Institutional mayhem: insights gleaned from the ALC Annual Report 2024-25

Away, and mock the time with fairest show;

False face must hide what the false heart doth know.

Macbeth, Act one, Scene seven

 

On 29 August 2024 Minister for Indigenous Australians Malarndirri McCathy issued an unprecedented media statement which among other things extolled the virtues and rationale of good governance (link here). She proclaimed:

Good governance is the cornerstone of trust and needs to be based on transparency, fairness, and accountability. Without the trust of the Anindilyakwa people and other key stakeholders, the ALC cannot properly represent its people and achieve its mission.

“I take governance at Land Councils seriously - poor governance and decision making can have a significant and detrimental impact on social, cultural and economic wellbeing.

This post provides a summary of the ALC’s most recent Annual Report (link here). I previously posted on the topic of delays in reporting to the Parliament and the public (link here) where I mentioned that the normal deadline for tabling annual reports of Commonwealth entities was before the supplementary Budget Estimates Hearings which are normally held after October each year.

In this post, I cover a wider set of issues than I would normally, essentially because they are all raised one way or another by the most recent ALC annual report. Significant issues covered include the basis for land councils assisting local corporations, education outcomes on Groote Eylandt and remote Australia generally, criminal justice outcomes, the status of the Winchelsea mine proposal, and the Ministers decisions on land council funding across the NT. I apologise for any induced indigestion!  

The Delay in Tabling

The ALC Chair’s cover letter to the Minister is dated 18 February 2026. The financial statements were signed by the members constituting the accountable authority on 13 February 2026. The ANAO signed off the audited financial statements on 17 February without qualification. No explanation was provided by the ALC nor the ANO for the delays in finalising the audit.

The Minister tabled the annual report on 16 April 2026. The Report was initially due to be tabled around the end of October 2025, a deadline that had been extended to end of February by the Minister. There does not appear to have been any explanation provided for the delays of five and a half months beyond the due date specified in the PGPA Act rules, and which includes a period of almost two months after it had been provided to the Minister. I find it problematic that a Minister who espouses the highest standards of transparency and good governance for agencies within her portfolio appears to allow lapses in such standards in matters within her control to occur without explanation or apology. It raises the question: what is it that is being hidden and downplayed, and why is that?

The CEO

On page 13, the Report states:

During the reporting period the Chair of the ALC was Ms Cherelle Wurrawilya. The CEO position was held by Mr Mark Hewitt until 16 October 2024. Mr Colin Wakefield held the position of Interim CEO from 17 October 2024 to 28 April 2025. Mr Matthew Bonson was CEO from 29 April 2025 and resigned on 17 July 2025. Michael Trainor was appointed Interim CEO on 22 August 2025 (emphasis added).

This is one of the few references to Mr Hewitt in the Annual Report. The section on the ALC CEO (page 17) focusses entirely on Mr Bonson who was CEO for only two of the 12 months in the reporting period. There is no mention of Mr Hewitt’s termination, nor the reasons or circumstances that led to it. See my blog post The Angels Weep (link here) for the partial details of these events on the public record.

Performance Reporting

The ALC performance reporting is linked to its corporate plan. See pages 48-50 for the explanation. In relation to the community and economic development objectives of the corporate plan, there are performance measures relating to school attendance, employment, law and justice outcomes and housing.

Pages 59-61 deal with school attendance in a limited cohort of some 80 students supported by the ALC funded Groote Eylandt/ Bickerton Island Primary College Aboriginal Corporation (GEBIPCAC). Attendance rates are declining (and there are indications that wider attendance rates on Groote are similarly low and in decline). There is a long explanation of some of the local factors contributing to these outcomes, though it seems clear that more systemic factors are in play across the remote areas of the NT (link here) and probably beyond. What is demonstrably clear, and should be of critical concern to the NT Government and its Education Department, is that average attendance rates for the 80 students in the cohort being measured of less than 40 percent (see Figure 5c on page 61) are unlikely to deliver acceptable educational outcomes for the students. While the measure suggests that at least 4 out of 10 students are at school each day, the reality is that it is highly likely that virtually all students are missing some portion of each month’s schooling and thus missing key steps in their education. When this persists over time (just how long this period is I am not in a position to determine) the students reach a point where they cannot keep up with the standard curriculum…in turn this creates insurmountable gaps which make the standard curriculum inaccessible, leading either to disruptive behaviours in class, further non-attendance, and eventually permanent dropping out. This annual report is a micro window into a massive problem that is impacting remote communities across at least four jurisdictions. It should be acknowledged as a national tragedy, one that activates and enlivens the Commonwealth Minister for Indigenous Australians. Instead, the response is invariably to shift responsibility: to the states, to the education portfolio, to the parents…yes they all have responsibilities, but in the circumstances we currently face, they all need to be encouraged, and activated to take those responsibilities seriously. This is a role for the Commonwealth Minister. Invariably however, what is in fact a national tragedy is merely presented as a static statistic framed as ‘low school attendance’.

On page 62, it is revealed that the employment rate of traditional owners by local organisations on Groote has fallen over the past year. In 2023-4, 307 TOs were employed, whereas in 2024-5, this had fallen to 199 (see Fig.5d on page 63). Here local factors are the cause, and particularly the drop-off in s64(3) payments arising from the cyclone damage to the wharf. This points to the urgent need for the Groote community to focus much more attention on reducing the dependency and reliance on the flow of royalty equivalents for key organisations on Groote.

Pages 64-68 record a truly exceptional improvement in justice outcomes on the Island. The report describes a range of new initiatives in recent years, and documents (using police data) substantial falls in arrest rates:

Ø  Total recorded offences dropped by 75%, from 1,041 in 2019 to 261 in 2024 (Figure 5e)

Ø  Youth offending decreased by 90% since 2019, from 267 offences to just 28 in 2024 (Figure 5f)

Ø  Arrests have declined 85% from 427 in 2018 to 61 in 2024 (Source: NTG data supplied to the ALC) These reductions are particularly notable in property damage, theft, and public order offences.

The report claims this is the result of greater Anindilyakwa control over justice initiatives and there is undoubtedly merit in this. The youth offending statistics are extraordinary, identifying almost a vertical drop in the last year (from around 250 to 50 offences), and suggest to me that the reduction in discretionary incomes may also have had an impact. In turn this points to issues that should perhaps be taken into account in future benefits distributions. The ALC would be wise (in my humble opinion) to commission an independent research project into the drivers of these improvements, and how best to institutionalise them into the future.

