Identity crisis: The importance of identifying the correct party to a contract

The importance of identifying the correct party when entering into a contractual arrangement is paramount.

When working as a government lawyer, you can often find yourself in unusual situations, like buying chaff for horses, bullet proof vests for dogs and canned soup for prisoners.  In the context of purchasing goods from local suppliers, knowing who is responsible when the goods are faulty is essential.  Getting this wrong can create significant issues when it comes to disputes and when seeking to enforce terms of the contract.

It is easy to make mistakes and errors can arise in a number of ways:

• referring to a non-existent company;
• not referring to the correct individual or correct company; or
• referring to a business name, rather than the holder of that business name.

Sometimes it is difficult to identify the correct party - there are multiple ways to set up and manage a business and just navigating company searches can be  a challenge. Companies can trade under numerous business or trading names, but it is the holder of that business or trading name that is the legal entity for contracting purposes.

Although courts will strive to ascertain the correct contracting party by applying a test of what a reasonable person would think, it is important to know how to undertake this process correctly from the outset.  Fortunately, post-contractual communications may be of aid to a court that is asked to determine the correct contracting entity.  However, it is preferable not to have to rely on, for example, email chains with a supplier, to overcome an incorrect party name in the contract.

To avoid the risks associated with contracting with the wrong entity, it is important to:

• have a written contract or written confirmation of an oral contract , not an oral one;
• confirm the contracting entity by:
• asking the other party to provide their business details (i.e. ABN/ACN); and
• undertaking company searches on ASIC (via ASIC Connect) to verify those business details are for the correct entity, 
• if the entity uses a business name, confirm that the holder of the business name (via ASIC Connect) is the entity listed in the contract; and
• ensure that signature blocks clearly set out the capacity in which a person signs on behalf of their company, partnership or as a sole trader.

If you are unsure who you are contracting with, please seek legal advice.

Carolyn Doyle
Managing Principal Solicitor
9947 1403

Sanishya Fernando
Solicitor
9947 1439

To retain or not to retain, that is the question: PROV's new record keeping policy

 Interest in records management tends to be events driven.  Last year the release of the Privacy and Data Protection Act 2014 (PDP Act) heightened awareness of data security issues for government entities.  Then in the lead up to the 2014 State election, minds were turned to which documents should be retained, or not retained, as the case may be.  

But best-practice records management presents constant challenges in respect of both form and content of records.  Records now come in diverse forms - not only traditional paper documents and record-keeping or business systems, but also email and social media accounts and network drives, for example.  But their significance is premised on their nature and content, which in some cases can be difficult to assess. 

Additional guidance is now to hand.

New policy released

In February this year, Public Record Office Victoria (PROV) released an over-arching policy on record-keeping for the Victorian Government, pursuant to its responsibility for collecting and preserving records from all Victorian government and local governing bodies whose records are public records under the Public Records Act 1973 (PR Act).    

PROV's new 'Record Keeping Policy: Appraisal Statement for Public Records required as State Archives' (Appraisal Statement) sets out the key appraisal considerations for specifying and identifying those Victorian records that are of permanent value to the Government and people of Victoria.  

What is 'appraisal'?

Appraisal is the process by which those records that are required for preservation as State Archives are identified by Government agencies.  In PROV's words:

appraisal is a planned and documented process based on research and analysis to provide transparent, reasoned and consistent reasons for the retention or non-retention of records. It is a reasonably complex, judicious and somewhat subjective process that involves the evaluation of the continuing value of records for the government and community against the cost of retaining and keeping the records accessible in perpetuity.

PROV has divided the characteristics of records of enduring value into the following six categories:

1. The authority, establishment and structure of government;
2.  Primary functions and programs of government;
3. Enduring rights and entitlements (of individuals and groups);
4. Significant impact on individuals;
5. Environmental management and change; and
6. Significant contribution to community memory.

Some of these activities and associated records are relatively self-evident.  For example, in respect of the second category, PROV lists the State budget papers as an example of 'Records that illustrate the government's role in the management of the Victorian economy'. 

However other categories, notably the fourth, are potentially more problematic.  Here PROV's guidance is particularly useful in circumstances where appraisal decisions may affect the 'most vulnerable members of Victorian society'.  Records listed as potentially falling into category four include:

• Collections and analyses of data compiled for planning and decision making;
• Representations and appeals against the decisions/actions of government or legislature; and
• Petitions documenting significant community opposition to government actions or policies.

