Public interest disclosure policy

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    PURPOSE

    This policy establishes the underlying principles and obligations of the Board of Professional Engineers of Queensland (Board – the organisation) concerning public interest disclosures (PIDs) under the Public Interest Disclosure Act 2010(PID Act). This policy has been developed in accordance with the PID Act and the Public Interest Disclosure Standards issued by the Queensland Ombudsman (PID Standards) which require agencies to have reasonable procedures to deal with PIDs.

    This policy forms part of the Board’s approach to integrity management and should be read in conjunction with the Public Interest Disclosure Procedure, Board Integrity and internal controls framework, the Code of Conduct for the Queensland Public Service and the relevant policies and procedures outlined in Attachment 1.

    This policy has been approved by the Board and is consistent with the following:

    This policy applies to all Board members and employees working for the Board (both Board appointed employees and public servants) regardless of whether they are permanent, fixed term temporary, full-time, part-time, or casual employees and/or on secondment from another department.

    It also applies to other persons who perform work for the Board including contractors, students gaining work experience and volunteers. For the purposes of this policy, the term contractor includes on-hired temporary labour services (agency staff).

    This policy applies to employees in all of their work-related dealings with each other and with customers, contacts or clients including while:

    • in the workplace or when working off site
    • at work-related functions (including social functions and celebrations)
    • on work-related travel
    • attending conferences.

    The key terms in this policy are defined in Attachment 3.

    LEADERSHIP / POLICY STATEMENT

    The Board’s commitment

    The Board (the organisation) is committed to fostering an ethical, transparent culture. In pursuit of this, the Board values the disclosure of information about suspected wrongdoing in the public sector so that it can be properly assessed and, if necessary, appropriately investigated.

    The Board is committed to:

    • implementing awareness initiatives and internal control systems to prevent and/or minimise corrupt conduct
    • promoting public confidence in the way suspected corrupt conduct is dealt with
    • promoting accountability, integrity and transparency in the way the Board deals with a complaint that is suspected to involve, or may involve Board members or employees
    • promoting the public interest by facilitating complaints of corrupt conduct and PIDs which relate to the Board
    • ensuring that allegations of suspected corrupt conduct and PIDs, including those made anonymously, are properly assessed and appropriately dealt with
    • ensuring that appropriate consideration is given to the interests of employees who are the subject of a complaint or PID
    • taking appropriate action on proven corrupt conduct and wrongdoing by employees, suppliers, providers and other external parties, and
    • affording support and protection from reprisals to people making PIDs.

    The Board will ensure disclosers are supported and protected from reprisal action for making a PID and that appropriate consideration is given to persons who are the subject of a PID.

    What is a PID?

    Under the PID Act, any person, including an employee, can make a disclosure about a:

    • substantial and specific danger to the health or safety of a person with a disability
    • the commission of an offence, or contravention of a condition imposed under a provision of legislation mentioned in Schedule 2 of the PID Act, if the offence or contravention would be a substantial and specific danger to the environment
    • reprisal because of a belief that a person has made or intends to make a disclosure.

    Employees can make a disclosure about the following public interest matters:

    • corrupt conduct
    • maladministration that adversely affects a person’s interests in a substantial and specific way
    • a substantial misuse of public resources
    • a substantial and specific danger to public health or safety
    • substantial and specific danger to the environment.

    A person or employee who makes a disclosure under the PID Act are generally referred to as ‘disclosers’ under this policy.

    Reporting suspected corrupt conduct and PIDs

    All Board members and persons working for and with the Board must report suspected corrupt conduct. This applies even where the suspected corrupt conduct relates to someone working in, or who has worked outside the Board (for example, someone working in another agency or a government department or local council).

    The Board expects its suppliers, providers and other external parties to report suspected corrupt conduct.

    Disclosers are encouraged to report PIDs directly to the Principal Legal Officer as the Board’s PID coordinator.

    Disclosers can, however, report PIDs externally to another proper authority, either as a first step of if they are unhappy with the Board’s initial response.

    Disclosures can be made in any way, including anonymously, either verbally or in writing. Disclosers are, however, encouraged to give their contact details so the Board can contact them to provide support, obtain any further information and provide outcome advice.

