IN THIS ISSUE

 

Australia

Australia: ACM contract under scrutiny

 

Senator COONEY (Lab, Victoria):  I would like to ask some questions arising out of the statement Mr Farmer made. You say you have full faith in the staff and have been very impressed with it over your three years. Have you got confidence in Australasian Correctional Management, ACM, that runs the centres?

Mr FARMER (Secretary, DIMA): We have an elaborate - and deliberately so - system for managing the contract with ACM.

Sen. COONEY:  I asked you whether you had faith in them. I take it from that answer that you have not.

 Mr FARMER: No, I am saying we have a process that enables us to reach conclusions about the way in which ACM handles its contract.

Sen. COONEY: Why would you do that if you had full faith in them? I simply asked whether you had confidence in them, and the impression I am getting is that you have not - which concerns me a bit.

Mr FARMER: Perhaps I am not conveying my view clearly.

Sen. COONEY: I do not think so.

Mr FARMER: We have in any major contract a variety of mechanisms for monitoring the contract. That is what you would expect. The detention services contract has substantial elements of reporting and monitoring which enable us to reach conclusions about the way in which ACM does its job. So I have more than an impression that we have a quite detailed process for reaching views on how that contract is performed.

Sen. COONEY: Do you have faith and trust in ACM?

Mr FARMER: Over the last two years there have been a number of highly challenging issues, many of which ACM has handled very well, in my view. There have also been a number of incidents where we believe things were not handled well, and we have pursued those with ACM.

Sen. COONEY: Unfortunately, I am still left with the impression that I am not sure what you think of ACM. It sounds as though you have some considerable doubt about them. If that is so, why do you persist with them?

Mr FARMER: I have not used those words, Senator. I have tried to explain to you the basis on which we deal with ACM, the way in which we try to ensure that they administer our centres in accordance with the contract.

Sen. COONEY: I keep asking the same question - I do not know how much clearer I can make it, I am sorry...

Mr FARMER: I think I have the same difficulty, Senator.

Sen. COONEY:  The question is: do you have full faith and trust in ACM? Every time I ask you that you baulk at the answer, you will not answer it. I conclude from that that you have some doubts about them.

Mr FARMER: The contract does not contain any reference to faith or trust. It talks about detention standards which we expect ACM to administer. As I said, we have a quite well developed process to enable us both to do that and to take corrective action if it is not being done.

Sen. COONEY: So your answer is that it is irrelevant as to whether you have full faith and trust in ACM?

Mr FARMER:  We have a commercial relationship with them, Senator; that is right.

Sen. COONEY: So you say that what you think as to whether they are good or bad is quite irrelevant?

Mr FARMER: No, not at all.

Sen. COONEY: I am not sure what you are saying.

Sen. ELLISON (Minister for Justice and Customs): Madam Chair, I think the thing here is that Senator Cooney has asked Mr Farmer about whether he has faith or trust in ACM. Those words are somewhat subjective, and Mr Farmer is saying, ‘We have a contract in place, there is quality assurance and we assess the performance of ACM in relation to that contract.’

I think we are perhaps on two different wavelengths here. If Mr Farmer were asked about how that contract had gone, the evaluation of it, and if they had fulfilled their requirements, that would be a little different to being asked about faith and trust, because that really is a more subjective view. To bring that into a contractual situation is a bit different. If you had asked, ‘Have they lived up to their contract and are they fulfilling their contract?’ that is a different story.

Sen. COONEY: I will explain to you why I am asking the questions. Mr Farmer introduced the issue of the problems that we have had in detention centres. He then says, ‘Arising out of those problems, there are statements by the inmates who say, “We have been treated badly.” There are then statements by the department which say, ‘We have looked at this, but it is all right. This has not happened. There has been the odd event but, by and large, it has been very good.’ If Mr Farmer is basing that opinion on the fact that he has great trust in the department - which he says he has - plus great faith in the ACM, then you would want to ask just how good the department and ACM are, because what he is doing is preferring one version to another. That is the difficulty with all this business in the detention centres. In other words, there seems to be a propensity on the department’s part to pick up the evidence of one side, and I think a lot of that comes because of his proper faith in his staff and in ACM.

Mr FARMER:  Senator, they are your words. You talked about ‘faith’ and ‘trust’. I have not used those words. I have not said that they are elements in my thinking about ACM.