Finally, the Report describes desultory progress on housing construction, but this is perhaps also in large measure a consequence of the Cyclone Megan. Hopefully progress will improve going forward, noting that much of this is out of the hands of the ALC.

Mine related activities

The performance statements include a useful section on mining, and particularly a detailed discussion of engagement with GEMCO. This seems largely on track, with the ALC engaging to ensure minor contract issues are resolved.

On the proposed Winchelsea mine, (as I have previously noted (link here) the ALC appears to have stepped back and is now treating the mine as it would any other third-party proposal. It does mention the Winchelsea exploration and mining agreements but makes no comment. There is no reference to the possibility that the agreements may be sub-optimal due to the possibility of conflicts of interest (a matter that is not acknowledged and which is arguably contested but see my previous analysis here and here). The Report notes (page 72) that

Winchelsea Mining is yet to commence production and during the period was, in ALC’s opinion, dormant. There were no activities on Winchelsea during the reporting period.

On page 77, in a section reporting performance on cultural protection, one of the corporate plan priorities, the report states (emphasis added):

Secondly, cultural sites and burial sites on Winchelsea Island were documented during cultural surveys conducted in the context of mining exploration. The protection that has been afforded to the recorded cultural sites and burial sites identified during the cultural surveys are key to addressing Traditional Owner concerns about the impact of proposed mining activities. Additional cultural surveys are planned and may identify other burial sites for protection.

This is to my knowledge the first public acknowledgement of unaddressed traditional owner concerns regarding mining on Winchelsea. It may underpin the statement I drew attention to in my November 2025 post assessing the most recent ALC Corporate Plan (link here) that

The ALC will be reviewing arrangements with Winchelsea Mining to ensure Traditional Owner's interests are met and that the principles of free, prior and informed consent are adhered to.

Ministerial Directions

The report notes at page 78 that there were no ministerial directions issued during the year.

This was notwithstanding the ostensible Ministerial displeasure with the speed of progress in implementing the ANAO /Bellchambers report which led her to deferring approval of the ALC estimates in late August 2024. In a media release dated 29 August 2024, she stated (inter alia):

I have taken the unusual decision to withhold approval for the ALC’s 2024/25 budget, instead approving an operational budget until 1 December 2024. The full budget will only be considered when ALC has demonstrated to the NIAA that it is sufficiently prioritising and implementing the recommendations of the review and the ANAO audit.  (link here)

She provided the following direct quotation:

The steps I have taken today put the ALC Board and management on notice. Their failure to sufficiently respond to the recommendations of the independent review and ANAO must not continue, and they need to demonstrate their progress to the NIAA.

This may not have been a formal ministerial direction (there is no provision in the ALRA for such formal directions) but strikes me as being in effect equivalent to a substantive direction. It also strikes me as being significant enough to warrant a mention in a Commonwealth agency’s annual report, perhaps in the section on significant actions and changes (see page 78) or in relation to ANAO reports (see pages 46-47 and 79-80). Given the Minister’s public statement calling on the ALC to engage more transparently, this seems like it might have been a good place to start!

Consultants (pages 85-87).

Note the quite high legal costs, which are on top of the in-house legal expertise on the ALC payroll. Yet there is absolutely no explanation in the report nor in the ALC’s media statements on what these legal costs are for (but see the section on contingent liabilities below).

Financial Statements 2024-25.

Note: Page numbering for the financial statements begins afresh.

Employee costs used

On page 5 in the Cash Flow statement, it is revealed that employee cash used has almost halved from the 2023-24 year, down from ($13,515,798) to ($7,725,279). No reason is provided.

Audit committee costs

On page 9, audit committee costs have almost halved, from $100,241 to $52,354. This suggests that the poor value for money practices that were adopted by the ALC over the past decade in relation to its Audit Committee costs (as identified by the ANAO in 2023) has finally been addressed.

Reimbursement of Expenses.

On page 11, wages and salaries, on-charged to local corporations (funded under 64(3)) reduced in 24/25, down from $6,874,714 to $3,818,802. Superannuation costs on-charged were down from $721,462 to $423,938.

Thus, total reimbursement of expenses fell from $8,599,473 to $4,959,070. The implications of this reduction in employment totalling over $3.5m is not clearly explained in the financial statement’s notes, nor as far as I can see in the Annual Report itself. This strikes me as a noteworthy omission in reporting significant events in the Land Council’s operations over the financial year.

The note explaining this states:

The Anindilyakwa Land Council sometimes pays for services and goods on behalf of other Aboriginal Corporations to support the Corporations in pricing and availability. Under Section 27 of the Aboriginal Lands Rights (NT) Act 1976 the Land Council can supply such support when requested. The Anindilyakwa Land Council charges this on to the Corporations with no further benefit. This note reports the substance of the transaction of the goods and services and ensures a clear ability to understand the true income and expense of the financial statements by all users.

Section 27 of the ALRA states inter alia:

(1)  Subject to this Act, a Land Council may do all things necessary or convenient to be done for or in connexion with the performance of its functions and, without limiting the generality of the foregoing, may:

 (a)  employ staff; …

 (1A) A Land Council may, on the request of an Aboriginal and Torres Strait Islander corporation that has received an amount of money from the Council under this Act, provide administrative or other assistance to the corporation.

There is no mention of reimbursement in this provision. The risk of utilising a reimbursement mechanism is that it creates a danger that a land council might use the mechanism to in effect fund itself especially if it can exercise influence or control over the local corporations being ‘assisted’. I have previously argued (and the ANAO pointed to the elements that allow this in its 2023 performance report) that the ALC exercises such influence over several corporations it has funded under section 64(3).

Also relevant to the rationale for the provision of ‘assistance’ is s.23(1)(ea) of the ALRA which deals with assistance for commercial activities of the corporations, and which states:

(1)  The functions of a Land Council are [inter alia]:

(ea)  to assist Aboriginals in the area of the Land Council to carry out commercial activities (including resource development, the provision of tourist facilities and agricultural activities), in any manner that will not cause the Land Council to incur financial liability or enable it to receive financial benefit; …

In my view, the reimbursement of expenses mechanism as it has been utilised by the ALC can easily slide into arrangements that would be in breach of the terms of the legislation, and create opportunities for maladministration (and in a worst case fraud) that require much greater transparency than has been the case to date. The NIAA (including its Audit and Risk Committee) in my view also has responsibilities to advise the Minister of the risks involved in these processes. The fact that these arrangements have been in place for an extended period without any public indication that such warnings have been raised should be a major concern to oversight agencies such as the ANAO and ORIC. See my previous discussion of these issues in my November 2025 analysis of the ALC Corporate Plan (link here).