    The Board is committed to taking appropriate action on disclosures (subject to sufficient information being provided).

    Complaints about the public official

    The CC Act requires a unit of public administration to have a policy that addresses how it will deal with a complaint that involves, or may involve, corrupt conduct of a public official.

    The Registrar is the public official of the Board of Professional Engineers of Queensland (the Board). Refer to the Complaints about the public official policy (Policy ID 1.25) for the details on this matter.

    PROTECTION FROM REPRISAL

    Making a PID about suspected wrongdoing is the right thing to do. Disclosers should not suffer harm or detriment because they have spoken up, or someone believes they may have spoken up. This type of action is called reprisal and is an offence under the PID Act.

    The Board will protect persons who make a PID, or are involved in a PID investigation, from reprisal.

    When a disclosure is made, the Board will assess the risks to the discloser and offer support.

    Allegations of reprisal are taken very seriously and will be assessed and appropriate action taken, which may include referral to the Crime and Corruption Commission and/or the Queensland Police Service.

    RESPONSIBILITIES

    Key roles and responsibilities are as follows:

    The Board, Chair and Registrar are responsible for:

    • communicating the expectation that all Board members and persons working for and with the Board are required to conduct their duties to high professional and ethical standards
    • the Board’s compliance with the PID Act and delegating responsibilities under the PID Act as considered appropriate, including:
      • receiving and assessing PIDs
      • establishing reasonable procedures to deal with PIDs
      • keeping a record of disclosures
      • reviewing the Board’s decisions not to investigate or deal with PIDs on request
      • providing disclosure information to the Office of the Queensland Ombudsman
    • leading a workplace culture that encourages, supports and raises awareness about disclosures and the appropriate management of PIDs
    • ensuring that the Board develops, implements and maintains a PID management program
    • appointing a PID Coordinator of the Board with responsibility for the implementation of the Board’s PID management program, including acting as the principal point of contact with the Office of the Queensland Ombudsman
    • ensuring all new employees and agency staff complete an induction process, including the completion of mandatory training in relation to public sector ethics and the Code of Conduct for the Queensland Public Service.

    The PID Coordinator – Principal Legal Officer is the principal contact for PID issues at the Board and is responsible for:

    • coordinating of the Board’s PID processes, including a PID management program
    • reporting to the Office of the Queensland Ombudsman
    • assessing disclosures, recording, reporting and managing PIDs in accordance with the PID Act, the PID Standards and the PID Procedure
    • undertaking and managing investigations of PIDs and any allegations of reprisal
    • allocating an investigator and support officer to PID matters (if applicable)
    • monitoring the investigation (if applicable) and resolution of PIDs and managing support and protection of disclosers
    • maintaining appropriate records in relation to PID matters
    • providing advice about PID matters
    • maintaining the relevant Board policies, procedures and completing associated reporting.
    • maintaining a workplace culture that values professionalism, integrity and diligence and upholds the Queensland Government values and Board principles
    • immediately referring suspected wrongdoing including any breaches of this policy to the Principal Legal Officer
    • raising awareness with staff about PIDs and encouraging the reporting of wrongdoing
    • responding to a reported PID in accordance with this policy and the PID procedure
    • ensuring all new employees and agency staff complete an induction process, including the completion of mandatory training in relation to public sector ethics and the Code of Conduct for the Queensland Public Service
    • in response to a PID and in consultation with the Principal Legal Officer:
      • providing support to the discloser
      • monitoring for reprisal
      • maintaining appropriate confidentiality
      • keeping appropriate records
    • ensuring that PIDs are properly investigated and appropriate action is taken with respect to any wrongdoing which is the subject of a PID
    • assisting employees to resolve ethical dilemmas, as required.
    • immediately reporting suspected wrongdoing including any breaches of this policy to the Principal Legal Officer. For further information on how to make a PID, refer to the PID Procedure
    • conducting their duties and work activities to a high professional and ethical standard
    • seeking appropriate management guidance if they have an ethical dilemma
    • cooperating fully with investigations into suspected corrupt conduct and PIDs
    • maintaining confidentiality in relation to a PIDs
    • refraining from taking reprisal action in relation to a PID

    Managers are responsible for:

