Item 14.4 - Attachment 1

12 Month Implementation Progress Report

Investigation into corrupt conduct associated with the regulation of brothels in Parramatta

Corruption Prevention Recommendations

12 month progress report

Please update this schedule with information about the status of each item as at September 2008. Include details of the latest action/update in respect of each initiative, dates where relevant and attach copies of any documents referred to, where possible, in support of implementation of particular initiatives. Should certain systems or structures no longer exist because of restructuring or other event, please indicate how these functions are currently being performed. Please provide the name of a contact person in your agency from whom we can seek more detail if needed. Please return this document to the ICAC in writing and electronically to msland@icac.nsw.gov.au by no later than 28 November 2008.

RECOMMENDATION	STATUS (implemented, not implemented)	DATE OF IMPLEMENTATION (or projected date if available)	VARIATION/COMMENT (include reference documents if appropriate)
Recommendation 1 It is recommended that the Minister for Planning and the Attorney General commission a review of the corruption risks attached to the regulation of brothels by local councils, and develop an appropriate strategy to deal with those risks.	Taskforce formed		Initial information provided to Task-Force members in October 2008
Recommendation 2 It is recommended that the Minister for Planning and the Attorney General consider adopting a system to prevent unsuitable persons operating brothels.	Taskforce formed		Initial information provided to Task-Force members in October 2008
Recommendation 3 It is recommended that the Minister for Planning and Attorney General introduce legislation to require sex industry advertisements to show the relevant development approval number. If the business does not require consent, the advertisement should be required to show an exemption number issued by the local council.	Taskforce formed		Initial information provided to Task-Force members in October 2008
Recommendation 4 It is recommended that Parramatta City Council implements a system of active staff and performance management in the compliance area.	Implemented	September 2007	Service Manager and Team Leader were recruited and implemented a more formal approach to management control over inspection activities. Team meetings are held every two weeks with independent challenge member (previously Legal Support) and Strategic Analyst. A monthly review of brothel advertisements is provided to the Strategic Analyst for further analysis and possible action. Enhanced standard operating procedures have been implemented covering: o Legislative and regulatory enforcement; o Management of evidence; o Corruption prevention in field activities; o Court proceedings and utility orders; and o Occupational Health and Safety. A tactical, team-based approach to brothel and related inspections has been implemented along with a regular inspection regime for all such premises. Performance standards have been established for non-compliance timeframes. A monthly Executive level meeting to oversight brothel compliance matters. Active networks and liaison have been established with external agencies including the Police and ATO. Further improvements are being developed and implemented as issues are identified and as part of the re-structure.
Recommendation 5 It is recommended that designated senior staff of Parramatta City Council regularly review closed matters and the information made available to them by the review and audit program recommended in Recommendation 12, and take action if this information suggests the possibility of corrupt conduct. Protocols regarding responsibilities and appropriate actions need to be developed.	Implemented and subject to variation by re-structure	August 2007	Prior to the structural changes in Outcomes and Development in September 2008, all closed matters were reviewed on a monthly basis by the Manager Development Services Unit. This role will be undertaken by the soon to be appointed Manager, Regulatory Services. Protocols will be updated accordingly.
Recommendation 6 It is recommended that the duties of the strategic analyst, crime and corruption prevention at Parramatta City Council include ascertaining the training needs of team members, service managers and senior managers; and procuring and/or developing relevant training programs.	Implemented	September 2007	Relevant responsibilities included in duty statement for Strategic Analyst. Initial training for compliance staff developed and conducted by Strategic Analyst.
Recommendation 7 It is recommended that Parramatta City Council provide initial and ongoing training tailored to the needs of team members and managers, targeted at recognising and reducing corruption risks.	Implemented and ongoing	September 2007	All compliance officers currently undertaking Certificate 4 Regulatory Course; Strategic Analyst has provided training to compliance officers in: o Powers and inspections process arising from introduction of the Brothels Legislation Amendment Act 2007; o Responsibilities under ICAC Act 1988; o Updated procedures relating to gathering and management of evidence, court procedures and specific corruption resistance strategies in field activities. Relevant Team Leaders and Managers attended ICAC Workshop on Corruption Prevention for Managers.
Recommendation 8 It is recommended that senior managers at Parramatta City Council undertake specialised training in risk management and methods for early detection of corrupt conduct..	In progress	December 2008	A series of workshops have been programmed for all managers covering corruption prevention, detection and risk management. The workshops will be facilitated by the ICAC and an external provider.
Recommendation 9 It is recommended that Parramatta City Council institute a program of rotation of the position of Team Leader, Compliance Services.	Partly implemented	September 2007	The Team Leader Compliance position was regraded to enable a greater capacity for rotation in the Unit. Rotation during periods of leave is being implemented. The skill sets across the Compliance and Regulatory teams are sufficiently different as to make a more permanent arrangement difficult to implement. The use of a team approach to all Brothel compliance inspections combined with management and peer reviews act as a compensating controls in this situation.
Recommendation 10 It is recommended that the service matter owner of CRMs concerning brothels should be the Service Manager, Compliance Services, rather than the Team Leader. It is also recommended that the Customer Relationship Management system be upgraded so that this does not remove from the Team Leader the ability to allocate tasks to inspectors in the team.	Partly implemented and subject to variation in re-structure	September 2007	Current business process covered by procedure allocates all relevant Service Requests to the Service Manager as the owner who allocates tasks to the Team Leader. Service Manager is responsible for reviewing action and closing Service Request. Business rules and procedures have been developed as the CRM system is not capable of building in the level of cross-approval processes required in this use. A review of procedures in re-structure is looking at further independent review of Service Request actions by the Service Manager being reviewed by a separate Service Manager.
Recommendation 11 It is recommended that the Customer Relationship Management system be upgraded to support the protocol that if an officer undertakes an inspection, he or she cannot close a CRM.	Partly implemented	September 2007	Currently covered by business rule and procedures as discussed above.
Recommendation 12 It is recommended that Parramatta City Council develops a rigorous review and audit system for the compliance function and that a high-level manager oversees that process.	Implemented and subject to variation in re-structure	September 2007 November 2008	Prior to the structural changes in Outcomes and Development in September 2008, all closed matters were reviewed on a monthly basis by the Manager Development Services Unit. This role will be undertaken by the soon to be appointed Manager, Regulatory Services. Protocols will be updated accordingly. Additionally, an inter-Council peer review and audit process has been negotiated with Bankstown and Ryde Councils with the first audit commenced in November 2008
Recommendation 13 It is recommended that Parramatta City Council introduces a system of fact checking of statements entered into the Customer Relationship Management system by the Compliance Team.	Implemented	September 2007 November 2008	Fact checking is currently undertaken on a sample basis by the Service Manager or Team Leader prior to closing a Service Request in line with the business rule and procedure. Part of the inter-Council peer review and audit identified above includes fact-checking on a sample basis. Total fact-checking on other than a sample basis is considered to be of less value given the volatile nature of the industry and the ability to totally reconstruct events some weeks after inspection or enforcement action.