National Integrity Spotlight – April 2025

In the first quarterly edition of the National Integrity Spotlight for 2025, we consider the latest update to the Corruptions Perception Index, legislative updates on whistleblowing and electoral reform,, and the findings of the Parliamentary Joint Committee on the NACC. We also consider updates from the NACC and state-based integrity organisations, as well as a number of recent activities by the Australian Federal Police.

Corruption Perceptions Index

On 11 February 2025, Transparency International released its 2024 Corruption Perceptions Index (CPI).

The CPI ranks 180 countries and territories by their perceived levels of public sector corruption according to experts and businesspeople. The CPI scores are based on a scale of 0 and 100, with 0 being very corrupt and 100 being very clean.

Australia is ranked 10th with a CPI score of 77, which is a moderate improvement from 2024, where Australia was ranked 14th with a score of 75.

One of the key challenges highlighted in the 2024 report is the direct impact of corruption on climate action, including:

• embezzlement and misuse of climate funds that intended to assist countries cut greenhouse gas emissions;
• undue influence on climate policies and decision making; and
• weak environmental protections (i.e. undermining the enforcement of environmental laws and policies).

Whistleblower Protection Authority Bill 2025 (No 2)

On 11 February 2025, Senators David Pocock and Jacqui Lambie introduced the Whistleblower Protection Authority Bill 2025 (No. 2) (the WPA Bill) for the establishment of the Whistleblower Protection Authority (the WPA). The WPA would, among other functions, receive and facilitate investigations of whistleblower disclosures and any mistreatment of whistleblowers, as well as providing advice, assistance, guidance and support to persons and agencies relating to whistleblower disclosures.

On 13 February 2025, the Senate referred the WPA Bill to the Legal and Constitutional Affairs Legislation Committee for its consideration. Submissions on the WPA Bill can be made to the Committee until 30 June 2025, ahead of its report by 29 August 2025.

Electoral Legislation Amendment (Electoral Reform) Act 2025

On 20 February 2025, the Electoral Legislation Amendment (Electoral Reform) Act 2025 (Electoral Reform Act) received royal assent. The Electoral Reform Act amends the Commonwealth Electoral Act 1918 and the Referendum (Machinery Provisions) Act 1984 to make a number of changes to the Commonwealth funding and disclosure scheme and to streamline and modernise administrative processes to support the AEC’s delivery of electoral events.

Key amendments include:

• definition of ‘gift’ – amending and clarifying the definition of a ‘gift’. For example, this now includes contributions to fundraising events, or fees paid to attend events, and uncharged interest on a loan. There are also defined amounts and services that are not considered a ‘gift’;
• disclosure threshold – lowering the disclosure threshold for gifts to $5,000 (subject to indexation);
• third party threshold – including a new concept of ‘third party threshold’ ($20,000), to reduce any reporting burden that the new, lower disclosure threshold has on individuals and smaller spending organisations that are incurring smaller amounts of electoral expenditure;
• expedited donation disclosure – a new requirement that gifts for a ‘federal purpose’ (i.e. political donations) valued over the disclosure threshold must be disclosed in ‘real-time’;
• gift caps – establishes an annual cap on political donations, an ‘overall gift cap’ and a ‘State and Territory gift cap’ which will limit the total value of gifts for a federal purpose an individual donor can make to certain persons or entities over a calendar year. The annual gift cap, overall gift cap and State and Territory gift cap operate concurrently. These caps reset after a general election; and
• electoral expenditure cap – political entities and other ‘capped expenditure entities’ must not incur electoral expenditure above specified caps each calendar year. The caps apply to electoral expenditure generally, and also to electoral expenditure targeted to particular Divisions, States or Territories (for Senate elections). Separate expenditure caps also apply for each by-election and Senate-only election.

The above operation of funding and disclosure reforms commence on 1 July 2026, while the electoral process amendments will be in place for the 2025 Federal Election.

Parliamentary Joint Committee on the NACC

On 27 March 2025, the Parliamentary Joint Committee on the National Anti-Corruption Commission (the Committee) released its reports following its examination of the Annual Reports of the NACC, and the NACC Inspector, and public hearings held on 22 November 2024.