Contingent Liabilities

On page 29, there is mention of the litigation between the ALC and GEAT. It is not mentioned elsewhere in any ALC public documents. Nor has there been an explanation of the issues in play.

Note 11: Contingent Assets and Liabilities. On 19 June 2024, Groote Eylandt Mining Company Pty Ltd (GEMCO) served a writ to commence legal proceedings and seek a determination in the Supreme Court of the Northern Territory concerning a dispute as to the proper division of mining royalties as between ALC and the Groote Eylandt Aboriginal Trust in respect of the 2016 Eastern Leases Mining Agreement signed under the Aboriginal Land Rights (Northern Territory) Act 1976. The matter was listed for mention on 1 May 2025 was vacated and relisted for 12 June 2025. The matter remains 'on foot' in the court until the position between Groote Eylandt Aboriginal Trust (GEAT) and GEMCO is resolved. The parties through formal negotiation are close to finalising a 'Variation Agreement'. Legal costs are unknown at this moment.

Assets held in Trust

Within Note 15 on page 34, there is a table showing the financial flows through the Royalty Shoppa card system. Some $14m was lodged on Royalty shoppa cards in 2025, and $12m of that was spent. See this post (link here) where I discussed a range of concerns with the operation of the Royalty Shoppa card system. It seems clear that the scheme is still operational and widely used. Its current effectiveness and fitness for purpose is unknown.

ALC Income for operating costs under s.64(1)

The Minister approves operational costs for land councils under section 64(1) of the ALRA. It is the source of core operational funding for all four land councils in the NT.

In 2024-25, the Tiwi Land Council s.64(1) funding dropped by around 20 percent and the CLC funding dropped by around 5 percent. The NLC received an increase in funding of some $38.7m, with section 64(1) funding rising from $69.5m in 2023-24 to $108.2m in 2024-25 or just over 50 percent (see page 116 of the NLC Annual report 2024-25). A footnote on page 120 identifies capital expenditure of $39.5m for ongoing costs of the construction of office precincts in Darwin and Katherine. When adjusted to take account of this, the operational funding for the NLC fell from $69.55m in 2023-24 to $68.7m.

[Short digression: there is a slight discrepancy between the section 64(1) allocations for the NLC in the ABA financial statements appended to the NIAA Annual report (see page 178) and the NLC Annual Report financial statements (see page 116). It is a comparatively small amount, and I don’t consider it materially affects the substance of the argument I am making here. The same ANAO delegate signed both audit statements two days apart in September 2025.]

Thus, in 2024-25, the Minister approved funding providing for reductions in operational funding for three of the four land councils in the NT.

In contrast to the TLC, the CLC and the NLC, the ALC financial statements disclose an annual increase in section 64(1) funding of $2.59m, representing a 20 percent increase over the previous year’s approved allocation of section 64(1) funding. See Note 3F on page 15 which discloses that Section 64(1) revenue in 2024-25 was $13,702,683 and in 2023-24 was $11,105,777.

Somewhat extraordinarily, in a year when, and in which she had issued a media release on 29 August of the financial year announcing an unprecedented decision to publicly withhold approval of funding until December based on generic and unspecified concerns that the ALC was not ‘sufficiently prioritising and implementing the recommendations of the review and the ANAO audit’, the only land council to be granted an increased section 64(1) operational budget by the Minister was the ALC.

Any suggestion that the ALC had somehow demonstrated that it was suddenly ‘sufficiently prioritising the implementation of these reviews and audits is undercut by the ANAO Financial Statements Audit Report issued on 6 February 2025 (link here) which noted in relation to the ALC, inter alia:

4.14.58 The status of the recommendations made by the ANAO, and the minister’s action to withhold funding, have heightened concerns about the ALC’s progress in addressing the governance findings. 

4.14.59 In view of the reduced available funding highlighted above, further audit work was required by the ANAO to understand ALC’s ongoing financial feasibility….

….

4.14.62 The ANAO concluded that there is sufficient evidence to support the preparation of the 2023–24 financial statements on a going concern basis, and the action taken by ALC to address the performance audit recommendations will be revisited by the ANAO in the 2024–25 audit. (emphasis added)

In other words, the ANAO would not be able to formally conclude that the ALC was sufficiently implementing its recommendations until the finalisation of the 2024-25 Financial Audit. While this assessment may not have been published before the Minister approved the full year budget, it does raise questions as to how the Minister might have reached a view that increased funding was warranted.

It is perhaps worth asking the question, what changed for the ALC between 29 August 2024 when the Minister announced the funding freeze and December 2024 when she likely approved the full year budget? The answer of course is the information that neither the Minister nor the ALC wishes to discuss.  

My June 2025 post ‘FOI Updates on ALC and Groote Eylandt’ (link here) confirms that in July 2024 the NIAA (undoubtedly with the Ministers knowledge) referred the ALC CEO to the National Anti-Corruption Commission (NACC). Within a month, the Minister issued her media release announcing a funding halt for the ALC. In October, the ALC Board met with no staff present and a single NIAA senior officer in attendance and decided to terminate on notice the former CEO (i.e. with a termination payment) with immediate effect. Within months, the full year funding for the ALC had been restored, and we now learn (alone among the four NT Land Councils) with additional funding of $2.5m, a 20 percent increase in operational funding. No public announcement was made notwithstanding the previous announcement of the funding halt. While a replacement CEO was not appointed until 29 April 2025, the appointee Mr Bonson resigned some months later. A new CEO has only recently taken up duty.

Readers and this author alike are left with the conundrum: what involvement did the Minister have in deciding it was time for the former CEO of the ALC to depart? Was there any effort made to encourage the ALC to terminate the CEO? Why might the Minister have thought it useful or necessary to provide the ALC with an unexplained 20 percent increase in the Land Council’s operational budget in the months after the CEO’s departure and before a permanent CEO had been recruited? And what does the Minister know about the causes of the institutional mayhem on Groote over the last decade that she is not telling us?

At the beginning of this post, I quoted the Minister’s statement that:

Good governance is the cornerstone of trust and needs to be based on transparency, fairness, and accountability…

For my part, I would reverse the order and suggest that trust and transparency are the indispensable prerequisite of good governance. Unfortunately, trust and transparency are in short supply in both Groote Eylandt and Canberra.

