Hawkesbury residents are being encouraged to have their say on a new draft Fraud and Corruption Control Policy designed to strengthen transparency, accountability and integrity across Hawkesbury City Council.
The draft policy has been prepared following recommendations from the Independent Commission Against Corruption (ICAC), which called on all NSW councils to review and strengthen their corruption prevention systems after its investigation into the former City of Botany Bay Council under Operation Ricco.
Council says the policy is intended to support the prevention, detection, deterrence and investigation of fraud and corruption while protecting public resources, information and property.
The draft document also aims to safeguard Council's reputation and ensure clear accountability for the implementation of fraud and corruption controls across the organisation.
According to the Council, the policy forms part of a broader governance framework and complements existing measures including the Code of Conduct, Public Interest Disclosure Policy, the Public Interest Disclosures Act 2022 and the Independent Commission Against Corruption Act 1988.
Fraud and corruption risks are also managed through Council's Risk Management Policy and Risk Management Plan.
At its meeting on 12 May 2026, Hawkesbury City Council resolved to place the draft policy on public exhibition for 28 days to allow residents and stakeholders the opportunity to review the document and provide feedback before it is formally adopted.
The move comes at a time when public confidence in local government governance and accountability remains a significant issue across New South Wales, with councils increasingly expected to demonstrate robust systems for identifying and managing corruption risks.
Council says the policy reflects its commitment to maintaining high standards of ethical conduct and ensuring public resources are used appropriately and transparently.
ANALYSIS OF POLICY ON EXHIBITION
Council's existing policy establishes that fraud and corruption are unacceptable and assigns responsibility, but it lacks many of the operational controls expected in a mature fraud and corruption control framework.
1. No Fraud Control Plan
The biggest omission is that the policy does not contain or require a detailed Fraud and Corruption Control Plan. ICAC guidance generally expects identified fraud risks, risk ratings, treatment strategies, responsible officers, implementation timeframes and monitoring arrangements.
Instead, the policy merely states that a Fraud Control Action Plan will exist. It does not specify its content or require public reporting. This creates a situation where Council can technically comply with the policy while doing very little in practice.
2. Excessive Reliance on the General Manager
The current policy Clause 5.5(d) gives the General Manager ultimate responsibility for fraud and corruption risk management and mandatory reporting.
This presents a governance risk because many serious corruption allegations in local government involve senior management, the General Manager controls information flows, staff may fear retaliation and independent oversight is limited.
While complaints against the General Manager are redirected to the Mayor or Administrator, there is no independent mechanism for allegations involving executive staff generally.
A stronger policy would require direct reporting pathways to ICAC, direct access to the Audit Risk and Improvement Committee, and independent external investigation triggers.
3. No Mandatory Reporting Timeframes
The policy says fraud and corruption will be reported. It does not say how quickly, by whom and under what threshold?
There are no requirements such as reporting suspected corrupt conduct within 24 hours, notify ICAC immediately upon reasonable suspicion, quarterly reporting to ARIC. Without timeframes, accountability becomes difficult.
4. Weak Whistleblower Protections
The policy refers to the Public Interest Disclosures Act and Internal Reporting Policy. However, it does not itself guarantee protection from reprisal, anonymity options, support services and monitoring of retaliation.
For a council with significant internal governance concerns, this is a major omission.
5. No Public Transparency Requirements
There is no requirement to publish fraud statistics, corruption complaints received, investigations completed, disciplinary actions and lessons learned.
The public therefore has no way of assessing whether the policy is working. Many modern public-sector frameworks include annual fraud reporting.
6. No Specific Controls for Planning and Development
The policy identifies planning and development assessment as a major corruption risk. However, it does not require declaration of conflicts, independent peer review, audit of planning decisions, developer contact registers and lobbying registers.
Given that planning corruption is one of the highest corruption risks in NSW local government, this omission is notable.
7. No Specific Controls for Procurement
Procurement is identified as a risk area. Yet the policy contains no mandatory controls such as segregation of duties, supplier due diligence, conflict declarations, tender evaluation independence and contractor integrity checks.
These are standard fraud prevention measures.
8. No Councillor-Specific Measures
Councillors are included in the scope. But the policy contains no provisions dealing with misuse of position, lobbying, influence over staff, confidential information leaks and development matters.
These are common corruption risks in local government.
9. No Investigation Framework
The policy refers to investigation but never explains who investigates, independence requirements, evidence standards, referral thresholds and reporting obligations.
This is a significant gap.
10. No Performance Measures
There are no measurable indicators such as percentage of staff trained, number of audits completed, risk assessments completed on time, and implementation of recommendations.
Without performance indicators, the Council cannot demonstrate effectiveness.
Specific Governance Concern
One clause deserves particular scrutiny. The policy states that records relating to reports and investigations will be treated as subject to Council's access to information and privacy policies.
While this sounds reasonable, it could create tension between transparency, confidentiality, protection of whistleblowers and public accountability.
A stronger policy would explicitly state how corruption investigations are handled under GIPA legislation and what information can or cannot be disclosed.
Overall Assessment of Council policy on exhibition
The policy is essentially it is strong on principles, moderate on governance and weak on implementation, transparency and independent oversight
For a council facing heightened community concern about governance and accountability, a stronger policy would include mandatory reporting pathways, public transparency measures, independent investigation triggers, councillor-specific controls, procurement controls, planning controls, and measurable performance standards.
The Bottom Line
The lessons from major NSW corruption investigations, including ICAC's Operation Ricco, are clear. Fraud and corruption policies cannot simply be documents sitting on a shelf. They must be supported by strong controls, independent oversight, transparent reporting and a culture of accountability.
Submissions close at the end of business on 22 June 2026
