NGOs, develops additional outcomes-based KPIs that reflect the critical objectives of the services that it funds. Where possible, measurement of these KPIs should not be based solely on information self-reported by NGOs.

    Report, page 11

11. Recommendation 11

    That FACS considers, as part of its ongoing review of its contract governance framework, implementing checks and (wherever possible) verifying qualifications, and continued registration (where necessary) of NGO employees.

    Report, page 11

12. Recommendation 12

    That FACS considers requiring funded NGOs to maintain an internal reporting or whistleblowing program that aligns to better practice (such as AS 8004-2003) and/or guidance issued by the NSW Ombudsman. Among other things, this should facilitate reporting directly to FACS or a similar representative

    Report, page 11

Published responses 5

• Final report - Department of Communities and Justice - FACS

  Other

• 12 month progress and final report - South Wesern Sydney Local Health District

  Progress report

• 12 month progress report - Department of Communities and Justice - FACS

  Progress report

• Action plan - South Western Sydney Local Health District

  Action plan

• Action plan - Family and Community Services (FACS)

  Action plan

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