 

4 May 2026

Formidable Challenges Part Two: the pervasive conflicted interests permeating the Winchelsea mine development process

  

Oh, I have ta’en too little care of this.

King Lear, Act three, Scene four

The issues discussed here comprise a critique of the adequacy of the approval processes for the proposed Winchelsea mine (which are laid out in Part One of this Formidable Challenges post) and are in many respects merely an extension and reinforcement of the analysis included in my previous posts on this Blog, in particular my November 2025 post The Angels Weep (link here), my January 2026 post ANAO financial audits and the case for ALRA reform (link here), and my February 2026 post, The rough torrent of occasion (link here).

A central issue raised in the documents listed in Part One of Formidable Challenges relates to the potential for conflict-of-interest arising from the fact that the exploration and mining agreements required by Commonwealth and NT legislation involved negotiation between two parties, the ALC and Winchelsea Mining. The Chair of the ALC was Tony Wurramarrba (now deceased) and the ALC CEO was Mark Hewitt (now terminated). Two of the four Directors of Winchelsea Mining were Tony Wurramarrba and Mark Hewitt ostensibly representing the majority shareholder, the Anindilyakwa Advancement Aboriginal Corporation (AAAC). In other words, the Groote based senior officeholders in both the ALC and Winchelsea Mining were identical. The ALC, whose core statutory function under the ALRA is to protect the interests of traditional owners is required to negotiate the terms of any mining on Anindilyakwa Aboriginal land. Thus, in the negotiations between the ALC and Winchelsea Mining, the two senior officeholders on both sides of the metaphorical negotiating table were Tony Wurramarrba and Mark Hewitt. I have referred to this situation in Part One as the ‘dual roles’ of the two office holders.

The attachments to Document B1 (a DPMC brief to Minister Scullion dated 18 September 2018) include the correspondence from the ALC Chair and ALC CEO dated 15 August 2018 to the Minister outlining inter alia their proposed strategy for managing this potential conflict (paragraphs 16 to 18). Documents A4, a submission from the ALC dated 14 September and appended to the ALC correspondence to the Minister of 14 September and attached to the DPMC brief in Document A1 relate to the consultation processes for the exploration licence application agreement. These various documents contain a detailed account of the arrangements put in place by the ALC ostensibly aimed at ensuring that the ALC Chair and CEO played no role in influencing the ALC’s strategy in negotiating the two agreements, and there are formal statements indicating that the ALC Board was explicitly advised that Mr Wurramarrba and Mr Hewitt represented, and should be treated as representing, Winchelsea Mining in all discussions.

The DPMC brief largely describes in a factual manner the proposed disclosure and non-participation arrangements in relation to the mine consultation processes to be followed by the ALC Chair and CEO laid out in the ALC correspondence. It notes that the ALC engaged external legal advice from Arnold Bloch Liebler (ABL), noted that the ALC had reduced the CEO’s remuneration package (to be reviewed in 12 months) and that the ALC Mining and Environment Manager would assume administrative responsibility of ALC matters related to Winchelsea Mining.  It seems probable that ABL were engaged very late in the consultation process, though neither ALC nor PMC made this clear in their advice to the Minister. The Department expressed a minor concern that it appeared that the ALC had not confirmed that they had been advised of the proposed remuneration the Chair and CEO would receive from Winchelsea Mining and provided suggested correspondence seeking clarification. There was no general expression of concern as to the workability nor the wisdom of the conflict mitigation arrangements proposed by the ALC. As noted in Part One, the released documents do not include the signed copy of the brief nor a copy of the signed letter if it exists. The letter attached to the brief was (inappropriately in my view) excluded from the FOI release on the basis that it was a draft. The fact that the final letter has not been identified or released in response to the FOI request, and nor has a version of the ministerial submission with his annotations suggests that the Minister never sent the letter expressing the PMC concern to the ALC. In turn, this decision suggests that the Minister did not wish to ask for advice that he knew would reveal and document (and thus record his knowledge of) the extent of the financial benefits flowing to the two senior ALC officers from their dual roles.

Part of the implicit justification for the existence of these arrangements (see paragraphs 4 to 8 of the PMC brief) was that the AAAC Rule Book provides for the representation of the ALC Chair and CEO on the Winchelsea Board. This glosses over the fact that the ALC (or at least its key officeholders including Mr Hewitt and perhaps Mr Wurramarrba) assisted in the incorporation of AAAC in December 2017 with the specific purpose of taking over the extant exploration licence applications on Winchelsea Island and surrounding areas. Those officers included this provision in the AAAC Rule Book, thus establishing the potential conflict which they then ostensibly sought to mitigate.

Up until the death of the former Chair and the termination of Mr Hewitt in 2024, the two clans who are the traditional owners of Winchelsea Island and provide the entirety of the Directors of AAAC had no representation on the Winchelsea Mining Board of Directors notwithstanding that the AAAC theoretically controls Winchelsea through its 70 percent majority shareholding. This is yet another instance of the ALC exerting potential (and thus effective) control over a local corporation to which it has also provided s64(3) funding at its discretion.

The ALRA provides that once an exploration agreement is approved, the traditional owners cannot refuse to provide their consent to mining. However, it does require a mining agreement be negotiated by a land council and then approved by the Minister, but his/her ability to refuse consent at the mining lease stage is limited to a determination of inconsistency between the terms of the licence and proposed lease, and/or that the national interest requires refusal (refer s47(3) of ALRA). It follows that the consideration of the application for an Exploration License is in many respects much more consequential than the ministerial consideration of the proposed mining lease.

In the Brief to Minister Scullion in relation to the approval of the Exploration Licence agreement (Document A1, para 9) the Department fails to alert Minister Scullion to the implications of section 47 of ALRA. The brief states

The material provided by the ALC supports the assertion it has complied with its statutory obligations in these matters and the Department recommends you give the consent and approval requested.

