On 26 June 2025, the Independent Broad‑based Anti‑corruption Commission (IBAC) launched new guidance materials on eight topics specifically designed for the public sector. In the second of our two-part blog series, we provide an overview of the three remaining IBAC guides, which focus on the high-risk area of procurement.

Developed following IBAC’s 2024 Public Sector Strategic Assessment, these guides address procurement-specific corruption risks in different contexts:

• Procurement risks in major projects
• Corruption risk in procurement
• Corruption risks when engaging consultants.

These materials offer clear, actionable steps for public officers, procurement teams, and senior leaders seeking to build stronger defences against misconduct.

Why procurement remains a high-risk area

Procurement has long been recognised as a vulnerable area for corruption risk, partly because significant sums of public funds are involved. Corruption in this context undermines public confidence that taxpayer money is being spent fairly, transparently, and on merit.

IBAC reports that:

“There is a growing concern about the risk of corruption in procurement, among both public servants and business. Almost all stakeholders consulted in IBAC’s 2024 Public Sector Strategic Assessment – including leaders in the Victorian Public Service and local government – view procurement as a significant risk for their organisation. Businesses are also concerned about corruption, with the number of business suppliers to government in Victoria perceiving corruption as a problem jumping from 64 per cent in 2022 to 70 per cent in 2024, with 41 per cent viewing it as a major problem.”

Procurement risks in major projects

This guide outlines how corruption can affect large-scale public investments, especially in the early stages of planning and procurement. Situations where corruption risks may arise, include:

• Pressure to select favoured suppliers
• Conflicts of interest
• Undue influence from unions or political actors
• Inadequate due diligence on contractors
• Fraudulent invoicing and falsified timesheets
• Complex supply chains diluting oversight.

To counter this, IBAC recommends strengthening front-end controls: build clear procurement governance frameworks, establish dedicated integrity functions, conduct random inspections, and use data analytics to detect anomalies. Periodic reviews and up-skilling of project teams are also encouraged to support compliance throughout the project lifecycle. In summary, major projects require major oversight.

Corruption risk in procurement

This guide identifies risks such as non-compliant processes, poor record-keeping, and unmanaged conflicts of interest as emerging risks facing procurement. IBAC notes that misconduct may occur in high-pressure environments, often driven by tight deadlines, procedural complexity, or limited capacity, rather than premeditated intent. Additional factors include decentralised service delivery, procurement conducted on behalf of other agencies, or outsourcing to third parties where oversight may be weaker.

IBAC advocates for simplifying procurement processes, disclosing transparent decision-making, embedding regular reviews, and using data analysis to safeguard procurement integrity. It also highlights the importance of reviewing procurement systems regularly to identify weaknesses and improve controls over time.

Having transparent procurement processes and a culture of open communication will promote integrity: “Preventing procurement corruption requires vigilant oversight and clear, enforceable rules.”

Corruption risks when engaging consultants

This guide highlights a growing area of concern:

“Consultants present unique risks in terms of the influence they can exert on the public service and decision-making processes. However, when engaged appropriately, consultants can bring valuable expertise and innovative solutions that enhance the effectiveness of public sector projects.”

Consultants are often used as subject matter experts, including in procurement, and IBAC highlights the following risks:

• Misleading findings to maintain favour
• Gaining inside knowledge to win future contracts
• Undisclosed conflicts of interest.

IBAC outlines good practice for managing these risks, including limiting access to information, maintaining clear documentation, and validating consultant outputs to ensure accuracy and accountability. It is also important to consider how commercial interests may shape the advice provided by consultants, and to critically assess recommendations within the broader procurement context.

Conclusion

IBAC’s updated procurement guidance materials are timely, practical, and necessary. In a landscape where procurement is both essential and exposed, these guides can help public sector agencies move from reactive compliance to proactive integrity management.

Resources

• 2025 new guidance materials (IBAC)
• VPS Code of Conduct (VPSC)

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CourtHeath acknowledges the Traditional Aboriginal Owners of Country throughout Victoria and pays respect to Elders past and present, and to the ongoing living culture of Aboriginal people.

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IMAGE: Used under licence from shutterstock.com

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