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Public Interest
Disclosures Policy
Policy Owner
Financial Services
Record no.
22/299256
Approved by:
EMT
Approval date:
9 February 2022
Endorsed by:
Audit and Risk Committee Date endorsed:
27 May 2022
Adopted by:
Council
Adoption date:
23 June 2022
Version
E
Last review date:
Adopted 10/12/2019
Next review date: December 2023
Prepared by
Riana Brims, Strategic Risk and Assurance Officer
Related document/s
Fraud and Corruption Control Framework; Fraud Prevention Policy; Fraud
Reporting and Investigation Procedure; Public Interest Disclosures Procedure.

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Public Interest Disclosures Policy
Page 2 of 8
1. Purpose
Brimbank City Council (Council) is a public body under the
Public Interest Disclosures Act
2012
(PID Act). The purpose of the PID Act is to encourage and facilitate the making of
disclosures of improper conduct by public officers and public bodies, including Council as
an organisation, Council officers, Councillors, providers and volunteers, and to ensure
disclosures are properly assessed and investigated.
Council’s Public Interest Disclosures Policy (PID Policy) establishes Council's commitment
to maintaining integrity and ensuring its compliance with the PID Act.
2. Policy Statement
Council is committed to the purpose and objectives of the PID Act and recognises the
value of disclosers coming forward to report improper conduct or detrimental action.
Council officers, Councillors, providers and volunteers, must act with integrity at all
times and should never engage in fraud, corruption, improper conduct or detrimental
action.
Council recognises the value of transparency and accountability in its administrative and
management practices, and supports the making of disclosures that reveal improper
conduct. Council will not tolerate the taking of reprisals or detrimental action against
those who come forward to disclose improper conduct.
3. Integrity Framework
In addition to this Policy, Council has developed a:
Fraud and Corruption Control Framework (FCCF) describing Council’s fraud
management approach.
Fraud Reporting and Investigation Procedure (FRIP) to guide Council officers in
the process for reporting and conducting an internal investigation when an
incident of suspected fraud or corruption is detected.
Public Interest Disclosures Policy (PID Policy) establishing Council’s commitment
to maintaining its integrity, supporting anyone disclosing information about
improper conduct or detrimental action, and ensuring its compliance with the Act.
Public Interest Disclosures Procedure (PID Procedure) setting out how Council will
encourage and facilitate the making of disclosures, provide protecting and
support for disclosers and witnesses, and ensure confidentiality and appropriate
reporting of disclosures.
This Policy is complementary to and is to be read in conjunction with the above suite of
documents, and is intrinsically linked to Council’s other key ethical guidance policies and
procedures as outlined in the following diagram.

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Public Interest Disclosures Policy
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4. Roles, Responsibilities and Accountabilities
Personnel
Accountabilities and responsibilities
Principal Officer
(Chief Executive Officer)
Ensures Council carries out its responsibilities under the PID Act
Appoints a Public Interest Disclosures Coordinator
Mandatory reporting to IBAC of suspected fraud and misconduct
Reports confirmed instances of fraud or corruption to the Audit and Risk
Committee
Determines actions and mitigation for suspected and confirmed fraud or
corruption, including reporting an incident to Victoria Police
Directors and Managers
A Director/Manager who is informed of an instance of suspected fraud
or corruption is required to notify the Public Interest Disclosures
Coordinator (Manager Governance) for assessment.
[If the Public Interest Disclosures Coordinator assesses the matter is not
a public interest disclosure, and refers it back to the Director/Manager,
the Director/Manager is then responsible for notification reporting to
the Chief Executive Officer, and any subsequent investigation of the
incident, and implementation of actions, as determined by the Chief
Executive Officer (or delegate).]
Staff and Volunteers
Reports suspected fraud or corruption to their direct
supervisor/manager/director, or Public Interest Disclosures Coordinator
or a Public Interest Disclosures Officer.
Fraud Control Officer
(Manager Finance)
Coordinates Council’s fraud and corruption resources, in accordance
with the Fraud and Corruption Control Framework.
Maintains the fraud and corruption register (including monitoring
appropriate mitigation measures to be implemented).
Public Interest Disclosures
Coordinator (Manager
Governance)
Ensures the Public Interest Disclosures Policy and Procedure are
complied with when handling public interest disclosures.
When informed of an instance of suspected fraud or corruption is
required to assess the information and determine if it is an assessable
disclosure in accordance with the PID Act, and Council's PID Policy and
PID Procedure.
Public Interest Disclosures
Officers (and Coordinator)
Handles reports of fraud and corruption by a discloser.
Investigating Officer
Director or Manager, or appropriate external investigator, appointed by
the Chief Executive Officer in writing is responsible for investigating
suspected fraud or corruption that is not a public interest disclosure.