Note the ambiguity in this sentence revolving around the words ‘supports the assertion’. The ALC supporting material outlines a rather bizarre consultation/negotiation process, outlining extensive meetings over six months or so in 2017 (see para 7.15) culminating in a majority (and perhaps unanimous) vote by a group of traditional owners of Winchelsea Island approving terms of a proposed exploration licence agreement to be negotiated with Winchelsea Mining which was yet to be established (see para 7.10; the nature of the vote has inexplicably been redacted on personal privacy grounds. This redaction may be intended to hide the small number of traditional owners who provided their consent). This was followed by a confirmatory meeting to confirm the decision of traditional owners at a meeting on 14 September 2018 attended by an un-named PMC officer and un-named Winchelsea Mining representatives (para 7.14). Whoever the Winchelsea representative was, there is no record of any constraint operating to prevent them subsequently identifying to the Chair and to Mr Hewitt any traditional owner who argued against the proposal. This is a significant flaw in the process. The ALC formally approved the exploration agreement on 10 September 2018, eleven months later. The extent to which the Winchelsea traditional owners were ‘as a group’ consulted on the final agreement is left unclear. The Chair and CEO absented themselves from the part of the ALC  meeting which considered the mining agreement and did not vote (see para 4.4). There is no indication that they had been absent from the consultations throughout 2017, and no indication that they had not been involved in Winchelsea’s framing the proposed approach to exploration (a matter that in theory may have been of concern to Winchelsea shareholders).

The issue of the addressing the potential conflict of interest of the ALC Chair and CEO by requiring that they not participate in the final meeting of the whole process has all the markings of being an afterthought. What is clear is that Minister Scullion in providing his approval for the exploration agreement implicitly confirms that he accepted the dual roles of the Chair and CEO on both the ALC and Winchelsea Mining. The Department, by virtue of recommending his approval without raising substantive concerns, did the same. The brief was copied to the Secretary and senior echelons of the Department of Prime Minister and Cabinet and to the Prime Minister’s Office. Based on my experience at senior levels of government over 30 years, I find it difficult to comprehend how in these circumstances such a brief could have been prepared and provided to a Minister, and inconceivable that a Minister who took his responsibilities seriously could have approved it.

The approval of the proposed mining agreement by Minister Wyatt was based on two briefs provided by NIAA in June and July 2021. They were based on consultations undertaken by the ALC extending from November 2020 through to March 2021. Documents B2, B3 and A10 refer.

The issue of conflict of interest (in contrast to the Exploration Agreement process discussed above) is dealt with in detail in the equivalent summary of the consultations outlined in Document A10. See the detailed processes put in place presumably on legal advice (see section 5). While those processes were orders of magnitude more comprehensive than what occurred at the Exploration Agreement phase, they did not relate to the provision of consent, and more importantly were to my mind seriously flawed and inadequate for the following reasons. All of these reasons also operate to undermine the legitimacy and probity of the decision processes on the exploration lease agreement.

First, their effective operation is limited to the formal engagements of the Chair and the CEO of the ALC with issues related to the proposed Winchelsea mine. Second, I understand that the then Chair’s spouse was on the Board of the ALC, and privy to all discussions about the agreement. Third, from 2018 through to 2024, the CEO’s spouse Sophie Liu was employed in the ALC Royalty Development Unit as well as Groote Holdings Aboriginal Corporation and Winchelsea Mining (link here) and was likely privy to agreement related information either formally or informally. Fourth, it seems highly likely that up to three AAAC Directors were also Directors of the ALC during the relevant period yet were not required to declare a potential conflict of interest. ALC Directors in March 2021 included Archie Jaragba, Lionel Jaragba, and Silas Bara all of whom had involvement in AAAC as members and Directors and were also potentially conflicted.

Adding some further heft to my critique, it is worth noting that the ANAO in its May 2023 Performance Audit (link here) was critical of some elements of the consultation processes related to the mine (see paras 3.74-3.76), including poor information on risks, poor record keeping and inadequate processes for updating traditional owners on changes subsequent to their approval. Consistent with its narrow focus on its remit, the ANAO did not consider let alone form a conclusion on the matters I have raised above and below.

Like Minister Scullion, Minister Wyatt implicitly acknowledged and accepted the dual roles for both the ALC Chair and CEO. As with Minister Scullion’s decision, it is difficult to conceive how a Minister charged with the responsibility to be satisfied that the land council has complied with its statutory responsibilities to protect the interests of traditional owners could approve a formal agreement infected with so many potential conflicts.

In relation to both Minister Scullion’s and Minister Wyatt’s approval processes the most fundamental potential conflict of interest went unacknowledged. The mitigations proposed in both cases to deal with the dual roles of the two statutory officeholders, inadequate as they were, applied only to the negotiations of the two agreements which required ministerial approvals. Yet the potential conflicts arising from their dual roles extended well beyond those processes, including to the subsequent approval of section 64(3) payments to Aboriginal corporations directed to mine related investments.

Neither Minister Scullion nor Minister Wyatt appeared to have given any consideration to the ongoing risks involved in these processes. It is unclear if the Department/NIAA ever provided advice to the two Ministers about this matter, but to date there has been no document released which suggested that they did. In any case, it was the Ministers who were ultimately responsible, and who failed to take the remedial action that would have prevented the apparent misallocation of those funds.

In my previous post The Angels Weep, I recounted advice to the Estimates Committee that suggests that in excess of $70m may have been misallocated by the ALC in supporting the proposed mine. The ANAO in its May 2023 Performance Audit of the ALC (link here) identified the risks of actual conflicts of interest arising from these dual roles as being high. It documents funding decisions by the ALC which overtly favoured applications sponsored by the CEO on behalf of GHAC and AAAC, corporations in which he was involved either directly or indirectly and which were focussed on supporting the proposed mine. See paras 4.45-4.50. But the ANAO stepped back from overt criticism of the CEO in relation to those risks perhaps in deference to the fact that both ministers had implicitly approved the dual role arrangements. The ANAO also documented the excessive costs and the potential conflicts of the Chair of the ALC Audit and Risk Committee but stepped back from overt criticism of either the accounting firm involved or the ALC CEO who oversaw the appointments and the apparently excessive payments involved. In my view the ANAO was unduly cautious; it identified the dots, but declined to connect them, an approach that allowed the Minister and NIAA to fudge the import of the ANAO report and thus facilitate the persistence of the status quo ante within the ALC for over a year.

Following the ANAO audit, one might have expected Minister Burney to reconsider the approach adopted by her two predecessors and initiate robust action to improve governance oversight of the ALC. Instead, as documented in many of my previous posts, she prevaricated and fudged the issues and so has Minister McCarthy (who was an Assistant Minister in the portfolio during Minister Burney’s tenure). In my recent post ANAO financial audits and the case for ALRA reform, I suggested the existence of

a deeper malaise characterised by ongoing and increasing financial risk, and the possibility of wider social consequences that are not visible through the lenses used by governments and their bureaucracies. In my view, that malaise extends to the absence of effective regulation by successive ministers and their agency, NIAA. 