Sen. COONEY: Of course they are my words. That is exactly what I am saying. You seem to cavil, Mr Farmer. You do not seem to want to answer the questions. If you do not want to answer, we draw our own conclusions.

Mr FARMER: I am not cavilling, and I am not not answering, Senator. I am saying that I do not use the words that you attributed to me.

Sen. COONEY: I know what you are saying. You are not answering the questions. You are saying that they are unfair questions and that I should ask you about the contract and whether you monitor the contract. I am not asking you that. As Senator Ellison says, perhaps I should not. But you are not answering my questions. You are saying, ‘I am not going to answer them because they are not appropriate.’

Mr FARMER: I  have answered your question, but I am not in a position where it is appropriate for me to say, ‘I have faith or trust in a commercial organisation.’

Sen. COONEY: Right. That is the answer.

Mr FARMER: Our approach is to use the elements in the contract which are designed to enable us to manage the contract and to arrive at views on whether the contractor is or is not performing the contract to the required standard.

Sen. COONEY: You have given me the answer that I want. Perhaps it would have helped at the start if you had simply said, ‘I do not think it is appropriate for me to answer the questions.’ That is all you needed to have said.

 

Performance measures?

Sen. HARRADINE (Ind. Tasmania): May I ask a question. Mr Farmer, what methods are used to measure ACM’s performance against the detention standards?

Mr FARMER: I will ask my colleague Ms Godwin, who is the First Assistant Secretary in charge of the detention task force, to answer that question in detail.

Ms GODWIN (DIMA): We have a process of quarterly formal evaluations. That takes the form of reports received by us from our centre managers - the DIMA business manager in each of the centres - as well as an examination of incident reports and the way in which various incidents have been managed during the period under review. Those items are brought together, as I say, in central office and staff in central office go through them. There is a framework against which the contractor is assessed, which is included in the contract, and points are assigned -positive or negative - and then, at the end of that process, there is either a net gain positive points - or net negative points, and they are applied. The way in which the assessment is done looks not just at the incident that occurred, for example, but at the way in which the incident was managed. For example, if an incident occurred but was well managed, that would not necessarily attract a negative response from us. On the other hand, if an incident occurred and we took the view that it had not been well managed then negative points might accrue.

Sen. HARRADINE:  So it is the amassing of those points, negative or positive, that constitutes the performance review function of DIMA?

Ms GODWIN:  That is the formal assessment component. As well as that, we have regular meetings with ACM, both at a central office and ACM head office level, and also on the ground where our DIMA staff at centres meet with the ACM manager at the centre. The purpose of those meetings is to discuss contract issues more generally. They may not be things that are formally assessable under the contract but where we would want to discuss with them, for instance, their staff selection processes or the way in which they have responded to the health needs of detainees in that particular centre or something of that nature.

Sen. HARRADINE: Or educational needs, specific needs for women and children and so on?

Ms GODWIN: We have those discussions regularly. They used to be held quarterly to coincide with the quarterly assessment process. In the last few months, we have upgraded those to monthly discussions. We are also introducing some additional elements to our monitoring arrangements to do with - what I guess you could call - audits from time to time of particular issues in the contract and that processes being implemented now.

 

Contract extended, but ...

Sen. HARRADINE: Much has been said about the contract. When was the contract entered into with ACM?

Ms GODWIN: The contract was signed in February 1998.

Sen. HARRADINE: For how many years?

Ms GODWIN: For an initial period of three years but with extension provisions.

Sen. HARRADINE: Am I correct in understanding that that has been extended for another 12 months and, if so, why?

Ms WEBB (DIMA): The contract was extended for a further 12 months to allow time for the negotiations that the contract requires to be conducted fully and thoroughly. In the preceding period, we had had that surge in boat arrivals and the department had not been in a position to give it the priority that it would otherwise have been given.

Sen. HARRADINE: Whether or not you renew a contract would depend on performance standards. Were you not at any given time during that period able to alert the ACM management to problems in their performance  standards? Presumably, their performance standards were not considered to be at a sufficiently high level to award them the contract for the further three years?

Mr FARMER: In terms of the contract itself, there are a number of steps that have to be taken.

The first one is that we have to satisfy ourselves that the service provider is delivering value for money. We also have to satisfy ourselves that, in terms of industry standards and so on, we are getting the sort of service that is the best in the marketplace and we have to satisfy ourselves about the quality of service. In relation to particular issues and incidents, we have pursued those with ACM. In relation to their overall performance during the contract, that is something that is being looked at in the context of contract renewal or not. We essentially have a choice: to extend the contract or to go to the market - in other words, to tender for services in the market.

