Evaluation of TAFE SA

Summary

The report's own summary: Executive summary, pages 10 to 11

In the body's own words

1. Finding

   There are opportunities for TAFE SA to strengthen its awareness and assessment of those risks and behaviours beyond the current understanding provided by its risk appetite statement and external audit function.

   Report, page 10

Findings, opinions and statements

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.

No findings are reproduced in this record. This does not establish that the report contains none.

Recommendations 34

1. Recommendation 1

   TAFE SA conduct a dedicated fraud and corruption risk assessment to complement and strengthen its overall risk management framework.1

   Report, page 14

2. Recommendation 2

   TAFE SA identify ways to better incorporate elements of fraud and corruption risk assessments into its internal audit program, especially for audits into functions, activities or processes identified as being high risk for corruption.

   Report, page 14

3. Recommendation 3

   TAFE SA update and distribute a detailed organisational chart to staff and provide periodic and regular updates to staff.

   Report, page 14

4. Recommendation 4

   TAFE SA conduct focus groups with staff across business units to review the effects of restructures and strategic plans with the aim to identify areas of duplication, communication issues, and work team or process silos.

   Report, page 14

5. Recommendation 5

   TAFE SA include conflict of interest disclosure and management obligations in its revised recruitment framework and in its panel training resources.

   Report, page 14

6. Recommendation 6

   TAFE SA provide training to all panel members involved in recruitment activities, with consideration given to making the training mandatory for appointment to a recruitment panel.

   Report, page 14

7. Recommendation 7

   TAFE SA conduct a role risk rating process to identify positions of trust which should attract higher scrutiny and screening processes during recruitments for those roles (including internal). Consideration also be given to conducting periodic post-employment screening for roles with the highest risk rating.

   Report, page 14

8. Recommendation 8

   TAFE SA amend its Pre-employment Declaration to screen for secondary employment or other remunerated activities of candidates.

   Report, page 15

9. Recommendation 9

   TAFE SA review and consolidate its various complaint, grievance, performance and behavioural management policies and mechanisms. Policies should clearly set out the process from assessment of complaints to disciplinary investigations and the imposition of sanctions.

   Report, page 15

10. Recommendation 10

    TAFE SA create at least one dedicated integrity position within the People and Culture directorate (such as a Principal Integrity Officer) responsible for: ⊲ overseeing the assessment and referral of complaints ⊲ overseeing any preliminary investigation or other processes undertaken by management relevant to a complaint ⊲ investigating serious misconduct allegations.

    Report, page 15

11. Recommendation 11

    TAFE SA ensure that all staff who have responsibilities for managing or conducting investigations complete the Commission’s Internal Investigation Seminar and Workshop.

    Report, page 15

12. Recommendation 12

    TAFE SA conduct a workforce structure review which maps lines of accountability and supervisory relationships with a view to determining integrity gaps or stresses within the workforce. This workforce review should be additional to, and complement, TAFE SA’s New Strategic Workforce Plan.

    Report, page 15

13. Recommendation 13

    TAFE SA amend the Induction Policy to include a local and worksite induction for internal employees who have moved to new positions.

    Report, page 15

14. Recommendation 14

    TAFE SA extend its employee exit practices to have the People and Culture directorate monitor and follow up employee exit interviews. Consider auditing recent employee access and use of information and resources for employees in positions of trust, those moving to roles at organisations that might benefit from access to TAFE SA information or resources, or on any signs of unusual or suspicious activity.

    Report, page 16

15. Recommendation 15

    TAFE SA assess its procurement compliance scheme to develop a schedule of procurement corruption risk signals or priority measures and triggers to prompt further scrutiny of at risk procurement processes.

    Report, page 16

16. Recommendation 16

    TAFE SA develop a simple integrity guideline for the procurement of consultancy services, the consideration and acceptance of unsolicited bids or proposals, direct single source approaches, and the risks of undeclared conflicts of interest. TAFE SA executive, managers and senior staff should be periodically instructed on the guideline, and refer to it prior to any relevant procurements.

    Report, page 16

17. Recommendation 17

    TAFE SA amend its procurement procedures to include a check of secondary employment, financial interests and conflicts of interest registers at appropriate stages of all procurements.

    Report, page 16

18. Recommendation 18

    TAFE SA commit to a future review of low value procurements (below $55,000) to explore ways to protect those activities from abuse. That review should ensure: ⊲ that any consolidation of a function (i.e. within Stores or equivalent units) maintains appropriate separation between procurement, contract management and inventory roles ⊲ processes are in place to manage vendor-employee relations, gifts and benefits, conflicts of interest, and supplier and company checks ⊲ provision of procurement training to new and existing staff conducting (or in close proximity to) large volumes of low value procurements ⊲ the activity has some level of supervision from TAFE SA’s procurement team to detect anomalies, patterns and irregularities

    Report, page 16

19. Recommendation 19

    As part of its review of low level procurement systems and practices, TAFE SA explore opportunities for efficiency and effectiveness to offset the removal of widespread purchase card access.

