Clients and corruption

Client relationships present a significant corruption risk.

Such relationship exist any time services are provided to a person; the existence of a client relationship is not limited to situations which involve a commercial context.

Many reports to the ICAC about corruption and unethical behaviour involve an external client of a public sector agency, such as a patient in a public hospital.

This article explores the key considerations set out by the ICAC.


Where to draw the line?

The ICAC acknowledges that “boundaries around client relationships can be blurred”. Confusion often arises when public officials are invited to attend social functions, which could be perceived as getting too close to a client.

The situation becomes even more complex when gifts and benefits are involved. Even receiving basic hospitality such as the provision of complimentary food or drinks could come under scrutiny.


Common corruption risks involving client relationships

Common corruption risks involving client relationships include:

  • A public official accepting or soliciting money or a benefit to provide favourable treatment or an unfair advantage to a client.
  • A client offering bribes to influence public officials delivering a desired service.
  • A public official deliberately failing to disclose a conflict of interest (for example, a personal relationship with a client).
  • A public official disclosing confidential information to a client.
  • A public official facilitating “queue-jumping” by a client so he or she can obtain a public service or product more easily.
  • A public official not following approval processes or exceeding delegation levels so that a client gets something more easily or something to which they were not entitled.
  • A public official abusing his or her position of trust to take unfair advantage of a client. In a recent case example, a NSW public official whose job was to organise community support services, was alleged to have fraudulently obtained over $5,000 from a client with an intellectual disability.


Managing corruption risks around client relationships

The ICAC provides advice for developing a strategy to mitigate corruption risks, which includes conducting a risk assessment and developing a strategy, ensuring diligent recordkeeping, and educating and training staff.


Risk assessment and strategy development

Client relationships should be treated as a risk to be assessed in internal audit and corruption risk management programs.

Following a risk assessment, agencies should develop a written policy and procedures for managing client relationships, which should be communicated internally and externally.

Staff who engage with clients should also be contractually required to declare conflicts of interest.



Records should be kept of clients’ applications for resources and services, and allocations of those goods and services.

If staff are invited to an event, they should keep their tickets or other records of the event.


Staff education and training

Staff who have frequent client contact should be educated about the corruption risks. Training sessions can help these staff learn how to deal with overly friendly clients, and how to politely decline a gift or explain why it is important to maintain a professional distance.


Key takeaways

Client relationships present a significant corruption risk. Agencies need to develop robust strategies for mitigating these risks and ensure that their staff have the appropriate resources to effectively implement these strategies.

Nyman Gibson Miralis provides expert advice and representation in complex corruption investigations involving the ICAC. 

Contact us if you require assistance.