Examination of the NACC

At the public hearing, Mr Paul Brereton, NACC Commissioner, advised the Committee that outcomes would best be demonstrated through investigations being conducted and publication of final reports, noting that “corruption investigations take time and it will take time for some of the investigations we’re conducting to produce results and show the value of the work we are doing.”

Mr Brereton also highlighted the education and engagement work of the NACC, noting that it had contributed to “elevating the importance of anti-corruption and integrity issues and the attention it is getting and the attention that officials all around the country are playing to.”

The Committee questioned Mr Brereton as to whether the NACC had considered commencing any public inquiries, as permitted by section 161 of the National Anti-Corruption Commission Act 2022 (Cth) (the NACC Act). While Mr Brereton indicated that the NACC’s current priority is first addressing the wave of referrals received since the NACC commenced operation, he also indicated that recurrent themes that may be appropriate for public inquiries included risks and vulnerabilities associated with the National Disability Insurance Scheme and the vulnerabilities and corruption risks associated with the employment of contractors in labour hire firms, as well as in grant schemes.

The Committee indicated that “the number of initial and continuing referrals show a healthy level of confidence” in the NACC, and that the work being undertaken is “complex” and would “take time to show results.” The Committee also highlighted the level of public reporting provided by the NACC, including the weekly updates, and that this demonstrated a significant level of transparency.

Examination of the NACC Inspector

The NACC Inspector, Ms Gail Furness SC, indicated in her first annual report that more than 1,300 contacts were received, 1,164 being specific complaints about the NACC’s decision to not investigate Robodebt referrals. This was reflected in the NACC Inspector’s inquiry into the NACC’s decision, and the report published on 30 October 2024.

Ms Furness indicated at the public hearing that a trend in complaints received by the NACC Inspector “were about the intake and triage process,” and highlighted that the nature of complaints received is likely to change over time.

One issue highlighted by Ms Furness was that section 184(1)(j) of the NACC Act provides that the NACC Inspector has the function of receiving public interest disclosures, and to deal with those disclosures as appropriate, but that this is not reflected in the NACC Inspector being named as an ‘agency’ under the Public Interest Disclosure Act 2013 (Cth). The Committee noted that this issue is currently under consideration by the Attorney-General, and is expected to be resolved by the next reporting period.

The committee concluded that, the NACC Inspector’s inquiry and investigation into the Robodebt decision in particular demonstrated that the processes set out in the NACC Act as it relates to the Inspector are effective.

National Anti-corruption Commission

NACC referral update

The NACC continues to provide regular updates on its operations. From 1 July 2024 to 23 March 2025, the NACC:

• received 1,676 referrals; and
• excluded 1,277 referrals at triage stage.

As at 26 March 2025, the NACC:

• is conducting 32 preliminary investigations;
• is conducting 33 corruption investigations, which includes nine joint investigations with other agencies;
• is overseeing or monitoring 15 investigations being undertaken by other agencies;
• has seven matters currently before the courts; and
• has 591 referrals pending assessment.

On 19 March 2025, the NACC also provided an update on its key activities and operational undertakings for its 20-month anniversary. Key insights included:

• almost 90% of referrals received by the NACC since inception (constituting 4,117) have been assessed;
• 58 preliminary investigations have been commenced to determine whether a referral raised a corruption issue for investigation, with 22 of the preliminary investigations concluded with no corruption issues arising. Two have progressed to corruption investigations and 34 preliminary investigations remain on foot;
• 37 corruption investigations have been commenced, including 12 joint investigations, with five matters finalised;
• of the NACC’s 32 current investigations, the top three themes that the investigations relate to, or involve, are senior officials (15 matters), procurement (14 matters) and former or current parliamentarians (eight matters);
• from commencement to 31 January 2025, the NACC has issued 283 directions or notices to produce documents or information, conducted hearings in seven investigations involving 32 witnesses. It has also issued 41 search warrants, 22 telephone interception warrants, 17 surveillance device warrants, and conducted one controlled operation; and
• 211 corruption prevention and education sessions have been delivered to public officials and civil society, and made 18 submissions to various consultations and reviews. The NACC has also undertaken 63 engagements with a range of international counterparts.

Outcome of Commonwealth Integrity Survey

On 9 December 2024, the NACC released the results of its inaugural Commonwealth Integrity Survey. More than 58,000 responses from 171 Commonwealth public sector agencies were received by the NACC, with the responses allowing the NACC to better understand the nature, risk and perception of integrity and corruption in the public service.