 

Costs , merchant bankers & audits

Sen. HARRADINE: Do you have figures that provide the overall cost, the cost per centre and the cost per detainee per year?

Mr VARDOS (DIMA): We do have those costings; I am sure they are in my brief.

Sen. HARRADINE: I would be grateful if you would take that on notice.

Mr FARMER: We will do that, Senator.

Sen. HARRADINE: Thank you. Are you able to provide us with a breakdown of payments made to ACM - for example, by centre per head of detainees per financial year?

Mr FARMER:  Some of those matters we have explained to the committee before. There is a particular reason. We are facing litigation in respect of this contract, and we have really been constrained from giving information that would, in effect, be of use in that litigation. We will give you such information as is possible to do within those constraints.

Sen. HARRADINE: Since the commencement of the contract with ACM, has DIMA ever conducted an audit of ACM’s accounts?

Mr VARDOS: There has not been an audit, in the conventional sense, of their accounts, but there certainly

has been a review of their costing regime in the context of the renewal of contract negotiations. Ms Webb may be able to provide more information on that.

Ms WEBB: If you would like me to elaborate, we employed a merchant banking firm, N M Rothschild and Sons, to assist us in understanding the costing structure and the way that the charges imposed by ACM had been constructed. That went on for about six months of last year. In a pretty thorough manner, they went right into the details of the books and were able to advise us in a lot of detail about the way the charges were constructed. While that is not a formal audit in the sense of their being an auditing firm and with the intention of their giving us, if you like, a bill of health about their books, it was nonetheless a very thorough analysis of the underlying charges that lead to the prices that we paid.

Sen. HARRADINE: Is there any way that one can get a handle on how ACM have done - for example, their profit and loss, their balance sheets and what have you - out of the centres?

Mr FARMER: Presumably, they have a company report. I just do not know the extent to which they report on matters in the report.

Sen. HARRADINE: Surely your department would be very interested in how they have gone financially in respect of the services provided at detention centres.

Mr FARMER: Indeed we are, and there are provisions in the contract for us to deal with ACM in relation to profit matters.

Ms GODWIN: As far as I am aware - and I would need to check this back to the beginning of the contract - ACM provides us with an audited statement each year. We are entitled under the contract to undertake our own examination of their books if we so determine. That was the point that Ms Webb was mentioning, that we have actually used our ability under the contract to examine their financial arrangements as part of our overall approach to contract renewal.

 

ACM’s profits guaranteed

Sen. HARRADINE: Can the committee be provided with this information on how they have gone and whether they have made a profit out of their contract with you?

Mr FARMER: They have certainly made a profit, because that is inherent in the contract.

Sen. HARRADINE: It is a cost plus arrangement, is it?

Ms WEBB: Yes, that is correct. The contract provides for a margin of profit above costs. In terms of  providing the details, can I suggest that we review how much we can give you consistent with not interfering with the other issues that we are facing. Within that constraint, we will give you as much as we can.

Sen. HARRADINE: In 3.3 of the general agreement it mentions the sharing of costs between DIMA and ACM. How is this measured and achieved?

Ms GODWIN: Each year, under the contract, if ACM has made savings over and above its normal operating arrangements, those savings are shared with the department on an agreed formula. Again, that is something that we are able to audit. It is done on a calendar year basis and we would be able to audit those. At the moment, we are at the point where we would expect to get their statement under that provision of the contract and then go forward with an audit.

Sen. HARRADINE: You have got a system of incentives and fines and, at the end of the year, you have performance linked fees. How does that operate?

Ms GODWIN: That goes back to the point that I was making before about the quarterly assessment. So it is not done on an annual basis; it is done quarterly. There is a proportion of the fee for each month in the quarter that is retained by us, and then at the point where we do the assessments - as I said before, there is a negative points, positive points sort of approach - if there is a net negative, there is a financial amount attached to that and we would withhold that. If it is positive, we do not pay them, but they would then get the full amount of what is called the ‘retention amount’ that we have so far held back.

Sen. HARRADINE: In the event of say, a riot, who pays for the damage? The new perimeter fence cost something like $1.7 million. Who pays for that?

Ms WEBB: In the case of something like a riot there are three ways that the damage bill is distributed. One way is by ACM themselves, if the damage is such that, under the contract, they would have been assessed as being reasonably capable of preventing it had they acted in a different way.