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Public Interest Disclosures Policy
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Reporting Officer or Source
Council officer who suspects or detects the fraud or corruption, or the
'source' of the information if an external person/supplier.
If the matter is referred for internal investigation, a written confidential
Notification Report will be provided by the Reporting Officer or Source.
Full details of roles, responsibilities and accountabilities including reporting channels is
provided in the PID Procedure.
5. Public Interest Disclosure Requirements
5.1 What can a disclosure be made about?
Disclosures may be made about improper conduct on the part of Council, Council
officers, Councillors, providers and volunteers.
Disclosures may also be made about detrimental action taken (or suspected may be
taken) in reprisal against a person in connection with a disclosure made about improper
conduct.
The conduct or action being disclosed may have taken place, still be occurring, or is
believed will occur. A disclosure must be made confidentially or in private – it is not a
disclosure if it is broadcast or already publically known (for example, made in public, in
the media/ on social media etc.).
If Council’s Public Interest Disclosure Coordinator (PID Coordinator) believes a disclosure
may be a public interest disclosure made in accordance with the PID Act, they will notify
the disclosure to the IBAC for further assessment and direction.
5.2 Who can make a disclosure?
Any individual natural person (that is, not an organisation or company) may make a
disclosure under the PID Act. The individual may be a person within the organisation, or
any member of the public. Individuals may also make a joint disclosure.
Disclosures may be made verbally (in person, by phone or voicemail) or in writing
(delivering in person, by mail, email or by online form). A disclosure can also be made
anonymously by phone or email, or by face-to-face meeting where a person refuses to
identify themselves.
5.3 How to make a disclosure?
Council’s Public Interest Disclosures Procedure (PID Procedure) details making a
disclosure under the PID Act, and sets out how Council handles any disclosures it
receives. The PID Procedure details information about who can receive a disclosure, and
how to make a disclosure to Council or IBAC, and the support available to disclosers.
The PID Procedure is available on Council’s website at
www.brimbank.vic.gov.au/council/governance/fraud-prevention-and-public-interest
disclosures
If a person would like a copy sent to them, please contact Council’s Customer Support
on 9249 4000 or Council’s PID Coordinator on 9249 4947 or
confidential@brimbank.vic.gov.au
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Public Interest Disclosures Policy
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5.4 Confidentiality
Council takes its obligations under the PID Act seriously. This includes taking all
reasonable steps to protect the identity of the discloser and the matters raised by a
discloser.
Maintaining confidentiality in relation to public interest disclosure matters is crucial to
prevent reprisals, and afford natural justice and procedural fairness to all involved.
Consequently, it is a criminal offence under the PID Act to disclose information
connected with a disclosure made in accordance with the PID Act, including the identity
of the discloser. The consequences for breaching confidentiality include financial
penalties and imprisonment.
5.5 For more information
Council has appointed the Manager Governance as its PID Coordinator to receive and
initially assess any disclosures. The PID Coordinator may be contacted on 9249 4947 or
0409 421 690 or confidential@brimbank.vic.gov.au.
The PID Coordinator can be contacted for more information, to receive a disclosure, or to
arrange a confidential meeting to discuss any matters.
Disclosures relating to Council as an organisation, or Council officers, can also be made
directly to IBAC on 1300 735 135 or online at IBAC's website
https://www.ibac.vic.gov.au/reporting-corruption/report/complaints-form
Disclosures about Councillors can only be made directly to IBAC or the Victorian
Ombudsman. For more information, contact:
• IBAC or visit its website www.ibac.vic.gov.au; or
• The Victorian Ombudsman at its website https://www.ombudsman.vic.gov.au

