Customs Reform Board First Report June 2013 Letter of transmittal 26 June 2013 Minister for Home Affairs and Justice Dear Minister Customs Reform Board’s First Report I am pleased to present to you the Customs Reform Board’s First Report on the Australian Customs and Border Protection Service (ACBPS). In developing this report, the Board worked collaboratively, informed by their experience in the integrity, law enforcement and business sectors, to undertake a holistic review of reform to the ACBPS. In the Board’s view, there is a clear need for Service-wide reform if the ACBPS is to keep pace with the accelerating evolution of the border environment while meeting Government and community expectations. The Board is confident that the ACBPS is on the correct path to reform. There is still much to do in planning and then implementing reform, while success will be heavily dependent on implementation and ongoing effective staff engagement. The Board wishes to thank the ACBPS, the Australian Federal Police, the Australian Commission for Law Enforcement Integrity, and other government and non-government stakeholders who participated in consultations. Their cooperation and assistance were greatly appreciated. In undertaking this report, the Board was supported by a secretariat from the Attorney-General’s Department. The Board thanks the secretariat members, and in particular, Mr Rohan Verco, for their commitment and professionalism. The Board welcomes the opportunity to contribute to the important transformation of the ACBPS. The Board trusts that this Report will assist in your deliberations. 2|Page Roger Wilkins AO Chair James Wood AO, QC Ken Moroney AO, APM David Mortimer AO Contents Letter of transmittal ................................................................................................................................ 2 Executive summary ................................................................................................................................. 4 1. Formation and role of the Customs Reform Board ......................................................................... 5 2. Methodology of the Customs Reform Board .................................................................................. 6 3. Identified challenges facing ACBPS ................................................................................................. 8 3.1. 4. Board observations on the ACBPS response to identified challenges ................................... 9 Board-identified ‘key issues’ for ACBPS consideration ................................................................. 11 4.1. Core considerations specific to change management and reform implementation ............ 11 4.1.1 Strong and united leadership ........................................................................................ 11 4.1.2 Effective communication and staff engagement .......................................................... 11 4.2. Considerations specific to the ACBPS Blueprint for Reform ................................................. 12 4.2.1 The ACBPS People and Operating Model: A professional and agile Service that is adaptive to change ........................................................................................................................ 12 4.2.2 Modernisation: Efficient business systems, streamlined processes and sophisticated intelligence .................................................................................................................................... 12 4.2.3 5. Integrity: A Service culture hardened against corruption.............................................. 13 Conclusion ..................................................................................................................................... 15 Appendix A: Terms of Reference ........................................................................................................... 16 Appendix B: Customs Reform Board Meeting Schedule ....................................................................... 18 3|Page Executive summary In response to the need for major structural and cultural reform of the Australian Customs and Border Protection Service (ACBPS or the Service), the Customs Reform Board (the Board) was tasked to advise the Minister for Home Affairs and Justice on strategic reform of the ACBPS and to help drive the implementation of reforms already introduced. The Board undertook a holistic review of reform of the ACBPS which consisted of three key elements: extensive stakeholder consultation across government and industry, operational familiarisation, and a review of ACBPS policy and strategic documentation. The Board concludes that there is a strong need for Service-wide reform if the ACBPS is to keep pace with the accelerating evolution of the border environment, while meeting Government and community expectations around trade and travel facilitation, as well as border management and protection. The Board is confident that the ACBPS is on the correct path to reform, and strongly supports the ACBPS’ second phase of reform articulated in its Blueprint for Reform: 2013 - 2018 (Blueprint for Reform). In the Board’s view, one of the biggest challenges the ACBPS will have is the successful implementation and integration of the reforms into its everyday business. Meeting this challenge will require strong, effective and professional leadership at all levels and a commitment to ongoing staff engagement and effective change management. 