Records not of permanent value

But what about those records appraised as not being of permanent value? All public records must continue to be retained for as long as they're needed to meet Government's administrative needs and legislative requirements, and to support accountability and community expectations. Section 19 of the PR Act has the effect that it is unlawful to dispose of or destroy a public record other than in accordance with a Standard made under s 12.  Minimum periods are set out in the Standards, or Retention and Disposal Authorities, issued by PROV for use by Government agencies.

Retention periods and personal information

Since opinions may differ as to how an individual record should be categorised in light of the Standards, these minimum periods are not without controversy, particularly in light of the requirements of Information Privacy Principle (IPP) 4.2 of the PDP Act (and its predecessor in the Information Privacy Act 2000).  IPP 4.2 requires destruction or permanent de-identification of personal information 'if it is no longer needed for any purpose'. 

The PR Act prevails over IPP 4.2 as a result of s 6 of the PDP Act (and previously s 6 of the IP Act).  Decisions of the Victorian Civil and Administrative Tribunal have accepted that personal information retained pursuant to a requirement of the PR Act is still relevantly 'needed' for a purpose (Caripis v Victoria Police(Health and Privacy) [2012] VCAT 1472; Zeqajv Victoria Police (Human Rights) [2013] VCAT 2105). 

Agencies should therefore be aware that retention of personal information beyond the retention period specified in a relevant Standard increases their risk if a complaint is made under IPP 4.2.  Moreover, when protective data security standards are released this year under the PDP Act, agencies may need to reevaluate the cost of managing any records that they are not required to retain.

If you are in the Victorian Government and would like assistance in respect of your agency's records management or privacy obligations, contact:

Carolyn Doyle

Managing Principal Solicitor

9947 1403

Deidre Missingham

Senior Solicitor

8684 0483

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Pranking doesn't pay: when can a licensing authority inquire into criminal conduct by a licensee?

In Australian Communications and Media Authority v Today FM (Sydney) Pty Ltd, a judgment handed down on 4 March 2015, the High Court considered the circumstances in which a regulator can investigate and make findings with respect to alleged criminal conduct by a licensee. The case arose out of a now infamous incident in which Australian commercial radio personalities Mel Greig and Mike Christian telephoned nurse Jacintha Saldanha claiming to be members of the British royal family and sought information regarding the health of the Duchess of Cambridge. The prank call was recorded and broadcast on Today FM's Hot 30 Countdown program on 5 December 2012. Ms Saldanha later committed suicide.

Action by the Australian Communications and Media Authority

ACMA investigated the conduct of Greig and Christian for the purpose of determining whether action should be taken with respect to Today FM's commercial radio broadcasting licence. In a preliminary investigation report, ACMA concluded that Greig and Christian had committed a breach of the Surveillance Devices Act 2007 (NSW). ACMA therefore determined that Today FM had breached a condition imposed upon its commercial radio broadcasting licence by the Broadcasting Services Act 1992 (Cth) (the Act) that it not use its broadcasting service 'in the commission of an offence against … a law of a State'.

Court Proceedings

Today FM sought a declaration in the Federal Court that the Act does not authorise ACMA to make a finding that a licensee has committed a criminal offence. It submitted that the Act only authorises ACMA to take notice of the fact that a licensee has been convicted of an offence by a court. In the alternative, Today FM submitted that the Act breaches the separation of powers mandated by the Commonwealth Constitution by investing ACMA with judicial power.

Today FM's application was dismissed by Edmonds J. An appeal to the Full Federal Court was allowed. ACMA appealed to the High Court.

Judgment of the High Court

French CJ, Hayne, Kiefel, Bell and Keane JJ stated that 'it is not offensive to principle that an administrative body is empowered to determine whether a person has engaged in conduct that constitutes a criminal offence as a step in the decision to take disciplinary or other action.' ACMA was required to determine, to the civil standard of proof, whether criminal conduct had occurred. However, this was to be done as a step in determining whether ACMA should take administrative action in response to a breach by Today FM of its licence conditions. ACMA was not required to determine criminal guilt as a step in the infliction of punishment. According to the majority, there was nothing 'incongruous' about conferring upon a licensing authority power to determine whether a broadcasting service had been used in the commission of a criminal offence.