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Public Interest Disclosures Policy
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6. Definitions and key terms used in this Policy
Assessable disclosure:
any report, complaint, concern, matter, allegation or
disclosure (however described) purported to be made
in accordance with Part 2 of the Act.
Detrimental action:
action that Council, a Councillor or a Council officer
takes against a person in reprisal for them making,
or participating in an investigation of a public interest
disclosure. Includes action causing injury, loss or
damage, intimidation, harassment, discrimination,
disadvantage or adverse treatment in relation to a
person's employment.
Improper conduct:
corrupt conduct or conduct by Council or a Council
officer that constitutes a criminal offence; serious
professional misconduct; dishonest performance of
functions; intentional or reckless breach of public
trust or misuse of information or material;
substantial mismanagement of public resources;
substantial risk to public health or safety or to the
environment; but does not include conduct that is
trivial.
Natural justice:
A principle of Common Law that says a person has
the right to be:
informed about the substance or the allegations
against them
given the opportunity to answer the allegations
before a final decision is made
informed about the substance of any adverse
comment that may be included in an investigation
report and have their defence fairly included in the
report.
Public interest disclosure:
Any complaint, concern, matter, allegation or
disclosure (however described) determined to be
made in accordance with Part 2 of the PID Act. A
public interest disclosure is one which is made by a
natural person or group of people who has
reasonable grounds for the belief that a public officer
or public body has engaged in, or intends to engage
in improper conduct in their official capacity, or
detrimental action.

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Public Interest Disclosures Policy
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Local Government Act 2020
Compliance Statement
Section 9(1) of the
Local Government Act 2020
(Act)
requires Council to give effect to
the overarching governance principles, in the performance of its role. Section 9(2) of the
Act specifies the governance principles as follows:
a) Council decisions are to be made and actions taken in accordance with the
relevant law
(Compliance with the law)
;
b) Priority is to be given to achieving the best outcomes for the municipal
community, including future generations
(Achieve best outcomes for the
community)
;
c) The economic, social and environmental sustainability of the municipal district,
including mitigation and planning for climate change risks, is to be promoted
(Promote the sustainability of the municipality)
;
d) The municipal community is to be engaged in strategic planning and strategic
decision making
(Engage the community in strategic planning and decision
making)
;
e) Innovation and continuous improvement is to be pursued
(Strive for innovation
and continuous improvement)
;
f) Collaboration with other Councils and Governments and statutory bodies is to be
sought
(Collaborate with all other levels of government and government
agencies)
;
g) The ongoing financial viability of the Council is to be ensured
(Secure the
ongoing financial viability of Council)
;
h) Regional, state and national plans and policies are to be taken into to account in
strategic planning and decision making
(Strategic planning and decision
making must take into account plans and policies in operation at all
levels)
;
i) The transparency of Council decisions, actions and information is to be ensured
(Council decisions, actions and information must be transparent).

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Public Interest Disclosures Policy
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In reviewing the Public Interest Disclosures Policy, Council has considered and
given effect to the overarching governance principles, as summarised below:
Governance Principle
Considerations
(a) Compliance with the law
Local Government Act 2020
Independent Broad-based Anti-corruption Commission
Act 2011
Public Interest Disclosures Act 2012
(b) Achieve best outcomes for the
community
The Policy enables fraud and corruption risks to be
identified, reported and managed appropriately to ensure
strategic objectives are met and best outcomes for the
community are achieved.
(c) Promote the sustainability of
the municipality
Economic, social and environmental sustainability was
considered in developing the Policy that provides Council’s
commitment to ongoing monitoring of fraud and corruption
risks and avenues for reporting fraud and corruption
incidents.
(d) Engage the community in
strategic planning and
decision making
Not applicable for the Policy.
(e) Strive for innovation and
continuous improvement
Council will review the Policy on a no less than biennial
basis, and pursue innovation and continuous improvement
during every review.
(f) Collaborate with all other
levels of government and
government agencies
Not applicable for the Policy.
(g) Secure the ongoing financial
viability of Council
The Policy:
is designed to create and protect value by targeting
effort and resources to areas of highest priority;
supports Council’s commitment to its financial
responsibility for effectively managing risks and
opportunities in all areas of operations;
supports the protection of Council assets and finances;
promotes efficient and ethical use of resources and
services.
(h) Strategic planning and
decision making must take
into account plans and policies
in operation at all levels
Not applicable for the Policy.
(i) Council decisions, actions and
information must be
transparent
This Policy supports the principle of transparency and
promotes integrity in Council decisions, actions and
information.