Key findings of the survey were overall positive, including that:

• 96% of respondents were confident they could identify corruption in their area of responsibility;
• 79% of respondents had faith in the integrity of their agency;
• 88% of respondents indicated willingness to report corruption if they had direct access to specific details;
• 64% of respondents who were aware of corrupt conduct took some action in response to the most recent incident of corrupt conduct in their agency of which they were aware; and
• 64% of respondents considered that their colleagues would be supportive of those who reported corrupt conduct.

The Survey also found some areas of concern, such as 15% of respondents indicating that they had specific knowledge of corrupt conduct within their agency, and 24% stating that they had witnessed four or more separate incidents of corrupt conduct, with insufficient evidence and fear of reprisal amongst the main barriers to the reporting of corrupt conduct.

Further sentencing in Operation Barker

On 10 December 2024, the NACC released a statement that Mr John Zeitoune has been sentenced to two years and 10 months imprisonment for aiding and abetting a bribe to a former ATO employee. This conviction follows Mr Zeitoune’s August 2024 guilty plea for aiding and abetting a bribe of a Commonwealth public official, contrary to sections 141.1(1) and 11.2(2) of the Criminal Code (Cth).

Mr Zeitoune’s sentence follows the two previous convictions in Operation Barker, previously covered in the August 2024 and March 2024 editions of the National Integrity Spotlight.

Robodebt Investigation

On 18 February 2025, the NACC announced that it will investigate six referrals received from the Royal Commission into the Robodebt Scheme, following the independent review undertaken by Mr Geoffrey Nettle AC KC. Mr Nettle’s review followed a review undertaken by the NACC Inspector. The NACC had initially declined not to investigate the matter further on the basis that it was deemed that it would be unlikely that there would be realistic prospects of obtaining new evidence, given the work already being undertaken by the Royal Commission.

The purpose of the investigation is to determine where or not any of the referred persons engaged in corrupt conduct.

The NACC Commissioner, Mr Paul Brereton, and Deputy Commissioners that were involved in the original decision, will not participate in the investigation in order to ensure an impartial and fair investigation takes place.

Zoe Daniel referral

On 20 February 2025, the NACC announced that it considered a referral about Ms Zoe Daniel MP, and that no corruption issue had arisen with respect to the referral. The NACC’s statement follows publication of the referral in the media in October 2024.

The referral, which was received on 1 October 2024, alleged that a former staff member of Ms Daniel’s office had lobbied a journalist at the Australian Financial Review on behalf of a donor, suggesting that Commonwealth resources may have been misused.

Through the course of its investigation, the NACC found that:

• the staff member ceased employment as a member of parliamentary staff in Ms Daniel’s office on 5 August 2024;
• the former staff member was employed by Ms Daniel’s private not-for-profit company as a temporary part-time consultant at the time they approached the AFR on 12 August 2024; and
• the AFR was not approached at the request of, or with the knowledge or authority of Ms Daniel’s, but in the former staff member’s capacity as a consultant to a third party that was not connected with Ms Daniels.

The NACC concluded that no corruption arose and would not take further action in relation to the referral.

Open letter on corruption risks in context of election

On 7 March 2025, the NACC Commissioner Mr Paul Brereton issued an open letter to prospective election participants to draw attention to various corruption risks and vulnerabilities that arise in the context of an election.

The letter states that, while some corruption risks arising in the course of elections are particularly obvious, such as the misuse of public resources, other risks “are more nuanced, such as the making of public sector appointments.”

The letter addresses various risks inherent in the election process, including:

• the use of parliamentary resources and staff (for example, parliamentarians must be prepared to publicly justify their use of resources and must act ethically and in good faith in using and accounting for them);
• the misuse of information (for example, using contact information held by agencies of grantees, suppliers, and stakeholders in order to distribute political messaging);
• public sector appointments (for example, an appointment that involves an abuse of office, or is made predominantly for an improper purpose, may be corrupt conduct);
• grants (for example, any grants made during a caretaker period should be done with care to ensure they are not targeted to electors or electorates for predominantly private or partisan purposes);
• government advertising, and ensuring that advertising undertaken by the Australian Government is free from political content and relevant to government responsibilities, as opposed to political purposes; and
• donations and other gifts (for example, candidates and political participants should avoid creating actual or implied reciprocal obligations to donors through the election process).