The majority rejected Today FM's constitutional argument in peremptory fashion, stating that 'none of the features of the power conferred on the Authority to investigate and report on breach of the … licence condition and to take consequential administrative enforcement action support the conclusion that it is engaged in the exercise of judicial power.' Gageler J delivered separate concurring reasons.

What does this case mean for decision-makers?

Administrative decision-makers are often called upon to determine whether conduct amounting to the commission of a criminal offence has taken place. Thus, for example, a Tribunal exercising functions under the Health Practitioner Regulation National Law may be called upon to determine on the balance of probabilities whether a health practitioner has engaged in professional misconduct amounting to the crime of rape or indecent assault.

The Court's decision in Today FM is a reminder that the treatment of criminal offences in the context of administrative decision-making is a wholly different matter from the conduct of criminal proceedings. Administrative decision-makers are not bound by the rules of evidence and must take into account all information that is relevant to the performance of their statutory functions. They apply standards of satisfaction as to factual matters that are fundamentally different from the standard of proof applied by criminal courts. Thus an administrative decision-maker may properly conclude that an offence has been committed even where an acquittal has been entered in respect of the offence by a criminal court. In addition to confirming the scope of ACMA's jurisdiction under the Act, Today FM provides a valuable caution against implying principles of criminal law into administrative decision-making.

Of course, Today FM is a corporation and is not entitled to the privilege against self-incrimination. The issues considered by the High Court in Commissioner of the Australian Federal Police v Zhao were therefore not relevant to this matter. It should, however, be borne in mind that in an appropriate case, an injunction may issue to restrain an administrative decision-maker from acting in circumstances where the performance of its functions may undermine an accused's right to silence.

For queries relating to any of the issues identified in this blog, please contact:

Jonathan Bayly

Principal Solicitor

jonathan.bayly@vgso.vic.gov.au

Janine Hebiton
Managing Principal Solicitor

janine.hebiton@vgso.vic.gov.au

Sporting chance for all - Equality for transgender people in sport and work

The recent media coverage of a high profile rugby union player reporting the use of derogatory slurs on-field highlights the issue of discrimination in sport.  This incident is timely as, in January, the Victorian Equal Opportunity & Human Rights Commission (VEOHRC) released a new guideline titled Transgender People and Sport.  This follows the release of the previous guideline, Transgender People at Work (updated in July 2014).

The Equal Opportunity Act 2010 (EO Act) protects transgender and intersex people from discrimination on the basis of their gender identity in a number of areas of public life.  In addition to sport and work, these include education, provision of goods and services, accommodation and clubs.

New guidelines

The two guidelines outline legal obligations under the EO Act in relation to sport and work, as well as practical information about gender identity issues, including lists of useful terms, case studies and decision-making steps.  While not legally binding, a court or tribunal may consider whether the guidelines have been complied with when hearing a discrimination complaint.

Discrimination on the basis of gender identity

The EO Act protects transgender and intersex people from both direct and indirect discrimination on the basis of their gender identity (ss 6(d) and 7).  Direct discrimination occurs when a person is treated, or proposed to be treated, unfavourably because of their gender identity (s 8(1)).  Indirect discrimination occurs when an unreasonable requirement, condition or practice is imposed, or proposed to be imposed, which has, or is likely to have, the effect of disadvantaging a person with a particular gender identity (s 9(1)).

It is also unlawful to ask a person to specify their gender identity where there is no legitimate, non-discriminatory reason for needing this information (s 107).

'Gender identity' is defined in s 4 of the EO Act as the identification by a person of one sex (or of indeterminate sex) as a member of another sex on a genuine basis.  This identification could be by:

• assuming characteristics of the other sex, whether by medical intervention, style of dressing or otherwise; or
• by the person living, or seeking to live, as a member of the other sex. 

The rights of transgender and intersex people are also protected under the Charter of Human Rights and Responsibilities Act 2006.

Transgender people and sport

This guideline is aimed at sporting organisations, clubs and staff.  It will also be useful for schools and universities.  The guideline explains that it is unlawful to discriminate against a person on the basis of their gender identity by failing to select them or excluding them from participating in sporting teams and activities, unless a relevant exception applies (s 71).  It also explains that it is against the law to discriminate against a person on the basis of their gender identity in club membership, including sporting clubs (ss 64 and 65), although it may be lawful for clubs to limit membership to a particular sex (s 68).

Transgender people at work

This guideline is aimed at all employers, and is relevant to all government departments and public entities.  VEOHRC has also produced resources for developing a transition plan for transgender employees as well as a policy template.  These documents will be useful for human resources professionals and anyone with responsibility for interviewing or recruiting new employees.