The documents now released under FOI serve to reinforce these conclusions, and make crystal clear that former Ministers have made egregiously poor policy decisions that appear at best to amount to maladministration and which are at the root of the governance failures which have pervaded the ALC. The evidence embedded in the documents released so far suggest that PMC and NIAA failed dismally in providing Ministers with both forthright and high-quality advice. It was only after a scathing media story based on information from an ALC whistleblower identified an attempt by Mr Hewitt to be granted a substantial equity share in Winchelsea Mining, that the NIAA (presumably instructed by the Minister) referred the matter to the NACC for investigation. Since October 2024 when Mr Hewitt was terminated, there has been a revolving cascade of changes at the senior levels of the ALC.

As I write this, the ALC Annual Report for 2025 due at the end of October 2025 is not yet available, the AAAC financial reports for 2024 and 2025 have not been published as required by the CATSI Act, and there have been no filings to ASIC by Winchelsea Mining Pty Ltd since 2024. ORIC have an investigation underway into GHAC but have not provided any reasons for why they are taking this action. The ALC appear to have stepped away from their commitment to assist these corporations representing traditional owners and which was the rationale they provided to Senate Estimates to justify their intense involvement in the Winchelsea mine proposal. And of course, some two years since complaints were first made to it, the National Anti-Corruption Commission is still considering whether to issue a report in relation to matters related to the operation of the ALC on Groote. Notwithstanding all this, the last two Senate Estimates Hearings have allocated negligible time to ALC issues. 

There are two elephants in the room which no-one with formal oversight responsibilities wishes to acknowledge, let alone discuss. The first is that the problems emanating from the potential conflicts of interest involved not just Mr Hewitt, but the former Chair Mr Wurramarrba, and potentially extended to numerous other individuals beyond those two. Moreover, in terms of their formal decisions, the ALC Board were fully supportive of the strategies being pursued by the Chair and the CEO from the beginning until Mr Hewitt decided, a month before his termination from all roles on the Groote Eylandt, to offer to resign as CEO to allow him to focus on the operations of Winchelsea Mining. In this respect, there are logically two possibilities: that the ALC Board members were effectively manipulated by the architects of the Winchelsea mine proposal to provide the ongoing formal support required; or, the ALC Board was fully committed to the strategy of developing the mine based on their independent and considered assessment, a strategy that they suddenly reversed without explanation at a potential cost in excess of $70m to the traditional owners of Groote. Neither option is attractive to contemplate, but it requires contemplation and consideration if the reforms necessary to ensure the current problems and recent mistakes will not be repeated and the necessary reforms are identified and put in place. My basic point is that the responsibility for whatever adverse findings and adverse outcomes emerge over the next few years cannot be laid solely at the feet of one individual, the former CEO Mr Hewitt. The issues within the ALC extend beyond one individual.

The second, and more significant elephant in the room is that successive Ministers have made egregious policy errors which in my view amount at best to maladministration and which have led to disastrous outcomes for the residents and traditional owners of Groote Eylandt. Again, whether the Ministers were merely incompetent and poorly advised, or were disposed to prioritise political advantage over the public interest is unclear. Without full transparency, concerned citizens and taxpayers cannot form a judgment. Whichever reason applies, citizens and the traditional owners of Groote Eylandt (as well as the wider Australian public) have a right to expect better.

It is significant that it has taken eight years for the documentary evidence of direct ministerial involvement in, and knowledge of, these conflicted roles within a Commonwealth statutory corporation to emerge into the public domain. Remember, this is a statutory corporation with responsibilities for the protection of traditional owner interests and the allocation of millions of dollars in compensatory financial benefits related to existing mining operations. Throughout this period, and continuing to the present day, ministers and governments have deliberately attempted to obfuscate and distract attention. The continuation of efforts to avoid transparency merely serve to raise further questions about what drove the initial decisions and continues to drive the inability to lay myriad unanswered questions to rest.

In my view, the Commonwealth has both an obligation and a long-term incentive to establish a necessarily independent and wide-rangeing investigation process that will allow such a comprehensive consideration to occur. While determining whether corrupt conduct has taken place is important, it is not necessarily the remit of the NACC to expiscate the broader systemic issues that have allowed the significant misallocation of funds appropriated by the Parliament for the benefit of traditional owners, and they may well decide not to do so. If that occurs, at least three years will have been wasted. The establishment and subsequent handling by NIAA of the previous investigation undertaken by Bellchambers Barrett avoided the issues related to the potential misallocation of funds and gave no consideration to the conduct of agencies and ministers; consequently, it was deliberately designed as a diversion, and has undermined the credibility of the recent ministers within the Indigenous Australians portfolio.

In any case, the ongoing failure to address the underlying causes of the myriad policy challenges facing the ALC will mean that the responsibility for the egregious policy errors that have torn the ALC apart and set back the aspirations and life-opportunities available to the Anindilyakwa people will continue to taint the operation of the ALRA, and the legitimacy of governments and their officials.  

The ALC have recently appointed their fourth acting or permanent CEO in less than two years. Without reflecting in any way on the new CEO’s capacity and ability, I believe the structural forces that have been in play, and which likely continue to operate, are such as to make the prospects of him delivering or oversighting sustained reform well-nigh impossible.

For the Commonwealth, and in particular the Minister for Finance who has responsibility for the Public Governance, Performance and Accountability Act 2013 (PGPA), the continuing challenges facing the ALC represent a test case for the robustness and effectiveness of the whole system of Commonwealth public sector administration. If the ALC were a local government in any jurisdiction in Australia, it would be facing the prospect of an Administrator being appointed. In my view, strong grounds exist for the Prime Minister to request the Minister for Finance to step in and make arrangements for the direct oversight the operations of the ALC for the next three years or so to ensure that there is a sustained return to complete compliance with the ALRA and the PGPA. Such a step would have the additional benefit of providing the Government with an independent perspective on desirable systemic reforms to the financial architecture underpinning the ALRA more generally and create the foundations to underpin the reforms that are required to ensure that the ALRA survives another fifty years. Without robust and decisive action by Canberra, the prospects of the ALC avoiding a governance meltdown over the coming five years will be close to zero. If this occurs, the reputation and legitimacy of the Commonwealth public sector will suffer yet a further body blow.

