Enforce Strict Board‑Approval Protocols
- Compensation arrangements, offsets or discretionary payments must be formally approved by the board in writing, before any transaction occurs.
- Verbal approvals should never substitute for proper governance processes.
- Encourage boards to maintain structured oversight even during operational disruptions (e.g. emergencies, closures).
Implement Strong Whistleblower and Reporting Protections
- Protect and promote an internal reporting pathway.
- Ensure employees know how and when to escalate concerns, including to the relevant regulator (L&GNSW, ASIC, AUSTRAC) or to the NSW Police.
Regularly Review and Refresh Governance Training
- CEOs, secretaries and directors should receive regular training on:
- financial governance
- conflicts of interest
- integrity expectations under the Registered Clubs Act
- personal accountability for authorisation of payments.
- Training should emphasise that ethical conduct must be maintained even during high‑pressure periods.
Strengthen Vendor and Third‑Party Due Diligence
- Require verification that vendor invoices match legitimate suppliers’ systems and invoice formats.
- Conduct periodic reviews of supplier relationships to detect unusual links to staff or third parties.
Conduct Periodic Forensic or Internal Audits
- Regularly test payment controls, including random sample reviews.
- Commission independent reviews where governance risks appear elevated.