The guideline explains that it is unlawful to discriminate against job applicants and employees because they are transgender (ss 16 and 18).  The only exception is if there is a 'genuine occupational requirement' for employees to be of a particular sex (s 26).

If you are in the Victorian Government and would like further information about your responsibilities under the Equal Opportunity Act 2010, please contact:

Catherine Roberts
Managing Principal Solicitor
8684 0247
catherine.roberts@vgso.vic.gov.au

David Catanese
Principal Solicitor
9032 3040
david.catanese@vgso.vic.gov.au

Should I stay or should I go (ahead)? Staying civil proceedings when they threaten a fair trial

In the recent case of Commissioner of the Australian Federal Police v Zhao, the High Court granted a stay of civil forfeiture (asset confiscation) proceedings to protect a defendant's right to a fair trial in related criminal proceedings. The Court's decision contributes to a body of law that addresses the question how a court should respond when the conduct of civil, disciplinary or inquisitorial proceedings threatens to prejudice the fair conduct of criminal proceedings.

The facts

On 2 July 2013 Mr Xin Jing was charged with offences against the Commonwealth Criminal Code. Shortly after the charges were laid, the Commissioner of the Australian Federal Police commenced proceedings in the County Court of Victoria seeking an order that the family home of Mr Jing and his wife, Ms Qing Zhao, be forfeited under the Proceeds of Crime Act 2002 (Cth) on the grounds that the property represented proceeds of the offences with which Mr Jing was charged.
Mr Jing and Ms Zhao sought an order that the forfeiture proceedings be stayed until the charges against Mr Jing had finally been determined. They argued that defending the forfeiture proceedings would require Mr Jing either to give evidence that might be used against in him in the criminal proceedings or to divulge the details of his defence before the conclusion of the prosecution's case. Mr Jing and Ms Zhao said that to allow the forfeiture proceedings to continue would rob Mr Jing of his right to silence.
The application for a stay of the forfeiture proceedings was refused in the County Court. However, an appeal to the Court of Appeal was successful. The AFP Commissioner then appealed to the High Court.

The High Court's Decision

The High Court determined unanimously that the Commissioner's appeal should be dismissed. In reaching its decision, the Court first noted that the continuation of the forfeiture proceedings would expose Mr Jing to a risk of prejudice in his defence of the criminal proceedings. The Court then held that the interests of justice would not be served by 'requiring the second respondent to defend the forfeiture proceedings or pursue the exclusion proceedings before his criminal proceedings are finalised, especially since the Commissioner will suffer no relevant prejudice from a delay in the continuation of the forfeiture proceedings.'

Relevance of the decision

Zhao builds on a series of recent decisions, including X7 v Australian Crime Commission and Lee v The Queen, in which the High Court has considered the means by which courts may ensure that the conduct of civil, disciplinary or inquisitorial proceedings does not prejudice the interests of an accused in pending criminal proceedings, either by requiring the accused to divulge his or her defence ahead of time or by requiring the accused to provide information that is likely to be incriminating. The cases show that courts have a range of means of ensuring that the fair conduct of criminal proceedings is not prejudiced by the conduct of other proceedings, such as:

• A stay order like the one in Zhao may be made by a superior court in its supervisory jurisdiction or may be made by an inferior court in the exercise of its implied powers. A superior court also has inherent jurisdiction to restrain contempt; this jurisdiction extends to making an order restraining a body with investigative powers (such as a disciplinary board) from seeking to compel a person charged with an offence from answering questions that relate to pending criminal proceedings.
• Where a statutory provision confers investigative powers on an office holder, a court will be reluctant to interpret the provision in a manner that empowers the office holder to compel the production of information that relates to pending criminal proceedings. It is only where clear and unambiguous terms are employed that a statute will be interpreted to require the production of information in breach of an accused's right to silence.
• Even where a provision empowers a statutory office holder to compel a person to provide information that may implicate him or her in the commission of an offence, the information will generally be held to be subject either to 'use immunity' or 'derivative use immunity'. Use immunity prevents information obtained by an investigator pursuant to his or her compulsive powers from being used directly in criminal proceedings. Derivative use immunity prevents evidence found or discovered as a result of the giving of information to an investigator from being admitted.