Whichever course is chosen, the challenges ahead for both the people of Groote Eylandt and the Commonwealth public sector will be formidable.

 

29 March 2026

Formidable Challenges Part One: The Commonwealth approvals process for the Winchelsea mine

 

O, what may man within him hide, though angel on the outward side!

Measure for Measure, Act two, Scene four

 

Under the Aboriginal Land Rights (Northern Territory) Act 1976 (ALRA), Land Councils whose primary statutory responsibility is to protect the interests of Traditional owners, have responsibility for managing negotiations over consent and the terms of any mining. Additionally, Ministers have explicit responsibility to approve key elements of any negotiated arrangements in addition to their overarching responsibility to ensure accountability for agencies within their portfolio to the Parliament and thus the public.

The NIAA has now released in accordance with the Freedom of Information Act 1982 (FOI Act) (link here) an updated version of a request for documents related to approvals by Commonwealth ministers under the Aboriginal Land Rights (Northern Territory) Act 1976 (ALRA) related to the proposed manganese mine on Akwamburrkba (Winchelsea Island) by Winchelsea Mining. The initial tranche of documents was released on 24 December 2025, and following a request for an Internal Review, an updated tranche of documents has recently been released. The documents released after the Internal Review are available on the NIAA FOI log and listed under FOI reference number FOI/2526/013IR.

Three documents within the scope of the initial request but not assessed in the initial release process have also been released under a separate FOI request (link here) and are available on the NIAA FOI Log under reference number FOI/2526/031.

The analysis below and the following post amalgamates both sets of documents. References to documents in the first tranche are identified as Document A#, and those in the second tranche as Document B#.

The released documents provide a comprehensive, but perhaps still incomplete account of the Commonwealth approval processes related to the fact that the proposed mine is on Aboriginal land which comes within the ambit of the Anindilyakwa Land Council based on Groote Eylandt in the NT.

This post comprises Part One of an analysis of the documents released under FOI and constructs a summary chronology of the salient events related to the Commonwealth side of the approval processes related to the proposal for the establishment of the proposed Winchelsea mine. A second post to follow will focus on analysing the major implications arising from the release of these documents, particularly focussing on the complex issues related to potential conflict of interest arising from the highly unusual governance structures adopted by the ALC in relation to the proposed mine.

Winchelsea Approval Summary Chronology

Ø  On 10 October 2017, the ALC wrote to Minister Scullion and NT Resources Minister Vowles updating them on the proposed Winchelsea project. This letter was not identified by NIAA in their FOI searches and thus is yet to be released. It is unclear whether this correspondence dealt with the issue of the proposed dual roles of the ALC Chair and CEO. This correspondence is mentioned in Document B1 at para 22 of Attachment B.

Ø  On 15 August 2018, the ALC wrote (in a letter jointly signed by Chair Tony Wurramarrba and ALC CEO Mark Hewitt) to the Minister to provide a further update (refer Document B1 Attachment B). This correspondence is important as it outlines for the first time (based on currently available information) the proposal for the ALC Chair and CEO to undertake dual roles within both the ALC and Winchelsea Mining. It also mentions a shareholders agreement between AAAC, Aus China and somewhat strangely Winchelsea Mining in its own right (at this point informally controlled by its two ALC associated Directors) and the existence within that agreement of a ‘fall back provision’ which deals with the possibility that AAAC equity in Winchelsea Mining may be reduced in the future.

Ø  On 6 September 2018, the ALC provided a further update to Minister Scullion (again jointly signed). Refer Document B1 Attachment D. This correspondence outlines in some detail the steps taken to mitigate the impact of the potential conflicts of interest arsing from the dual roles of the ALC Chair and CEO. The letter mentions the involvement of Melbourne law firm Arnold Bloch Liebler (ABL) and mentions the recommendations of the Independent Chair of the ALC Audit Committee. In neither case was there any reference to potential conflicts of interest which may have related to the consultancy work of either ABL or Enmark (the accounting firm owned by the Audit Committee Chair). Both these firms have been engaged by the ALC and/or ALC associated corporations in receipt of section 64(3) payments beyond their advice here. The accuracy of the Audit Committee Chair’s advice to the ALC is questionable (see para 16 (d)).

Ø  On 13 September 2018 the ALC wrote to Minister Scullion, NT Minister for Resources Ken Vowles, and Mr Dongfang Yu, Co-CEO of Winchelsea Mining notifying them that the Land Council had on 10 September consented to the grant of the relevant Exploration Licence under s.42 of the ALRA. Refer to Document A2.

Ø  On 18 September 2018, PMC provided a brief to Minister Scullion recommending he note the information provided by the ALC in the two previous letters and providing a draft reply which recommended he seek further information related to the remuneration of Mr Wurramarrba and Mr Hewitt related to their dual roles in the ALC and Winchelsea Mining. (see paragraph 9). As the released document is unsigned, it is unclear if the Minister noted the brief and sent the letter; he may have amended the letter (which in any case has not yet been released by NIAA). Refer Document B1.

Ø  On 12 October 2018, Minister Scullion consented to the grant of an Exploration License to Winchelsea Mining and approved the ALC entering into the Winchelsea Island Exploration Agreement. In doing so he explicitly agreed that he was satisfied that the ALC had complied with its statutory obligations under the ALRA. Documents A1 to A5 refer.

Ø  On 14 July 2020, the CEO of the NT Department of Primary Industry and Resources wrote to the Minister Wyatt supporting the Winchelsea project and mentioning the desire of AusChina International (then holding 40 percent ownership in Winchelsea Mining) to divest their shares in the joint venture, thus providing in his words ‘a significant opportunity for AAAC [the holders of 60 percent equity in Winchelsea Mining] to significantly increase their investment should they be able to access appropriate financing arrangements’. Document A6 refers.

Ø  On 16 April 2021, Mr Hewitt as CEO of Winchelsea Mining wrote to Minister Wyatt and the NT Minister for Mining regarding the nature of proposed works for the mine. Document A7 refers.

Ø  On 13 May 2021, NT Minister for Mining and Industry, Nicole Manison wrote to Minister Wyatt confirming that she had considered (under delegation from the Commonwealth) the proposal for the grant of a mining lease and as it was consistent with the previously approved Exploration License, she was required by the provisions of ALRA to grant the lease. She added a handwritten annotation: ‘A very exciting project!’ Refer Document B2 Attachment B.

