The challenge
Serious allegations concerning workplace conduct and performance management required an independent investigation capable of testing complex claims against legislative, policy and organisational requirements.
An Australian federal government agency engaged OCM to conduct an independent investigation into a Public Interest Disclosure (PID) alleging systemic misuse of performance management processes, bullying and maladministration. The concerns centred on whether workplace performance practices were being applied inconsistently with policy and whether those practices constituted disclosable conduct under the relevant legislative framework.
The agency required an objective and defensible assessment of the allegations within a sensitive workplace environment. This involved examining complex interactions between legislation, enterprise agreements, workplace policies and organisational practices, while ensuring procedural fairness and maintaining independence throughout the investigation.
How we helped
A structured, evidence-led investigation combined policy analysis, documentary review and procedural fairness principles to assess the allegations against the requirements of the Public Interest Disclosure framework.
OCM’s team established a clear scope and methodology aligned with the terms of reference and relevant public sector investigation standards. This included reviewing applicable legislation, enterprise agreements, workplace policies and historical guidance to understand the requirements governing performance management practices.
A detailed examination of disclosure materials, correspondence, organisational records and information relating to previous complaints and investigations was undertaken. We also engaged with the discloser and considered additional evidence provided during the investigation, carefully testing the allegations against contemporaneous records and the relevant legislative and policy frameworks.
Procedural fairness remained central throughout the process. Relevant matters were put to the appropriate parties for response, and the evidence was assessed objectively and in context. This structured approach enabled us to deliver clear, defensible findings and practical recommendations to support stronger organisational oversight.
Results that matter
A rigorous assessment of the evidence provided the agency with confidence in its governance arrangements while identifying opportunities for continuous improvement.
The investigation found that none of the allegations of disclosable conduct were substantiated. No breach of Commonwealth law relating to performance management practices was identified, allegations of maladministration were not substantiated within the meaning of the Public Interest Disclosure framework, and the investigation did not establish the existence of an unreasonable health and safety risk arising from workplace conduct.
We delivered a final report that provided a clear and transparent assessment of the evidence, supported by detailed legislative and policy analysis, documented findings and practical recommendations. In addition to addressing the specific allegations, the review identified an opportunity to strengthen oversight and monitoring of performance development agreements to support consistent implementation of updated policy requirements across the organisation.
As a result, the agency received independent assurance regarding compliance with its legislative and policy obligations while gaining valuable insights to support the continued maturity of its performance management and governance practices. OCM’s work provided a robust foundation for future decision-making and reinforced confidence in the organisation’s approach to accountability, integrity and workplace management.
Rob Critchlow