Finally, where an accused has been required by an investigating body to provide information in breach of his or her right to silence, improper provision of that information to prosecuting authorities may require any subsequent conviction to be quashed.

For queries relating to any of the issues identified in this blog, please contact:

Jonathan Bayly
Principal Solicitor
jonathan.bayly@vgso.vic.gov.au

Rodney McInnes
Principal Solicitor
rodney.mcinnes@vgso.vic.gov.au

WA Supreme Court delivers explicit message on privacy: compensation awarded to Facebook post victim

A woman who was the subject of sexually explicit social media posts by her ex-boyfriend has been awarded almost $50,000 in damages, in a further development of the protection of privacy in Australia.

The facts

In the recent case of Wilson v Ferguson, the plaintiff claimed that her former partner had breached an equitable duty of confidence by posting sexually explicit photographs and videos of her on the internet.

The couple had sent each other explicit photographs over the course of their relationship.  The defendant also took naked photographs of the plaintiff with her consent.  On one occasion, the defendant accessed the plaintiff's phone without her permission and emailed himself videos of the plaintiff engaging in sexual activity.

Following the break-down of the relationship, the defendant posted 16 explicit photographs and two videos of the plaintiff on his Facebook page, along with offensive comments.  The images were accessible to hundreds of the defendant's 'Facebook friends' - many of whom also knew the plaintiff - before they were removed several hours later.

Judgment

The Supreme Court of Western Australia found that the defendant had breached an equitable duty of confidence owed to the plaintiff.  The elements for succeeding in an action for breach of confidence are:

• the information in question was of a confidential nature (i.e., not widely known);
• the information was communicated or obtained in circumstances importing an obligation of confidence; and
• the information was used or disclosed without authorisation.

The Court found that where a person shares intimate photographs in the context of a relationship, it is ordinarily on the implied condition that the photographs are to be kept confidential.  In this case, the plaintiff's expectation that the material be kept private was confirmed in her conversations with the defendant.  The Court also found that by accessing sexually explicit videos from the plaintiff's phone without her knowledge, the defendant was placed under a duty to keep those videos confidential.  The Court was satisfied that posting the material on Facebook was a clear misuse of the confidential information.

A new avenue of redress for victims?

While there are numerous criminal offences which involve breaches of privacy (such as stalking, the use of surveillance devices and the interception of telecommunications), the common law action for breach of privacy remains relatively undeveloped in Australia.   As recently reported by the Australian Law Reform Commission, this means there are limited avenues of redress for persons who have suffered from serious intrusions on their privacy.

Plaintiffs have occasionally brought actions for breach of confidence, where the usual remedy is an injunction to prevent the publication, or further publication, of the confidential information.  Equitable damages have traditionally been awarded for economic loss, but not for distress that falls short of a psychiatric injury.  Accordingly, this cause of action has not been seen as useful for plaintiffs who suffer embarrassment, but no financial harm.

Importantly, in Wilson v Ferguson, the Court not only granted an injunction preventing the defendant from republishing the explicit images of the plaintiff, but also awarded equitable damages of $35,000 to the plaintiff as compensation for the distress caused by the dissemination of the images.  The Court expressly relied upon the 2008 Victorian Court of Appeal decision of Giller v Procopets  in determining that such damages were available.  The defendant was ordered to pay a further $13,404 in equitable damages for economic loss, to cover the plaintiff's time off work following the incident.

As such, this case represents a potentially significant precedent on the award of equitable damages for emotional distress for the misuse of personal information.  If the decision is followed, bringing a legal action for breach of confidence may become a far more attractive avenue of redress for people who have suffered from serious invasions of their privacy where there was an obligation of confidentiality.

A cautionary tale of the use of technology…

One of the Court's key reasons for expanding the award of equitable damages was the recognition that the law needs to keep pace with the use of technology on modern society. As Justice Mitchell remarked, it is not uncommon for people in relationships to use mobile phones to share intimate communications, and the internet is an easily accessible platform to disseminate those communications with the world.  Although the explicit images in this case were removed from the defendant's Facebook page just hours after being posted, the damage had already been done.  The award of almost $50,000 damages against the defendant comes as a timely reminder that comments and postings made online in the spur-of the-moment can have far-reaching 'real world' consequences.

