Integrity Policy and Public Interest Disclosures

Integrity Policy

Wyndham City Council's Integrity Policy brings together key integrity commitments into a single, clear framework that promotes ethical behaviour, accountability, and transparency. The Policy sets out expected standards of conduct, reporting and investigation processes, and protections for people who raise concerns.

Working alongside the management of Public Interest Disclosure and Fraud and Corruption the Policy supports Council's commitment to preventing, detecting, and responding to misconduct. It strengthens governance, improves consistency across the organisation, and reinforces our focus on integrity, conflict of interest management, human rights, fraud prevention, and ongoing education and reporting.

Public Interest Disclosures

Wyndham City Council is committed to integrity, transparency and accountability and encourages the reporting of suspected fraud, corruption, improper conduct, misuse of Council resources, abuse of power, or detrimental action against a person who raises a concern. Anyone can make a report or disclosure, including staff, contractors, volunteers, community members and anonymous individuals. Council treats all reports seriously and is committed to protecting and supporting those who speak up.

All reports and disclosures are treated confidentially and managed in accordance with the Victoria’s Public Interest Disclosures Act 2012, policies and procedures. Council assesses all matters appropriately and, where required, refers them to the Independent Broad-based Anti-Corruption Commission (IBAC) or other relevant authorities. Council has zero tolerance for fraud, corruption, improper conduct and reprisals against those who raise concerns. People who make a public interest disclosure are protected by law and will be supported throughout the reporting and assessment process.

What is improper conduct?

The definition of Improper Conduct is specified by the following categories:

  • corrupt conduct
  • criminal offence
  • serious professional misconduct
  • dishonest performance of public functions
  • intentional or reckless breach of public trust
  • intentional or reckless misuse of information
  • substantial mismanagement of public resources
  • substantial risk to health or safety of a person
  • substantial risk to the environment
  • conduct of any person that adversely affects the honest performance by a public officer of their functions
  • conduct of any person that is intended to adversely affect the effective performance by a public officer of their functions for the benefit of the other person.
What is a disclosure and in what circumstances is it protected?

A disclosure is a report made by a person or group of people about:

  • improper conduct of the Council or its officer(s); or
  • detrimental action that the Council or its officer(s) takes against a person in reprisal for making or cooperating in the investigation of a protected disclosure.

The conduct may have occurred in the past, is currently occurring or may happen in future.

It is not a disclosure if the complaint or allegation is already in the public domain.

It may be assessed by IBAC and deemed a protected disclosure if:

  • it has been made by an individual or group of people;
  • it is made verbally (in private) or in writing to a person authorised to receive a disclosure;
  • it is about conduct which has, is or will adversely affect the honest performance of the Council or it’s officer(s) official function; and
  • there is information which shows or tends to show improper conduct or detrimental action; or
  • there are reasonable grounds for the discloser to believe that there is information which shows or tends to show improper conduct or detrimental action.
How do I make a disclosure?

You can make a disclosure about suspected improper conduct by Wyndham City Council, its employees or officers by contacting one of Council's authorised Public Interest Disclosure Officers:

Alternatively, reports or disclosures can be made through the following channels:

What does the Council do when it receives a disclosure?

The Public Interest Disclosure Officer will assess disclosures received:

  • to determine whether the conduct constitutes improper conduct or detrimental action, giving consideration to how serious the consequences are; and
  • to identify the link between the conduct and the official function of the Council or it’s officer(s).

The Public Interest Disclosure Officer will determine, in consultation with IBAC as necessary, if a disclosure is required to be referred to IBAC. The Council has 28 days from the time the disclosure was made to assess the report, determine how it will be handled, report back to the discloser in writing and if required notify IBAC.

If referred to IBAC, they will conduct an assessment and communicate the result to the discloser in writing within a reasonable timeframe. If they determine it is a public interest disclosure, they can decide to either dismiss, investigate or refer the investigation to another body (such as the Ombudsman).

If not referred to IBAC, or they determine that it is not a public interest disclosure, the Public Interest Disclosure Officer will convene a meeting of Integrity and Ethics Committee, if appropriate, for a decision on handling of the disclosure. The Council may dismiss, conduct their own investigation or appoint an appropriately qualified external organisation to investigate.

What protections are provided for people who make disclosures?

Protections apply to disclosures made in line with the requirements specified in the Public Interest Disclosure Act 2012. They apply from when the disclosure is made, regardless of whether the matter is referred to IBAC, and includes the subsequent provision of any further information. These include:

  • a person is not subject to civil / criminal liability or administrative action;
  • a person is not committing an offence against any legal Act which imposes obligations of confidentiality or restrictions on information disclosure;
  • a person is not breaching any other confidentiality obligation made by oath, rule or law or practice; and
  • a person cannot be held liable for defamation in relation to information provided.

These protections do not apply if the discloser provides information knowing it to be false or misleading, or falsely claims a matter is the subject of a protected disclosure.

There are a number of confidentiality obligations related to the receipt and investigation of public interest disclosures. Loss of protections and a range of more serious penalties may be applied for the breach of these obligations.

There are also welfare obligations related to public interest disclosures. Council must provide welfare support to a discloser or witness as the circumstances require.

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