Had the damage been such that it was assessed that it was not something that ACM were able to prevent, then we go to the Commonwealth insurer - Comcover - and put in a claim for insurance, which is what we have done with the damage done in the Woomera riot. Comcover is assessing the claim. In that instance, we understand that we will shortly be getting a determination from Comcover and we are led to believe that they will agree to foot the bill.

The cost of the capital works at the various centres is met in different ways, to some extent depending on who owns the centres. Where the Department of Finance and Administration is the landlord, at places such as Maribyrnong or Port Hedland, they actually fund the capital to put up fences or, in the case of Port Hedland, to put in a new kitchen. At Woomera the department has been funding those works either as capital works or as works that can be dismantled and moved to another centre when we need them.

Sen. HARRADINE: Mr Farmer, has the department made an overall assessment of the comparison between the cost of detention prior to privatisation and the cost after - that is, the cost to the taxpayer?

Mr FARMER: I am not sure that the microphones are working properly. We cannot hear you.

Sen. HARRADINE: I will try again. Has the department made an analysis of the comparison between the cost to the taxpayer of the detention prior to privatisation as against after privatisation?

Mr FARMER: There are a number of things to say to that. One is that in absolute terms the cost to the Commonwealth has risen very substantially because the number of people in detention has risen very substantially in the last two years.

Sen. HARRADINE: Mutatis mutandis.

Mr FARMER: The trouble is changing of things that need to be changed. We are dealing with different contracts and we are asking different things of the current detention service provider than we asked of the previous detention service provider. Mr Metcalfe elaborated on this point to Senator McKiernan at an earlier meeting. I might ask him to elaborate on that point.

Sen. HARRADINE: I do not want anything to be repeated, if you can point me in the direction of when that was.

Mr METCALFE (DIMA): It certainly was at the previous estimates hearing. I think it was in this room, possibly 12 months ago.

Just to supplement what the secretary said, when the Australian Protective Service were the service provider, essentially they were providing guarding services and security services, but some other aspects of service delivery, such as medical services and catering and so on, were independently contacted by the department. Part of the concept of the competitive tendering of the contract would be that the service provider provides a complete service: detention services, catering, health and education services, transport services and whatever.

As I said to Senator McKiernan some time ago, it is difficult to make a comparison because you are comparing apples and pears. We can find the reference to the earlier exchange and we will provide that to you.

Sen. HARRADINE: Obviously we are interested - and no doubt you are, because we are both responsible for the expenditure of public monies - in seeing how it has gone, principally for the detainees but also for the taxpayer. That seems to be a relevant question. I know you have got apples and pears arguments ...

Mr METCALFE: I completely understand the question and I think it is a very fair proposition that you are pointing to. I will take on notice that particular issue and see if there is any analytical or comparative work that may have been done that may be able to assist the committee in saying whether it was cheaper to do it in a certain way or more expensive to do it in this way.

To a certain extent, I think our response may be seen as not being particularly helpful, but it may reflect reality: the decision was taken by the government in 1996 to competitively tender the service.

A number of companies forwarded tenders. The previous service provider did not tender, so what their costs might have been under the current service provision becomes quite speculative. Adding to that is the fact that, as we have discussed at previous hearings, there are different daily rates for detainees depending on the numbers of people in detention.

Having made all those points, I will take that question on notice and see if we can provide you with an answer.

 

Wackenhut’s involvement

Sen. HARRADINE: Thank you. On the question of your own immigration detention standards, I notice that the first principle in those standards states: ‘Immigration detention is required by the Migration Act and is administrative detention, not a prison or correctional sentence.’ Considering that, how did DIMA assess that against its decision to appoint a company which really is a prison and correctional services company?

Mr METCALFE: The answer is that the company can do a variety of things and, in the tender process that took place before the signing of the contract in November 1998, an evaluation was made of the tenders.

You are quite right: we are looking for a range of services which is not in all respects the same range of services that you would be looking for in a prison or a correctional environment. We are looking at the capacity of potential service providers to provide what we require.

Sen. HARRADINE: ACM’s parent company is Wackenhut Corrections Management, isn’t it?

Mr METCALFE: There are two owners of Australian Correctional Services: Wackenhut, a US company, and Theiss Constructions, an Australian company.

Sen. HARRADINE: What is the relationship between the Australian company and Wackenhut, for example, in its operations in America?