Ø  On 18 June 2021, NIAA provided a brief to Minister Wyatt recommending he confirm that the national interest provision of the ALRA mining regime does not apply to the Winchelsea proposal, thus clearing the final hurdle for the grant of a mining lease by NT Minister Manison. Document B2.

Ø  On 30 June 2021, Minister Wyatt provided his consent under s47 of the ALRA. This is a precondition to the consideration of the Mining Agreement. The substantive content of the determinations is not evident from the documents released. Document A8 refers.

Ø  On 30 June 2021, an official of the ALC (either the then Chair or the Mining Manager; the name has been redacted) emailed the Minister requesting his approval of the Winchelsea Island Mining Agreement. Documents A9 and A10 refer.

Ø  On 20 July 2021, the NIAA briefed Minister Wyatt recommending he agree that he is satisfied that the ALC has complied with its statutory obligations in seeking consent and approval for the grant of the relevant Mineral Lease to Winchelsea Mining and providing consent to the ALC to enter into the related Mining Agreement.

Ø  On 2 August 2021, Minister Wyatt accepted the NIAA recommendations that the ALC had complied with its statutory obligations and that he should consent to the grant of the Mineral Lease and to the ALC entering into the Mining Agreement. Document B3 refers. Minister Wyatt also wrote to the ALC (presumably the Chair, but perhaps the Mining Manager) and the NT Mining Minister advising his approval of the proposed Mining Agreement. He also wrote to Mr Hewitt, a Director of Winchelsea Mining advising Winchelsea that he has given his consent to the mining agreement. Documents A11, A12 and A13 refer.

Ø  On 2 November 2022, a representative of CDM Smith, an environmental consulting firm wrote to Minister Burney updating her on the ongoing consultations with relevant stakeholders regarding the preparation of the EIS for the project. Documents A14 and A15 refer.

Ø  On 28 February 2023, Minister Burney responded to CDM Smith noting the consultation process, and noting that royalties for the project are proposed to replace royalties from the existing GEMCO mine which is expected to cease operations within five years. She also noted that AAAC ‘ownership of the mine’ [sic: of the joint venture company Winchelsea Mining] has increased to 70 percent. Document A16 refers.

Ø  On 23 August 2024 the Chair of the ALC wrote to Minister McCarthy seeking additional funding for a range of projects due to the cessation of s64(3) payments arising from the impact of Cyclone Megan on GEMCO operations. Document A17 refers.

Ø  On 30 January 2025 [five months later!] the Minister responded to the ALC Chair politely refusing her request and redirecting her elsewhere. Document A18 refers.

 

Reflections on transparency and accountability

I am cognisant that very few readers will have the time or inclination to read the chronology outlined above and cross reference or access the actual documents. I have included it nevertheless to demonstrate the significance and extensiveness of the engagement between the ALC and the Commonwealth (PMC and NIAA). Yet over that period there were no ministerial media releases by the Commonwealth related to the development of the mine. There was a highly curated public relations narrative on the ALC web site, but minimal attempt to provide the transparency one might expect from a Commonwealth agency. There remain unanswered questions.

The transparency and accountability issues related to the proposed mine arising from the direct involvement of Commonwealth Ministers over the period from 2017 to the present, and which are embedded and identified in the documents released under FOI discussed in this post have not previously been disclosed. Moreover, they are extremely unlikely to have seen the light of day except for the existence of the FOI Act. The Executive dominance over the Parliament and an apparent consensus shared by both ALP and LNP that any exposure of the issues involved would be politically harmful has meant that the Senate Estimates process since 2017 and particularly since 2023 when the ANAO performance report on the ALC was tabled has failed to consistently ask and follow up the hard questions (link here).

The ALC Annual Reports which are required by the Public Governance, Performance and Accountability Act 2013 (PGPA Act) and PGPA Rule 2014 identify a range of high-level requirements for Annual Reports including audited financial statements, annual performance statements, a significant issues report, and governance structures. Agency Annual Reports are provided to and approved by the portfolio minister for tabling in Parliament. Yet over the period since 2017, neither the portfolio agencies (PMC and NIAA) nor any portfolio minister ever took action to ensure core information regarding the potential conflicts embedded in the dual employment relationships of the ALC Chair and CEO were included in the ALC Annual Reports notwithstanding that they were all aware of the existence of these issues.

Along with ensuring a wet blanket was placed over successive Senate Estimates discussions and failing to ensure that ALC Annual reports were fully transparent, the current ALP Government has pursued a determined and ongoing strategy to distract and obscure attention related to the accountability issues on Groote. This has been aimed at downplaying the knowledge and involvement of Commonwealth Ministers and their agencies in facilitating the development of the Winchelsea Mining proposal and in oversighting the (mis)use of section 64(3) funds intended to benefit Aboriginal people on Groote for mine related purposes. This strategy included the refusal to investigate the underlying issues raised in the 2023 ANAO performance audit of the ALC (link here) instead engaging a consultancy firm to review the implementation of the ANAO recommendations. As I have previously pointed out, that review was far from independent despite NAIA claims to the contrary (link here).

Following a media story in the SMH and Age by investigative reporter Nick McKenzie sourced to an ALC whistle-blower which alleged that the former CEO was seeking to be granted up to ten percent equity in Winchelsea Mining by AAAC, the NIAA (presumably with the Minister’s approval) referred the matter to the National Anti-Corruption Commmission. The NIAA then (again almost certainly with the knowledge of the Minister or her Office) directly injected itself into internal ALC affairs and played a prime role in the meeting of the ALC (without any ALC staff present) where the ALC Board terminated the former CEO Mr Hewitt (link here). One might surmise that the foundation is being laid to place the primary blame on the former CEO for any maladministration that may be found to have occurred by the NACC. Such a framing would in my view be deeply dishonest and would be extremely problematic insofar as it would necessarily leave deeper systemic accountability shortcomings (that apply well beyond the ALC) unaddressed.

While the documents released under FOI reveal the extent to which potential conflicts of interest were embedded within the ALC and its associated corporations funded under s64(3) of ALRA, they do not shed light on the deeper reasons governments since 2017 have been determined to turn a blind eye. That is a matter that will hopefully emerge from the shadows over the course of the next year or so.

In the second part of this post, I seek to explore in greater detail the extent to which the potential conflicts of interest embedded within the processes described the documents released under FOI were created and granted legitimacy.

 

29 March 2026