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ANAO Report No.10 2014–15 Administration of the Biodiversity Fund Program
53
of interest.
74
The ANAO examined the department’s probity planning, the role of
the probity adviser in the competitive grant assessment and selection processes,
and the steps taken by Environment to manage potential and actual conflicts
of interest.
Probity planning
3.32 While
Environment did not develop a specific probity plan for the Biodiversity
Fund program, each round’s grant assessment plan included a section
describing probity principles
75
that would underpin the administration of
the program. Procedures to support these probity principles were included in
the grant assessment plans for each round.
3.33 Environment
also engaged a legal services firm to provide probity advice
on the Biodiversity Fund program, with the role of the probity adviser described
in the grant assessment plans for each round.
Probity adviser
3.34 The
probity adviser played an active role throughout the four
competitive merit‐based grant assessment rounds.
76
In particular, the adviser:
provided
input to the development of guidelines, application forms, grant
assessment plans and assessment criteria and other supporting materials,
such as training for assessors;
74 These issues are further examined in ANAO Audit Report No. 47 2013–14 Managing Conflicts of
Interest in FMA Agencies, June 2014. 75
These five probity principles were:
program participants will manage and administer a fully defensible assessment process and recommendations to the Minister will be made with the primary objective of achieving an
efficient, effective, economical and ethical use of Commonwealth resources;
any potential or actual conflict of interest will be declared by a program participant, and steps to mitigate any potential risks arising will be developed and implemented as soon as practically
possible;
appropriate standards of confidentiality and security will be maintained by program participants;
all program participants will meet their legal obligations and at all times act with integrity; and
all applicants or potential applicants will be treated fairly and consistently, and no applicant will be given any unfair advantage or disadvantage by program participants.
76 The documentation retained by Environment does not indicate that the probity adviser provided advice
in relation to the selection and recommendation for funding of four discretionary grants awarded under the program the selection of discretionary grants is discussed in Chapter 5.
ANAO Report No.10 2014–15 Administration of the Biodiversity Fund Program
54
provided
advice on requests for extensions for submitting applications, and
on other matters, such as procedures for distributing applications to
assessors;
provided advice in Round 1 on the design and implementation of the
‘normalisation’ process which is described in Chapter 4 at
paragraph 4.14;
attended
all meetings of the Normalisation Panels and Moderation Groups,
and provided advice where requested; and
prepared a probity report that provided an overview of the processes
undertaken for each round and the probity adviser’s certification that
these processes were defensible from a probity perspective.
3.35 Given
the complex grant assessment and selection process that was implemented
for the Biodiversity Fund program, including the involvement of a
Moderation Group discussed further in Chapter 4, having an independent probity
adviser in each funding round helped to provide the department with additional
assurance regarding the equity, accountability and transparency of the
assessment and selection processes.
Management of conflicts of interest
Grant assessors
3.36 Environment
sought the involvement of external or ‘community’ assessors
in the grant assessment process for each funding round because of their
broad community and local knowledge, as well as their technical or scientific
understanding of the complex issues involved in natural resource management.
A risk in this approach was that assessors may have professional andor
personal relationships with applicants that they are required to assess particularly
as Environment intended to allocate applications to external assessors
from their regions to draw on their local experience.
3.37 Environment
sought to manage these risks by providing appropriate training
and documented guidance to assessors in relation to conflicts of interest.
The department also put in place the following procedures, which were
outlined in the grant assessment plans for each round:
a requirement for assessors to make a conflict of interest declaration
before commencing the assessment process;