The NACC also indicated that it considers that it is inappropriate for a referral to the NACC to be announced as collateral or for political purposes. Specifically, Mr Brereton stated that it would use its power to make public statements in the public interest to make comment on referrals and investigations to avoid unfair reputational damage “if referrals to the Commission are weaponised in this way.”

Victoria Independent Broad-based Anti-Corruption Commission (IBAC)

Corruption and misconduct allegations dashboard

In December 2024, the IBAC launched its corruption and misconduct allegation dashboard. This dashboard allows people to view and search information relating to corruption and misconduct allegations across the Victorian public sector. The initial tranche of data uploaded to the dashboard incorporates de-identified allegations received by the IBAC between 1 July 2018 and 31 December 2023. The IBAC has emphasised that the data only reflects reported or suspected corrupt conduct, rather than conduct that has been substantiated, and that data is not available for public organisations with fewer than 50 employees in order to protect anonymity.

The bulk of the alleged corrupt behaviour and misconduct reported related to inaction, being failures to properly investigate, follow policies, take sufficient or appropriate action or failure to provide adequate care or supervision, followed by breaches of professional boundaries including rudeness, bullying and harassment, discrimination, exceeding delegated powers, improper searches or inappropriate relationships with a vulnerable person.

Interestingly, in terms of outcomes, more than half of the total 29,710 complaints were dismissed (63.5%). Only 0.8% were investigated and 32.1% were referred to another agency.

Focused Police Complaints Pilot Report released

On 20 December 2024, the IBAC released a summary report on its Focused Police Complaints Pilot program.

The Focused Police Complaints Pilot (Pilot) established a dedicated team to assess and investigate single incident complaints about the conduct of Victorian Police personnel from communities most at risk of being exposed to police misconduct, including:

• Aboriginal and Torres Strait Islander peoples;
• people with disability;
• people who identify as LGBTIQA+;
• people from culturally and linguistically diverse backgrounds;
• people aged under 25 years;
• people with mental illness, where their mental illness is linked to their engagement with police; and
• people who have a reasonable fear of their safety.

The Pilot, which ran from October 2023 to April 2024, with an internal evaluation completed in June 2024, was developed with the aim of improving the experience for complainants approaching the IBAC, including addressing:

• timeliness of the IBAC’s complaints assessment, investigation and outcome notifications;
• trialling better ways to identify focus community complainants; and
• increasing transparency and the complainants’ understanding of the outcomes of complaints.

Through the course of the Pilot, 94 complaints and notifications were assessed by the team, with the following themes of police misconduct risks and vulnerabilities identified:

• the use of force to the throat and neck;
• high-risk geographical areas;
• issues arising in relation to the authorisation and processes of searching people;
• poor communication and engagement by police officers;
• usage of body worn cameras; and
• the knowledge of police officers of their powers, including where police officers exercised their powers with limited knowledge about what they were permitted to do.

Western Australia Corruption and Crime Commission (WA CCC)

Overview of Serious Misconduct Quarterly Report

The WA CCC has released its Overview of Serious Misconduct for the  2024/25 Quarter Two. The overview provides insight into the number of notifications received, the number of allegations assessed, and the outcomes of allegation assessments for the WA Government Sector and the WA Police.

Key observations from the three month period ending 31 December 2024 included:

• 739 reports and notifications were received;
• 43% of notifications came from the public, while 33% came from the WA Police, and 20% came from the WA government sector. The remaining 4% was received from Public Sector Referrals and Federal/other agencies;
• 378 allegations of serious misconduct were assessed about WA government sector entities, and 573 allegations of alleged minor and serious misconduct were made against WA Police;
• 79 outcomes of alleged serious misconduct were recorded in the government sector, of which 70% were sustained; and
• unlawful use of computer and timesheet fraud constituted the most common categories of sustained allegations in the government sector, consistent with previous quarters.

Tasmania Integrity Commission (TIC)

Triannual Report released

On 18 March 2025, the TIC published its Triannual Report (No 2) of 2024-25 covering the period from 1 November 2024 to 28 February 2025.

