“Why would a council procurement officer order 400 kilometres of construction fencing when only 20 kilometres were required? A clumsy data entry error, or something more sinister? 

Most of us think of procurement corruption as something that happens in high-stakes, big-ticket purchases, like massive construction projects, fleet acquisitions, or multimillion-dollar infrastructure deals where the financial incentives are enormous. These cases grab headlines and spark outrage, but they represent only part of the problem. In reality, low-value procurement (purchases that fall under thresholds for formal tender requirements) is rife with opportunities for misconduct. 

The NSW ICAC highlighted this issue, noting:

"The problem is that while the total value may not be significant for the agency, or in state-wide terms, the corrupt funds to be obtained remain significant for perpetrators. In fact, because low-value items are often frequent purchases, their value can add up over time…"

Items like office supplies, maintenance tools, or, as in the fencing example, construction materials, may be ordered repeatedly without triggering red flags. Staff with end-to-end control can manipulate orders, accept kickbacks, or collude with suppliers, all while the organisation's finance department and audit teams remain oblivious.

Ahead of GovProcure 2026, Quest Events interviewed Dr Benjamin Marx, Principal Officer Corruption Prevention at the NSW Independent Commission Against Corruption, and Lorna Elisei, Contract Management Specialist, Finance, Planning and Projects at Victoria Legal Aid, to discuss how to reinforce integrity and build public trust in government procurement.

What practical behaviours can procurement professionals adopt to reinforce integrity in their everyday decisions?

Procurement professionals share a responsibility to uphold transparency, fairness and sound probity,” says Elisei. “This includes openly sharing information when appropriate, treating all suppliers equitably, actively supporting supplier diversity, and promptly identifying and managing conflicts of interest.”

Elisei notes that Integrity is further reinforced through clear policies, practical guidelines, and targeted training that help staff recognise fraudulent or corrupt behaviour and understand their responsibilities.

Marx shared a short list of behaviours that reinforce procurement integrity:

• Ensuring that procurement-related associations are accurately declared and assessed, and that identified conflicts of interest are appropriately managed.

• Conducting supplier due diligence and ensuring that any identified red flags are appropriately actioned.

• Documenting procurement decisions and the reasons for them, especially when unusual approaches are being taken.

• Enforcing integrity-based contract clauses, such as those related to audit rights or ethical requirements.
  

Marx notes, however, that in many public authorities, procurements are often done by non-procurement professionals. “Procurement professionals, therefore, also need to ensure that these steps are taken in procurement processes in which no procurement professionals are involved.”

What lessons can we learn from recent cases of misconduct in procurement, and how can these be applied to prevent similar issues in the future?

There are several important lessons to be learned from recent investigations by the NSW Independent Commission Against Corruption, says Marx. 

Firstly, poorly designed procurement success criteria can perversely incentivise behaviours that create corruption risk. 

If an agency has decentralised procurement, procurement practitioners cannot assume that individuals conducting or managing procurements have adequate procurement knowledge. 

Poor price estimation creates corruption risk by creating surplus funds that can be misappropriated. Similarly, poor market knowledge creates corruption risk because it can be used to prevent a genuine competitive process from taking place.

Marx points out that basic supplier due diligence, such as comparing internal records to results from company and director searches, can prevent some procurement corruption schemes from occurring. 

In Queensland, a December 2025 CCC investigation found that representatives of a medical device company allegedly made secret payments to QLD Health officials in return for the use of the medical devices in public hospitals. 

Cases of this sort highlight systemic weaknesses in procurement controls, says Elisei. “These incidents reinforce the need for stronger governance, more robust internal checks, and proactive risk management to prevent misconduct and protect public trust in government contracting.” 

How can we evaluate the effectiveness and fit-for-purpose of our governance frameworks?

Governance frameworks must be “live” to be effective, says Elisei, rather than being treated as a set-and-forget exercise. “They remain effective when they are regularly reviewed, updated, and aligned with organisational strategy. This might include incorporating audit findings, reassessing roles and responsibilities, and ensuring policies remain relevant as the organisation evolves. Flexibility and responsiveness to industry changes are essential to maintaining a fit-for-purpose governance model.”

Marx says that the best way to evaluate the fit-for-purpose of frameworks is to ‘test them.” 
“The same principles embedded within governance frameworks can be used to assess them,” he says. “You need to determine what outcomes your governance frameworks are trying to achieve and what key risks threaten these outcomes. You can then develop mechanisms to determine the extent to which these outcomes have been achieved, and risks realised.”

Marx adds that these mechanisms need to be different from those already in the governance framework. Units like Risk and Internal Audit should be able to provide guidance on potential mechanisms that are suited to your context.

Do you believe AI has the potential to improve ethics and governance in public procurement, or do you think it could have a negative effect? 

What strategies can we implement to rebuild trust after an ethical/governance breach in procurement?

The dust has settled, and disciplinary action has been taken. What next? 

Reinforce that ignorance of procurement rules is no excuse for a breach. Elisei recommends targeted training to strengthen awareness of fraud, corruption risks, and probity expectations. “Regular refresher programs can help reinforce this knowledge. Managers should also be equipped to identify warning signs of misconduct, ensure conflicts of interest are properly managed, and increase oversight of third-party providers.” 

Elisei adds that strong record-keeping and transparent governance processes further discourage unethical behaviour and help restore confidence.

Marx observes that rebuilding trust after an ethical or governance breach can be challenging, but several things can help.

It begins with the way you address the issue with the team. 

“Where possible, tell staff that you are disappointed or angry that the breach happened and that it doesn’t reflect your organisation’s values and standards. Let them know you will work to ensure that it doesn’t happen again, and that you know that the vast majority of staff have integrity. Take appropriate action against those who acted improperly and, where possible, tell staff that this has happened.”

The next step is to enhance compromised systems and processes, and link improvements back to the breach. Finally, be sure to thank reporters and others who assisted in uncovering the breach.”

Continue the conversation at GovProcure 2026

Join Dr Benjamin Marx, Lorna Elisei and a host of other thought leaders at GovProcure 2026, 10th-12th March 2026, Sydney.