Wednesday 15 November 2023

Silent dissemblance: discussion of the ANAO report on the ALC in Estimates

Smooth runs the water where the brook is deep

2 Henry VI, Act three, Scene one.

 

I thought it might be worthwhile to have a quick look at the most recent Estimates Hearings related to the Indigenous portfolio. Held on Friday 27 October (link here), the hearings were predictably anodyne. I am not seeking to provide a comprehensive overview but thought I would focus on just a few issues that struck me as significant (albeit under-appreciated). In particular, the transcript is interesting for two reasons: first, for the issues that were avoided during the questioning; and second, for what it tells us about the approach of the various committee members.

 

Unsurprisingly, the dominant presence during the hearings was the Oppositions spokesperson on Indigenous Australians, Senator Nampijinpa Price.  She appeared to have two main objectives. The first was to pursue the extent of the involvement of various agency and statutory corporation staff appearing before her in supporting the Yes case in the recent referendum. Her efforts on this front failed to strike the gold she perhaps was searching for, but the insistence of her efforts, and the recourse of those being interrogated to providing answers later ‘on notice’ left an impression that at least in some instances some unspecified red line had been inappropriately crossed. The second objective was to seek out information and further detail on a range of presumed accountability failures. Here I suspect her intent was to lay the groundwork for a future political attack on the government for the lack of accountability in the Indigenous sector. Interestingly, her focus was wide and shallow rather than deep and narrow, and overwhelmingly focussed on the Northern Territory, which happens to be her own constituency. In other words, she appears to be laying down the outline and precursors for a future political campaign directed towards reinforcing the longstanding predispositions of her non-Indigenous constituents.

 

There were two meta-issues that struck me as particularly significant insofar as they are almost certain to have substantial policy and financial implications into the future but were almost completely ignored or avoided by the committee in its questioning.

 

The first relates to the ANAO audit of the four NT land councils. The second issue raised only tangentially during the Hearing relates to the preparations for the divestment of the Ayers Rock Resort by the ILSC. This second matter is slightly complex and speculative, so I shall deal with it in a future post.

 

Turning to the ANAO, all four land councils were called to appear before the Estimates Committee. Questions from Senator Price covered their support for the referendum and issues raised by the ANAO audit recommendations, including governance shortcomings, and progress on section 19 lease approvals (an issue that plays into deeper conservative beliefs regarding the constraints on economic development arising from communal and inalienable title). Labor Senator Sheldon asked the land councils about their respective processes of membership selection (a matter also raised in the ANAO reports, but without identifying major concerns). Pages 39 to 45 of the transcript cover Senator Price’s pursuit of the NLC, the TLC and the CLC in relation to various technical recommendations of the ANAO in relation to their fraud control policies and conflict of interest policies not being up to scratch. What a close reading of the transcript reveals however is that Senator Price neglected to raise the issues of actual conflicts of interest and various other shortcomings identified by the ANAO in relation to the management of the Anindilyakwa Land Council.

 

Senator Price also went out of her way to raise the land council audits when the ANAO appeared before the Senate Finance and Public Administration Legislation committee on 24 October (link here). Again, she raised a series of technical issues relating to the NLC, and at the end of the session as time was running out, went out of her way to state that she had extra questions:

…I would like to have the opportunity to ask all the questions that are before me – they are obviously very important – with regard to all of the land councils within the Northern Territory.

 

She had that opportunity later in the week in the Cross-portfolio hearing, but didn’t raise any substantive issues relating to the ALC. It was almost as if, to use a rugby term, she was running interference for the ALC.

 

Avid readers of this blog may recall that in June and August of this year I published three separate posts reviewing the ANAO audits (link here and link here and link here). In my last post, I provided the following high-level assessment of the impact of the audits for the land councils:

The overall picture has been positive, although the ANAO findings in relation to the ALC in particular are in my view extraordinary and of serious concern. In relation to the ALC audit, we are yet to see any formal or public response by Minister Burney nor NIAA, though one hopes that action is underway behind the scenes.

 

My post dated 1 June 2023 (link here) had recounted quite significant and disturbing ANAO findings within the Anindilyakwa Land Council’s governance structure. Shortcomings which — in theory — could be utilised to facilitate actual fraud and mismanagement. To be clear, the ANAO did not identify any instances of fraud or financial mismanagement. Of much more significance was the ANAO analysis which identified a complex array of related corporations which while technically and legally independent of the ALC have substantial overlap in terms of senior management involvement. The result is that they are effectively either controlled or influenced by the senior management of the land council and are both the recipient of substantial benefits and investments emanating from the land council and yet outside the purview of the ANAO as they were private companies. See figure 4.1 of the ANAO report at page 68 (link here) although this diagram does not include the revenue streams related to the two private trusts referenced below. The financial flows involved are significant, especially when extended into the medium term.