Mr METCALFE: There is an Australian set of directors and it is an Australian company, but there is an ownership structure back to the American company.

Sen. COONEY: Is it ACM or ACS that you are talking about?

Mr METCALFE: The parent company in Australia is Australasian Correctional Services. They have contracted the service delivery component of the contract to a subsidiary company, Australasian Correctional Management. The names do tend to get interchangeably used, but ACM are actually the people who provide the service.

Sen. COONEY: Mr Farmer, when you were asked by Senator Harradine about what experience they have had, you said they have done a variety of things. I take it from that that they have looked after detention centres either here or overseas prior to signing up with the immigration department. Can you tell me what those detention centres either here or overseas that you were referring to were when you said that they do a variety of things?

Mr METCALFE: It was before my time, Senator, but we will see if someone who was involved in the contract can help you there.

Ms BEDLINGTON (DIMA): I know, because we got references from the countries concerned, that Wackenhut or one of its subsidiaries actually operated immigration detention centres in the United Kingdom and in the US.

Sen. COONEY: We have been told by the secretary that Wackenhut is not directly involved, that it has an ownership link and that it has nothing to do with the management. I was asking this in terms of management.

Ms BEDLINGTON: They do have a link in terms of management in the sense that where they produce, for example -

Sen. COONEY: Just stop there. I want to clear this up first. We were told that it did not have a management link, that it had an ownership link and that it was all done in Australia.

Ms BEDLINGTON: Senator, if I could finish, then the answer to that question will become clear.

They do not have a direct responsibility management link, but where they develop products and procedures that might be useful, for example, particular management techniques and so on, there is an informal sharing of best practice across Wackenhut and all its subsidiaries. They are subject to direction from the parent company.

Sen. COONEY: How do you know that?

Ms BEDLINGTON: That was part of the evaluation.

Sen.COONEY: Have you got those evaluation documents?

Ms BEDLINGTON: I beg your pardon?

Sen. COONEY: Have you got the evaluation documents you have just spoken about?

Ms BEDLINGTON: That was part of the tender evaluation.

Sen. COONEY: Where are they now? You have told us something, and I just want to check up on it. Is that possible?

Mr METCALFE: Those documents will be held by the department. Could I take on notice that question and again run the issue of whether there are any commercial-in-confidence issues that may arise. I know the precise point that you are seeking, and we may be able to extract that particular aspect.

 

Smoke and mirrors

Sen. COONEY: Mr Metcalfe, you have been very helpful over the years and I thank you for that - but when we discuss these issues here, we get statements - bang - and, as a committee, we have absolutely no way of checking the credibility of those sorts of statements.

Mr METCALFE: I appreciate the point. That is why I said that, certainly to the extent possible, we will follow that issue up. The precise thing that I think you are asking is: what information was before the department when we awarded the contract to ACM?

Sen. COONEY: I will put the issue of statements in context. From what I can see and from events described in the papers, a lot of trouble has occurred in these detention centres, which is not normal if you look at jails.

People say, ‘It is really the inmates who are the problem,’ which seems to me to be a cop-out, if I can use that expression, because there are not the same problems in the places that ACS runs where you have convicted criminals.

We are told that it is an inmate problem and we have to do nothing there, but you can imagine - and I think you have given evidence that people sent out as guards to Woomera, for example, have about four weeks of training - that  people with little training who are working in these detention centres are going to get a bit irritated by what goes on there and that clearly the closest people to take their frustrations out on are those they are supposed to be looking after. That is the picture you get. You come along here and say, ‘What about the contracts,’ and, ‘This contract is going to do this’ but we never see the contract.  That is a bit unfair because you have given me a pro forma and invited me to look at it, which I do not intend to do because this has all got to come out in public.

The committee is bound the whole time here by statements from the table. I am not saying for one minute that the department is not full of people with absolute integrity, but I would really like to know whether their interpretation of things is as good as it could be.

Ms Webb gets you a bit worried when she says, ‘We went off to a merchant banker to see our way through.’ You have to ask yourself: ‘What capabilities are in this gathering before us?’ I am just trying to get some sort of check on things.

Mr METCLAFE: I know where you are coming from Senator, and to the extent possible we certainly will assist.

 

 

Exclusive contract negotiations

 Sen. COONEY: As I understand it, Mr Farmer was saying that the way we are checking whether or not we ought to keep on ACM is by measuring them against contractors. It is not a matter of having faith or trust in them; it is a matter of whether they adhere to the contract. They said they are in negotiations and that they are going to be long negotiations. Would I be right in concluding that there would be some problems with ACM management?