For information on privacy law and related criminal offences, please contact:

Louise Jarrett
Acting Managing Principal Solicitor
louise.jarret@vgso.vic.gov.au 

Amy Galeotti
Solicitor
amy.galeotti@vgso.vic.gov.au

Operation Fitzroy - learnings for integrity in procurement practices

Between September 2013 and October 2014, IBAC conducted an extensive investigation into alleged serious corrupt conduct by employees of a government department and statutory authority.

The investigation, dubbed 'Operation Fitzroy', involved 15 current and former public officials and government contractors being called to evidence during a series of public examinations conducted in the County Court of Victoria in mid-2014. These were the first such examinations conducted by IBAC since its establishment in 2012.

The IBAC report identifies a need for the Victorian public sector to learn from the findings of Operation Fitzroy and to strengthen measures to ensure integrity in public procurement.

As another year begins, it is timely for government agencies and departments to reflect on the findings of the IBAC report and consider whether their own existing procurement practices are adequate to safeguard against corruption.

Lessons from Operation Fitzroy

Public sector organisations are entrusted with a significant responsibility for public expenditure. With this comes an obligation to have robust measures in place to ensure integrity in procurement practices.

Solid organisational processes, and a good organisational culture, are cornerstones of good procurement practice.

The IBAC report identified a number of factors as contributing to corruption risks. Ensuring that departments and agencies have robust practices in the following areas will help protect against corrupt conduct and ensure integrity in procurement practices.

1. Contract management. Good contract management practices are essential to managing corruption risks. It is good practice, for example, to continue to monitor projects once a tender process is finished and a contract awarded. Adequate performance monitoring, which continues beyond a tender process, may assist in detecting corrupt practices. Controls over sub-contracting arrangements are also important.
2. Supplier due diligence. Due diligence must be conducted on suppliers who are awarded contracts. This enables departments to investigate any connections between individuals within the department, and companies that are being awarded contracts. There should be controls to ensure that suppliers have the necessary skills, qualifications, financial viability and experience to deliver the required goods and services. This will help ensure that value for money is achieved in government procurement practices.
3. Training and expertise. Government employees with procurement responsibilities must have appropriate training, experience and adequate technical knowledge about the goods or services being procured. There should be ongoing processes for employees and contractors to raise concerns about procurement misconduct and corruption. There should also be ongoing education and training for all relevant employees regarding procurement policies and procedures, as well as associated corruption risks, and mechanisms to engage with suppliers regarding procurement policies and procedures, probity obligations, standards and requirements.
4. Management of conflicts of interest. Departments must ensure that there are appropriate processes in place to manage conflicts of interest. This could include, for example, a register of interests in which department employees regularly record any relevant interests, training for identifying when conflicts of interests occur, and processes for referring contentious or difficult conflict of interest issues to management.
5. Management of procurement staff. Managers of procurement officers must be appropriately trained in managing conflicts of interest and other corruption risks, and have appropriate managerial expertise. This will ensure that procurement staff are adequately supervised, and that staff activities are monitored and checked. It will also mean that red flags, which may indicate that improper or corrupt practices are occurring, are identified and acted upon sooner, rather than later. There must also be accountability of those at management level.
6. Recruitment of management staff. There should be processes for screening prospective employees in potentially high-risk positions relating to finance and procurement, and re-screening regularly for appointed employees.
7. Timeframes for delivery of projects. Tight timeframes and a culture of expediency may create corruption risks related to procurement planning, compliance and scrutiny of decisions. Regarding procurement policies as subservient to delivering significant programs of work as quickly as possible may lead to non-compliant or improper behaviour. The tension between meeting project delivery requirements and complying with procurement policies and processes must be monitored and managed appropriately.

The VGSO has a long-standing practice in public sector integrity, government procurement and public sector governance. We can assist you to ensure that your department or agency is protected against corruption risks, and conducts its procurement activities appropriately. With extensive expertise in public sector integrity processes, we can also provide advice and assistance with respect to department and agency responses to inquiries by bodies such as IBAC.

 For queries relating to any of the issues identified in this blog, please contact:

Julie Freeman
Assistant Victorian Government Solicitor
9947 1404
julie.freeman@vgso.vic.gov.au

Alison O'Brien
Assistant Victorian Government Solicitor
8684 0416
alison.o'brien@vgso.vic.gov.au

Sophia Angelis
Solicitor
sophia.angelis@vgso.vic.gov.au

Handy resources for procurement

• Current Victorian Government Purchasing Board procurement policy framework 
• Victorian Public Sector Commission Good Practice Checklist -Supporting Integrity in Procurement