 

The NIAA annual report reports payments to the ALC of $59m in 2022-23 for distribution to royalty associations representing traditional owners. Over say ten years, the amounts involved would be extraordinary, likely totalling around half a billion dollars. In addition, the ALC document Invested in our Future (link here) indicates that there are two further trusts established to receive negotiated royalties arising from mining agreements with GEMCO. That document suggests that these two trusts had a balance of $262m in 2020, and expect to receive a further $370m, in future royalties and interest payments over the decade to 2030. This takes total royalty and associated revenues flowing into Groote to around a billion dollars over the coming decade.

 

Given the quantum of funds flowing to Groote, the potential consequences of risks such as fraud, or mismanagement, or commercial loss for ALC constituents arising from poor due diligence of commercial development proposals are orders of magnitude higher than those related to the mere (mis)use of Commonwealth funds appropriated for the operations of land councils. Yet all these risks can be traced back to institutional arrangements established by, and theoretically overseen by, the Commonwealth. In a worst-case scenario, were significant royalties and other monies to be diverted away from the intended beneficiaries utilising complex private rather than public governance structures, the Commonwealth would be unlikely to escape legal and fiduciary responsibility, as well as significant political responsibility. Yet neither the Government nor the Opposition are focussed on addressing the issue of potential risks.

 

A major contributing factor to this short-sightedness is that there are a plethora of Commonwealth (and NT) regulatory oversight agencies each looking at a slice of the total picture: the NIAA, ORIC, ASIC, AFP, NT Police, the NACC, and the ANAO each have potential roles in oversighting elements of the financial structures in play on Groote. The ANAO adopts an extraordinarily narrow view of its responsibilities, notwithstanding it is purporting to undertake ‘performance’ audits. In his evidence to the Estimates Committee on 24 October at page 135 (link here), the Auditor General laid out in detail his overly narrow approach to his job, in effect leaving it to other agencies to investigate suspicions of fraud and indicating that his legislative remit does not extend to non-government entities. This is a matter I have argued, in my post dated 17 August 2023 (link here), that requires both more adventurousness by the ANAO and probably legislative reform.

 

What is missing is any oversight agency with a remit to undertake a wholistic risk assessment of these royalty flows. Moreover, the issues related to financial risk on Groote are replicated at probably ten other mine sites across the nation, mostly in WA.

 

Conclusion: an action agenda

It strikes me as more than strange that neither the Government nor the Opposition are prepared to initiate an open discussion about the financial risks and implications arising from the ANAO’s narrow and minimalist findings into the ALC. Clearly there are multiple angles with potential political implications: a Commonwealth entity facilitating direct Aboriginal investments into a joint mining venture with a privately owned company (AUS China International Mining Pty Ltd) with limited resource development experience; potential environmental issues related to strip mining of manganese and the associated infrastructure on Winchelsea Island and the northern coast of Groote Eylandt; an extraordinarily ambitious development agenda for Groote Eylandt apparently endorsed by the NT Government’s Local Decision-making Framework (link here) and supplemented by slick marketing and PR most evident in the 2022 document on the ALC website Invested in our Future  (link here) [note the caveat at the end of this document];  a commercial and administrative presence in Darwin and Cairns (link here); and not least the paradox of poverty and dysfunction amongst revenue plenty (link here [see data point two] and link here).

 

These risks are balanced against the important focus on building a sustainable fund to underpin the future viability of the Groote economy outlined in the document Invested in our Future on the ALC web site. The plan to establish a perpetual fund to provide an income stream to Anindilyakwa people post mining has real merit, although it is unclear how robust the estimates are and why the focus is limited purely to the negotiated royalty streams and not the statutory royalties. However if significant risks eventuate, they will threaten the viability of creating a sustainable future fund for Groote people. This is why the issues raised in this post are so important and demand policymakers; attention.

 

There are also serious management questions that are worth asking. For example, the ALC CEO who received $419k in total remuneration in 2021-22 is also listed as the Transition Manager of Groote Holdings Aboriginal Corporation (GHAC) in the 2022 document on the ALC website Invested in our Future. That document lays out the extraordinarily ambitious development agenda being pursued by the ALC and its associated entities. The ALC 2021-22 Annual Report (link here) (page 125) lists the CEO as both a Director of GHAC and also a Director of Winchelsea Mining. The ANAO in figure 4.1 (page 68) (link here) go out of their way to make clear that not only is the ALC CEO a Director of GHAC and Winchelsea, but his spouse is the Chief Operating Officer of GHAC and an Executive Assistant within Winchelsea. Moreover, ENMARK the company providing the Chair of the ALC Audit Committee is also responsible for governance and accounts in GHAC (see page 34 of Invested in our Future). As the ANAO said in para 4.46:

4.46 AAAC holds 60 per cent of the shares in Winchelsea Mining, and GHAC will own the Little Paradise logistics base assets being developed to support the Winchelsea Mining venture (see paragraph 1.29). Figure 4.1 shows the directorships and senior positions of, and main financial flows between, the ALC, AAAC, GHAC and Winchelsea Mining. The figure shows that the ALC Chair and CEO have interests in GHAC and Winchelsea Mining, either as Chair, CEO or director.