Key observations of the relevant period include:

• 59 complaints alleging public sector misconduct made, 15 of which related to the Tasmanian Police;
• the median time for which a complaint was triaged was nine working days;
• of the total complaints received, 30 were dismissed at the triage stage of the process, primarily due to a lack of substance or credibility;
• 24 complaints referencing the Tasmanian State Service were closed, meaning the complaints were assessed, investigated, or the subject of an integrity tribunal;
• 27 notifications and seven information reports about possible misconduct were registered,
• 11 assessments into whether a complaint should be investigated were commenced in the relevant period, with a total of six assessments completed and dismissed;
• five investigations were completed (three of which were ‘own-motion’ investigations) and a further two were commenced;
• of the investigations completed, two were referred, three have a Board decision pending, and two included a Board recommendation.

ACT Integrity Commission (AIC)

On 17 January 2025, the AIC released its investigation report in Operation Falcon, which was an investigation into allegations that a corrections officer from the Alexander Maconochie Centre (AMC):

1. did not conduct mandatory observations of a detainee who required hourly observations during a 24-hour period (owing to a medical condition); and
2. falsified observation records to show that such observations were conducted on an hourly basis.

The investigation also concerned the conduct of the AMC General Manager (General Manager) overseeing the Corrections Officer, with respect to the General Manager’s allegedly improper responses and actions to concerns raised by an Indigenous Official Visitor Corrections (Official Visitor).

In the report, the AIC made adverse findings against both the corrections officer and the General Manager, but did not make a finding of corrupt conduct against either.

Key observations included:

1. The Corrections Officer – although the failure to perform the hourly observations and the falsifying of entries were serious and intentional acts, they did not meet the threshold of “serious corrupt conduct” under the Integrity Commission Act 2018 (ACT) (IC Act). Contributing factors included the lack of evidence to show a reoccurring pattern of misconduct, the lower level of responsibility arising from the corrections officer’s subordinate role, and the possibility that personal circumstances affected the corrections officer’s actions.
2. The General Manager – while the General Manager did fail to take action in response to the corrections officer’s non-compliance duty and misled the Official Visitor, there was insufficient evidence to establish dishonesty or a breach of public trust in either of those actions.

Although findings of corrupt conduct could not be substantiated, Operation Falcon shows the importance of adhering to policies and procedures, the need for managers to take action in response to non-compliance and the critical role of official visitors.

Operation Juno report released

On 18 March 2025, the AIC released its investigation report in Operation Juno, which was an investigation into the conduct of Mr Walter Sofronoff KC in his role as head of the ACT Board of Inquiry into the Criminal Justice System (the Board of Inquiry) which, among other matters, considered the trial of Bruce Lehrmann. The AIC’s investigation into Mr Sofronoff was previously considered in the April 2024 edition of the National Integrity Spotlight.

The investigation followed a mandatory corruption notification made on the basis that Mr Sofronoff had engaged in serious corrupt conduct by:

• delivering a copy of the Board of Inquiry’s report to two journalists before it had been made public; and
• disclosing information to and communicating with members of the media through the course of the relevant inquiry.

The AIC was required to consider whether the disclosures breached the requirements of the Inquiries Act 1991 (ACT) (Inquiries Act), or other rules or principles governing the Board of Inquiry to arise to corrupt conduct under the IC Act.

Mr Sofronoff claimed that his conduct was compliant with the requirements of the Inquiries Act and that any disclosures he made were in the public interest to ensure that the media were appropriately and adequately informed about the matters under investigation by the Board of Inquiry.

The AIC, however, concluded that Mr Sofronoff had not acted in good faith and that his conduct amounted to corrupt conduct within the meaning of the IC Act, and that this conduct undermined the integrity of the Board of Inquiry’s processes.

Northern Territory Independent Commissioner Against Corruption (NT ICAC)

General report on activities released

On 23 January 2025, the NT ICAC released its January 2025 General Report, providing an update on the work of the NT ICAC, a number of prevention and engagement activities undertaken, and an overview of Operation Hurricane.

In the period of 1 July 2024 to 20 January 2025:

• 147 allegations of improper conduct were received;
• 185 assessments of allegations of improper conduct were completed, including 38 allegations received prior to 1 July 2024;
• 34 allegations were referred to referral entities, with reports awaited for 20 allegations;
• five reports were finalised from referral entities;
• 38 engagement and training activities were undertaken, with 1,172 participants across a range of public bodies;
• five investigations were completed, with another seven currently in progress; and
• of the 66 recommendations arising from finalised investigations that were being monitored for implementation at 1 July 2024, seven have been implemented and closed.

