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 Self-disclosure and reporting mechanisms

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Staff and third parties are required/supported to self-disclose real or perceived conflicts of interest, gifts, benefits, incidents or mistakes.


Some examples of this type of countermeasure include:

  • Staff are required to declare conflicts of interest.
  • Inadvertent access disclosure processes.
  • Gifts and benefits registers.
  • Requirements to update circumstances, e.g. to maintain a security clearance.

Purpose of this countermeasure

Staff or contractors can abuse their position of trust to:

  • access, manipulate or disclose sensitive information without authority, and
  • steal physical documents.

Staff and contractors can also be coerced to commit fraud for the benefit of another person or entity, e.g. coerced to provide sensitive information.

Abuse of public office or influencing a Commonwealth public official to commit fraud are offences under the Criminal Code Act 1995.

Staff and third parties failing to self-disclose real or perceived conflicts of interest, gifts, benefits, incidents or mistakes can lead to worse impacts, such as fraudulent conduct, dishonest influences or coercion.


This type of control is supported by:

How do I know if my countermeasures are effective?

You can apply the following methods to measure the effectiveness of these types of countermeasures:

  • Confirm policy and guidance material exists.
  • Confirm guidance material is available and easy to access.
  • Review guidance material to ensure it is clear and easy to understand.
  • Confirm guidance material and processes concord with legislation or policy, e.g. the PGPA Act.
  • Ask staff about the forms, processes or systems to ensure they have a consistent understanding.
  • Analyse the use of registers such as Conflict of Interest registers or Inadvertent Access registers.

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