 

Setting aside the question of whether the ALC CEO ( a full time position) is being paid additional remuneration by GHAC and/or Winchelsea, there remains the question whether the Land Council (a complex organisation with a range of governance challenges as identified by the ANAO) is getting adequate attention from its CEO given these competing responsibilities.

 

As an aside, the effectiveness of the Estimates Committee (and the currency of this post) has not been helped by the fact that, contrary to the Department of Finance guidelines, the 2022-23 Annual Reports for the four NT land councils are yet to be tabled (as of 14 November) notwithstanding that the expected date for tabling is in advance of the October estimates hearings. This is a matter that falls within the responsibility of the portfolio minister, and which deserves an explanation. Neither the Government members, the NIAA, the land councils, nor the Opposition or Greens commented on the absence of these reports in the Estimates transcript.

 

The avoidance of any questions to the ALC by the Opposition, and the apparent inaction of the Government following the ANAO report, serve to add weight to the view that all is not what it might seem in relation to the commercial development agenda of the ALC on Groote, and the relationship between the ALC and government in both the NT and Canberra. Moreover, this silence only heightens the questions relating to the quality of the overall management and allocation of the ALC’s extraordinary royalty revenues, and the concomitant risks.

 

Whether or not there is maladministration or worse is not the point. The real issue is that the current policy frameworks in relation to royalty management, commercial development and social services delivery are contributing to a much more fluid and complex policy environment. In turn this is throwing up new challenges and opportunities, including ensuring that the essential oversight of corporate activities are fit for purpose. Addressing the economic, social and commercial challenges at Groote, and grasping the opportunities in ways that are able to be sustained and grow, will require strong management and governance. The success or failure of these efforts will have real world implications for the people resident on Groote. The existence of substantial royalty flows, and the financial implications and significant commercial risks of the current ALC strategy, merely reinforce this point.

 

A close reading of the ANAO report suggests that they had serious concerns but lacked the forthrightness to make their concerns clear. Their recommendations were anodyne. Their remit, and thus their recommendations are limited insofar as they are directed only to the ALC and do not address the issues being pursued by the ALC’s associated entities. Notwithstanding the excellent work of their audit team, the ANAO senior management appear to have baulked at the last hurdle.

 

I am sure that within NIAA, there is an appreciation of the risks of a substantial and monumental policy failure in relation to royalty management on Groote. They too have a responsibility to provide the Minister with forthright advice. Following the robodebt debacle, the possibility (however remote) of a Royal Commission at some point in the coming decade should be front of mind for public servants advising the Minister on these issues.

 

And the Opposition shadow on Indigenous Australians also has a responsibility to focus on these issues. It seems to me highly unlikely that she is unaware of at least some of the issues on Groote. Whatever her motivation for avoiding asking the hard questions in the recent estimates committee, she would be wise to get on the front foot and play a constructive role in shaping effective policy outcomes going forward. In our democratic system of government, the role of the Opposition is not merely to criticise the Government (important as that is), but to play a part in ensuring that policy outcomes are effective and in the public interest.

 

Given the magnitude of the economic and political risks, and the adverse social consequences if those risks come to pass for the Groote populace, it would be smart if the Minister for Indigenous Australians were to initiate an independent and wide ranging inquiry into the current developments at Groote. If all is well, there is no downside to pursuing such a course, and it will expand trust in the judgment and probity of the policymakers involved, and send a clear signal to future leaders and managers that their policy choices need t be robust and well directed. If all is not well, then the sooner we identify the issues and address them the better. Doing nothing and acting as if there is nothing worth examining in relation to Groote would be both irresponsible and short-sighted.

 

A second action worth initiating would be for NIAA to develop (ideally in conjunction with Treasury and Finance) advice on policy options to ensure better and more coordinated regulatory oversight of the increasingly complex Indigenous commercial development policy domain. The absence of regulatory coordination exacerbates the likelihood of a major commercial and financial disasters particularly where royalties and native title payments are substantial. Indigenous citizens are more vulnerable to the impacts fo such occurrences than other Australians.

 

15 November 2023

 

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