Client and Community Awareness Programs (Anti-Corruption)

A client and community awareness program is the tenth and final component of the Queensland Crime and Corruption Commission's Fraud and Corruption Control Framework. It concerns the deliberate, outward-facing communication of an agency's fraud and corruption control standards to clients, contractors, suppliers, and the broader public, on the premise that external parties who understand what proper conduct looks like are better placed to notice, and report, conduct that falls short of it.

1 Legislative and standards basis

The Right to Information Act 2009 (Qld) establishes a presumption in favour of public access to government-held information, replacing the more restrictive freedom-of-information model that preceded it. This presumption of openness provides the legislative backdrop against which client and community awareness activity operates: an agency that discloses its fraud and corruption control standards, and information about how it is performing against them, is acting consistently with the general statutory posture toward transparency, rather than volunteering information it could otherwise withhold.

AS 8001:2008, at page 20, goes further than the general transparency presumption and specifically recommends that organisations communicate their Fraud and Corruption Control Plan to external stakeholders, not merely to internal staff. This recommendation reflects a view that a fraud and corruption control plan kept entirely internal loses much of its deterrent value, since potential external wrongdoers, including corrupt contractors or clients seeking to exploit discretionary decisions, remain unaware that the organisation has structured, active countermeasures in place.

2 The declining external detection rate

The guide cites two successive KPMG surveys to make a specific empirical argument about the limits of relying on external parties to detect fraud. The KPMG Australia/New Zealand Fraud and Misconduct Survey (2010) found that around 25 per cent of the largest reported frauds in the survey sample were detected by external parties, such as customers, members of the public, or business partners, rather than by the organisation's own internal mechanisms. By the time of KPMG Forensic's 2013 survey, that figure had fallen to around 10 per cent.

The guide uses this decline to argue against complacency: an organisation cannot assume that external parties will continue to serve as a reliable fraud detection channel at the same rate observed in earlier years. Instead, the falling external detection rate is presented as a reason to invest more heavily in strong internal detection mechanisms, of the kind described in Internal Controls Against Corruption, while still maintaining an active external awareness program to capture the detection value that external parties can still provide. The two are treated as complementary rather than substitutable: internal controls catch what insiders can see, while a well-informed external audience catches what only clients, contractors, or the public are positioned to observe, such as a regulator who appears unusually favourable to a particular company or a contractor who is asked for an informal payment.

3 Communication plan structure

The guide recommends that a client and community awareness effort be organised as a formal communication plan with defined elements. Objectives state what the program is intended to achieve, for example increasing the reporting rate of suspected corrupt conduct by contractors, or raising general public confidence that complaints will be taken seriously. Audience segments the external stakeholder base, distinguishing, for example, between contractors bidding for the agency's work, clients receiving a regulated service, and the general public. Key messages set out the specific content to be communicated to each audience segment, tailored to what that audience needs to know and is able to act on. Methods specify the channels through which the messages will be delivered. Budget allocates the resources needed to execute the plan credibly, recognising that an under-resourced awareness effort tends to produce token, ineffective outputs. Evaluation establishes how the organisation will know whether the program achieved its objectives, closing the loop back to the stated goals.

4 Techniques

Several concrete techniques recur across agencies implementing this component. Publishing the organisation's code of conduct on its public website makes the standard directly accessible to anyone dealing with the agency, reinforcing the standards discussed in Public Sector Codes of Conduct. Annual reports frequently include a dedicated section on fraud and corruption control activity and outcomes, satisfying both the transparency expectations of the Right to Information Act and specific reporting obligations elsewhere in Queensland's integrity legislation. Procurement documentation commonly incorporates explicit ethics clauses, requiring bidders and contractors to acknowledge and comply with the agency's anti-corruption standards as a condition of contract. Related to this, "claw-back" provisions in contracts allow the agency to recover funds already paid where it is later established that a contract was procured through corrupt conduct, giving the awareness message a concrete enforcement consequence rather than a purely aspirational one. Finally, complaints hotlines, whether agency-specific or run through a central body, give external parties a low-friction channel to report concerns, complementing the internal whistleblower protections that apply to staff.

5 Common pitfalls

The guide identifies several recurring failure modes in client and community awareness programs. A narrow definition of "awareness," limited to simply publishing a code of conduct online without any active promotion or audience-specific tailoring, tends to produce a program that exists on paper but achieves little practical change in external detection behaviour. A lack of strategic thinking, where awareness activity is undertaken opportunistically rather than through the structured communication plan described above, produces inconsistent messaging and makes evaluation impossible. Under-resourcing, treating the awareness function as a residual activity funded only with whatever budget remains after other framework components are funded, signals to both staff and external stakeholders that the organisation does not regard external awareness as a serious priority, undermining the credibility of the broader Fraud and Corruption Control Framework.

See also: Fraud and Corruption Control Framework, Whistleblowers and Disclosers, Pathways to Corruption Detection.

References

1. Crime and Corruption Commission (Queensland), Fraud and Corruption Control: Best Practice Guide, March 2018, ISBN 978-1-876986-86-5.
2. Right to Information Act 2009 (Qld).
3. Standards Australia, AS 8001:2008 Fraud and Corruption Control, p. 20.
4. KPMG, Fraud and Misconduct Survey, Australia and New Zealand, 2010.
5. KPMG Forensic, Fraud and Misconduct Survey, 2013.