    Report, page 17

20. Recommendation 20

    In accordance with the Commission’s publication Buy Now, Lie Later: Corruption Risks in the Management of Government issued Purchase Cards, TAFE SA modify its purchase card practices, especially in assessing the business need for issuing particular employees with purchase cards.

    Report, page 17

21. Recommendation 21

    TAFE SA set out in its Asset Disposal policy that misappropriation of surplus or low-value assets or unwanted or forgotten items can amount to theft.

    Report, page 17

22. Recommendation 22

    TAFE SA regularly convene a working group of campus facilities staff drawn from all campuses to monitor the operation of the Across Government Facilities Management Arrangements, and devise processes and strategies to better manage the work of contractors and facilities maintenance generally.

    Report, page 17

23. Recommendation 23

    TAFE SA commit to a specific fraud and corruption assessment whenever substantial changes are made to its subsidy structures, funding arrangements, policy settings or financial governance instruments, in order to determine whether and where they might have stimulated opportunities for exploitation.

    Report, page 17

24. Recommendation 24

    TAFE SA commit to reviewing its results attribution practices to prevent, manage or mitigate any incentives for improper resulting among lecturers, and assess further opportunities to improve result monitoring and moderation.

    Report, page 17

25. Recommendation 25

    TAFE SA update its lecturer behaviour and staff/student relations policy suite (especially the Professional Boundaries for Lecturers Guidelines) to reflect specific risks of bribery, inducement, threat, unduly favourable treatment, and abuse of public office risks. Consider explicit training for staff to support the recently introduced Professional Boundaries for Lecturers Guidelines.

    Report, page 17

26. Recommendation 26

    TAFE SA ensure all complaints and reports of unsatisfactory lecturer conduct, as well as action taken to address the conduct, be referred to and monitored by a dedicated integrity officer such as a Principal Integrity Officer. This should be supported by periodic reporting to the People and Culture Committee.

    Report, page 18

27. Recommendation 27

    TAFE SA conduct an audit of past ICT system procurements across all workgroups, close down all systems and services which are obsolete, unnecessary or present risks to TAFE SA’s brand or information, and transition services to TAFE SA’s new enterprise booking/scheduling software.

    Report, page 18

28. Recommendation 28

    TAFE SA seek to strengthen its Fee For Service function by: ⊲ further ‘ring fencing’ the function to ensure confidential or sensitive commercial information does not move too freely among staff and teams at the agency. ⊲ amending the Educational Commercial Revenue Policy to include regular processes to manage conflicts of interest, and provide staff with regular opportunities to identify and declare any conflicts. Conflict of Interest policy expectations should be set out in the Educational Commercial Revenue Policy. ⊲ including the Gifts and Benefits Policy and register in the Fee For Service function, and set out expectations in the Educational Commercial Revenue Policy. ⊲ implementing a staff register of interests to be updated and consulted during revenue generating activities.

    Report, page 18

29. Recommendation 29

    TAFE SA develop a policy and procedure addressing the management of industry and client engagement with particular regard to managing conflicts of interest that may arise.

    Report, page 18

30. Recommendation 30

    TAFE SA provide industry and client relationship risk management training to staff with significant exposure to, or dealings with, industry and commercial clients.

    Report, page 18

31. Recommendation 31

    TAFE SA require all staff in positions of trust (not just executives) to annually declare and record financial interests, with a record being retained on a central register.

    Report, page 18

32. Recommendation 32

    TAFE SA create a standalone secondary employment and other remunerative activities policy (separate from its existing Conflict of Interest Procedure) which requires employees to request approval for outside employment or business interests, and line managers to assess those declarations for risk before granting approval.

    Report, page 19

33. Recommendation 33

    TAFE SA conduct a risk assessment to identify business areas and employee positions particularly vulnerable to secondary employment risks. Staff in those areas and positions should be regularly reminded of their secondary employment obligations, and assessments should be conducted every 2-3 years.

    Report, page 19

34. Recommendation 34

    TAFE SA consider conducting ASIC company director searches and Australian Business Number searches against identified vulnerable employees/business areas to identify any business interests or other remunerative activities which may not have been approved by TAFE SA. Further inquiries should be undertaken where those searches reveal undeclared interests.

    Report, page 19

Published responses

No published response was found.

Coverage

This publisher

• Office for Public Integrity: publishes only its annual reports (excluded); no OPI report or statement records.
• Since October 2021 the Commission does not make findings of corrupt conduct; most records have no findings.
• Government and agency responses are recorded only where the Commission's page links them or the report reproduces them; implementation status is not published by the Commission as structured data.
• Scanned reports without a text layer are not read (no OCR); their recommendations stay not_extracted.
• Recommendations are extracted only from numbered 'Recommendation N' lists; reports that set out recommendations in prose, tables or unnumbered lists keep recommendations_status not_extracted.
• Findings are extracted only from investigation reports that state them in the Commissioner's own words (Oakden 2018, Gillman 2015); public statements are not read for findings.