The report also provided an update on the progress of Operation Hurricane, a review commenced in November 2023 that focused on the practices, policies, and procedures of the Northern Territory Department of Health in the recruitment of positions. The review considered 11 recruitment and selection processes and considered adherence to legislation, employment instructions for recruitment, delegations, and the management of conflicts of interest. The final report was provided to the Department of Health on 21 November 2024, including four best practice recommendations that focused on conflicts of interest, qualifications, training on merit selection, and job descriptions.

Operation Tasman

On 18 February 2025, the NT ICAC published its report in Operation Tasman, following its investigation into the “misuse of leave entitlements by a senior public officer.” Operation Tasman ultimately found that the officer the subject of the investigation had engaged in corrupt conduct.

The investigation, which commenced on 31 May 2022, was commenced following the review of emails by the NT ICAC in the course of another investigation. The allegations were categorised as consisting of:

• at least nine instances where the public officer was absent from work but had not submitted an application for leave through the applicable system; and
• at least six instances where the public officer had submitted an application through the applicable system for personal leave without a medical certificate, and documentary records showed that the leave entitlement was used for a purpose inconsistent with the conditions of their employment (i.e. recreational or annual leave would have been more appropriate).

While the public officer indicated that, in at least some instances, the failure to appropriately apply for leave entitlements was due to errors in the system, or taking ‘mental health days’, no explanation could be provided for instances where there had been “pre-planning, sometimes days or weeks in advance, of fishing trips and long weekends interstate, and then on the day representing he was unwell and that he would not be in the office.”

The report sets out four recommendations to the Office of the Commissioner for Public Employment, and the relevant public body, including that reviews be undertaken to ensure consistency of when personal leave could be taken without a medical certificate.

Queensland Crime and Corruption Commission (Qld CCC)

Updates from the Qld CCC are covered in depth in the Gadens monthly Queensland Corruption and Integrity Update publication. The most recent edition is accessible here.

Australian Federal Police (AFP) updates

The AFP continue to be active in the integrity space. Recent examples of activity undertaken by the AFP include an investigation into a cyber scam and an investigation into money laundering.

Cyber scam

In April 2024, the cybercrime platform known as LabHost was brought down as a result of an international police takedown. The AFP-led Joint Policing Cyber Criminal Coordination Centre was involved in this international effort.

LabHost was a website that provided technology to enact phishing scams. The website in question provided the tools to fraudulently replicate over 170 reputable websites.

As part of the takedown, a Melbourne man was charged. The man obtained the personal data, including birth dates and contact information, of 11 victims via a phishing scam and stole $34,990 from two of his victims. In March 2025,the man plead guilty and was ordered to pay $34,990 in compensation, sentenced to 200 hours of community service, and three months’ imprisonment served as a good behaviour order in the community.

$1.1 million seized at Perth Airport

On 20 February 2025, the AFP charged a New South Wales man with one count of engaging in “conduct in relation to money, worth $1,000,000 or more, that is proceeds of general crime, contrary to section 400.3(2A) of the Criminal Code (Cth).” The man was charged after the AFP seized roughly $1.1 million from a suitcase left at Perth Airport.

On 17 February 2025, the man abandoned his suitcase at Perth Airport, at which time the AFP was alerted. Officers opened the bag after it was detected by suspicious by a trained dog. On 19 February 2025, officers executed a search warrant at the man’s home in Sydney and seized electronic devices and items of clothing for forensic examination.

The AFP is still in the process of investigating him in relation to how he obtained the cash but believe that the interstate investigation had successfully disrupted significant money laundering activities.

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Authored by:
Cinzia Donald, Partner, Perth (Lavan)
Kelly Griffiths, Partner
Daniel Maroske, Partner
Mitchell Wright, Partner
Phoebe Brosnan, Special Counsel
Anna Fanelli, Senior Associate
Kasia Jaruzelska, Senior Associate
Stephanie Brown, Senior Associate
Oskar Henderson, Lawyer
Caitlin Holmes, Lawyer
Jacinta Beecher, Lawyer
Freya Surma-Litchfield, Solicitor (Lavan)
Jonathan Kumar, Paralegal
Ray Huang, Lawyer