Mr FARMER: Were we to decide not to extend the contract, the length of time gives us the option to go into a tender process which would take some time. That is the reason for the period we are talking about.

Sen. COONEY: I understood that this was a term contract for three years, with a right - I take it the right is in ACM - to renew the contract, but for how long?

Mr METCALFE: I might briefly explain the contractual overview to provide some context to that question. Essentially, the department has a contract in place with ACM, called the general agreement, which has a life of 10 years.

Although that sounds like a long period, the actual performance of the contract comes under a services contract which is the three-year contract we have been talking about. That ran from February 1998 until about now and has been extended to allow us to go through this particular process. It is open to the Commonwealth to extend the contract for a further period, but as Mr Farmer indicated earlier when responding to Senator Harradine, there are a number of issues that we are obliged to take into account in deciding whether or not we would extend the contract.

The threshold issue is: do we believe that we are getting value for money? Are we able to satisfy ourselves in relation to that? That is exactly what we are going through at the moment and what Ms Webb has described. Depending upon the outcome of that, we also have to look at issues such as whether we believe that they are performing all requirements of the contract to a satisfactory standard and whether they represent best practice in the industry.

The value for money consideration is occurring at the moment. We are being very careful in what we say today because the contract requires an exclusive negotiation period and that is what we are in currently. It is crucial that we maintain an open mind in relation to these matters until the secretary ultimately takes a view one way or the other. Hypothetically, were the decision taken that we did not wish to extend the contract, then we would need to go through a new tender process.

ACM, of course, would be open to bid for that process but other companies could then come in and we could examine their costs and capabilities in the area. Our experience in such commercial areas is that that process would naturally take some time. We would need extensive commercial and legal advice. It is a valuable and crucial contract in terms of public interest, so we want to do the best we possibly can. As we have indicated, when it occurred last time one of the disappointed tenderers commenced litigation in relation to that issue. So we will obviously undertake the task properly and carefully. Realistically, that will take some months. That is why the 12-month extension was provided. If the secretary hypothetically decided to extend the contract, that is something that would occur more quickly.

Sen. COONEY: I take it that the right for renewal lies with the department; the ACM has no right of renewal.

Mr METCALFE: The contract allows ACM to make an offer, which they have done. It requires there to be an exclusive bargaining period, which is what we are in, but at the end of the day it is our decision.

 

Investigating incidents

Sen. COONEY: In this context but a little differently, say there is a complaint, a difficulty at some detention centre, and someone rings up or writes in to the department that there are some problems there: what happens? I get the impression that you might ring up ACM and say, ‘Is there any trouble?’ and they say, ‘No. Somebody was rioting and that’s all been fixed up now.’ You then hang up the phone and say, ‘That’s the problem. Write a letter to the constituent saying that we have inquired about this and our inquiries show that that has not happened.’ Or else you might ring up somebody from the department who was there but did not see the incident and then sees ACM. One of your problems is a problem with prisons in general and it is a difficult one. It is the quality of an investigation into an incident that is a problem, I think.

Mr METCALFE: It is more than just a phone call, I can assure you. A lot of resources are devoted to monitoring and performance managing of the contract.

Ms GODWIN: In many instances we would already have been made aware that there had been an incident through what is referred to as the incident reporting process. That is something that has been a matter of discussion publicly in the last few months. In any event, if we got such a complaint, you are quite right - we would in the first instance speak to ACM, but it would not just be a phone call, as Mr Metcalfe said. What we would ask for would be a report of the incident, if one had not already been provided. On the basis of that report we would go back and seek further information. A number of other things would follow, or may already be in train.

ACM itself will often, depending on the nature of an incident, appoint an investigator from some other part of the agency - someone who is not in that centre and who is not involved in the management of that centre in any way - to go in and examine the complaint. We would always consult with our DIMA business manager as to their view - whether there were further issues that needed to be explored. Depending on the nature of the incident, we would also check that certain reporting had been done. For example, if it was something that should have been drawn to the attention of the police or some other agency we would check that it had been done appropriately. There have been occasions - and this is something we are progressively doing a bit more of - when we would engage somebody independent to undertake a further examination of ACM’s handling of an issue and, to some extent, whether we, as the DIMA officers responsible, had also attended to the issue appropriately.