    • maintaining a workplace culture that values professionalism, integrity and diligence and upholds the Queensland Government values and Board principles
    • immediately referring suspected wrongdoing including any breaches of this policy to the Principal Legal Officer
    • raising awareness with staff about PIDs and encouraging the reporting of wrongdoing
    • responding to a reported PID in accordance with this policy and the PID procedure
    • ensuring all new employees and agency staff complete an induction process, including the completion of mandatory training in relation to public sector ethics and the Code of Conduct for the Queensland Public Service
    • in response to a PID and in consultation with the Principal Legal Officer:
      • providing support to the discloser
      • monitoring for reprisal
      • maintaining appropriate confidentiality
      • keeping appropriate records
    • ensuring that PIDs are properly investigated and appropriate action is taken with respect to any wrongdoing which is the subject of a PID
    • assisting employees to resolve ethical dilemmas, as required.

    All Employees and persons who perform work for the Board are responsible for:

    • immediately reporting suspected wrongdoing including any breaches of this policy to the Principal Legal Officer. For further information on how to make a PID, refer to the PID Procedure
    • conducting their duties and work activities to a high professional and ethical standard
    • seeking appropriate management guidance if they have an ethical dilemma
    • cooperating fully with investigations into suspected corrupt conduct and PIDs
    • maintaining confidentiality in relation to a PIDs
    • refraining from taking reprisal action in relation to a PID

    undertaking mandatory public sector ethics training provided by the Board, including training in relation to the Code of Conduct for the Queensland Public Service.

    REPORTING REQUIREMENTS

    The Registrar will provide a report to the Board, as required.

    HUMAN RIGHTS

    Decision makers must act and make decisions in a way that is compatible with human rights and give proper consideration to a human right relevant to a decision, as required by s 58 of the Human Rights Act. For further information please refer to the Board’s Human Rights intranet page.

    The policy has been reviewed for compatibility with human rights under the Human Rights Act.

    The policy has been found to limit human rights only to the extent that is lawful, reasonable, and demonstrably justifiable in accordance with section 13 of the Human Rights Act, therefore, it is reasonable to conclude that the policy is compatible with human rights.

    APPROVAL

    This policy was approved by the Board on 2 April 2025.

    Minor revisions were approved by the Registrar on 30 June 2025 and approved by the Board on 16 July 2025.

    ATTACHMENT 1: CONTACT

    The Principal Legal Officer is the first point of contact for any questions regarding this policy.

    ATTACHMENT 2: REFERENCES

    The requirements set out in this document are based on, and are consistent with relevant Government legislation, regulations, directives, information standards and/or policies at the time of publication.

    Any reference to legislation, policy or other document is taken to be a reference to that legislation, policy or other document as amended or replaced from time to time.

    Legislation and regulations

    Board policies, procedures and guidelines

    • Conflict of Interest Policy (Policy ID 1.02)
    • Employee Complaints Policy (Policy ID 1.07)
    • Fraud and Corruption Prevention Policy (Policy ID 1.10)
    • Complaints about the public official policy (Policy ID 1.25)
    • Customer Complaints Management Policy (Policy ID 2.06)
    • Corrupt Conduct Prevention Procedure
    • Public Interest Disclosure Procedure
    • Board Integrity and internal controls framework.

    Queensland government guidance documents

    • Public Interest Disclosure Standard No. 1/2019 – Public Interest Disclosure Management Program
    • Public Interest Disclosure Standard No. 2/2019 – Assessing, Investigating and Dealing with Public Interest Disclosures
    • Public Interest Disclosure Standard No. 3/2019 – Public Interest Disclosure Data Recording and Reporting
    • Making a public interest disclosure – a guide for individuals working in the public sector 2011 (publication jointly prepared by the Queensland Ombudsman, the former Crime and Misconduct Commission and the Public Service Commission)
    • Handling a public interest disclosure – a guide for public sector managers and supervisors 2011 (publication jointly prepared by the Queensland Ombudsman, the former Crime and Misconduct Commission and the Public Service Commission)
    • Disclosure Fact sheet 1: What is a disclosure
    • Disclosure Fact sheet 2: Checklist for making a disclosure
    • Disclosure Fact sheet 3: Discloser information and support