4|Page 1. Formation and role of the Customs Reform Board The Minister for Home Affairs and Justice established the Customs Reform Board on 20 December 2012 in response to the need for major structural and cultural reform of the ACBPS. The Board has been tasked to advise the Minister on the strategic reform of the ACBPS, and to help drive the implementation of reforms already introduced. Specifically, the Board’s Terms of Reference provide the following: • • • • improving the business operations, law enforcement and integrity culture of the ACBPS embedding an improved culture of professionalism, collaboration, innovation and adaptability within the ACBPS operational, administrative and legislative changes required to support the reforms; and any other relevant matters. Notwithstanding the broad remit of the terms of reference, addressing the corruption and integrity issues faced by ACBPS has been the primary focus of the Board to date given the high potential for damage caused by corruption. Accordingly, the observations contained within this report are directed towards these issues. This is not to say that other issues such as collaboration, innovation and adaptability are not important. The Board supports the initial direction the ACBPS is taking to address these other areas, however, success will largely be driven both by implementation strategies and the execution and evaluation of those strategies. 5|Page 2. Methodology of the Customs Reform Board The Board undertook a discovery of ACBPS law enforcement capability, business operations and integrity culture consisting of three elements: stakeholder consultation, operational familiarisation, and a review of documentation. This process enabled the Board to understand how the ACBPS manages its business, to identify and become familiar with the challenges faced, as outlined in section three below, and to determine key focus areas for the ACBPS to consider when moving forward with its reform programme. Stakeholder consultation The Board held discussions with the ACBPS senior leadership group, including detailed discussion on their human resources strategy and processes, intelligence functions, IT capabilities (as they relate to intelligence) and integrity initiatives. The Board was briefed by each Division of the ACBPS and provided with an overview of their responsibilities within the broader Service, and the challenges each faces in performing their role efficiently and to the highest professional standards. The Board received ongoing sensitive briefings from the Australian Federal Police (AFP) and the Australian Commission for Law Enforcement Integrity (ACLEI), providing insight into the vulnerabilities and integrity challenges facing the ACBPS, as identified through their investigations in the Sydney Airport and Port Botany environments. As this is sensitive information, relating to current investigations, the board has not been able to provide direct comment but has taken account of the information in deliberations. The Board was briefed firstly by the Australian Public Service Commission (APSC) on the capability review program and secondly by the independent senior review team on the capability review of ACBPS. The Board acknowledges the significant work completed by the independent reviewers and has taken into account their assessment of the challenges, issues and identified areas for improvement within ACBPS in the development of this report. Representatives from the Community and Public Sector Union, the Australian Institute of Marine and Power Engineers and the Customs Brokers and Forwarders Council of Australia were also consulted to provide external opinions on challenges faced. Operational familiarisation visits The Board undertook an operational familiarisation visit to Sydney International Airport and ACBPS facilities at Port Botany. The Board witnessed operations at the primary line, baggage search areas, the container examination facility (CEF) and were acquainted with compliance and detained goods management activities. The size and complexity of the roles and responsibilities undertaken by the ACBPS within the airport and port environments were clearly evident, and the Board was provided with supporting operational strategies, policies and procedures as part of its literature review. Literature review The Board was provided with a range of ACBPS policy and strategic documents setting out the current and future operating environments, the existing operating model, existing capabilities and a summary of the ACBPS reform programme. The Board was provided with mapping of the traveller, 6|Page mail and cargo supply chains to supplement their operational understanding, and an overview of the numerous stakeholders and partners ACBPS works within the border environment. Additionally, the Board was advised of the ACBPS’s existing documentation available to staff covering the notification of corruption allegations to ACLEI, integrity and professional standards, drug and alcohol polices and conflict of interest and security requirements. 7|Page 3. Identified challenges facing ACBPS In the Board’s view, the primary role of ACBPS is to facilitate legitimate trade and travel across the Australian border. Necessarily, enforcement – dealing with illegitimate trade and travel - is a key component of this role in dealing with those people who seek to circumvent Australian laws. The Board recognises the need for Service-wide reform if the ACBPS is to keep pace with a rapidly evolving border environment, while meeting Government and community expectations around border management and protection. The future of the border is characterised by the increasing volume and complexity of travellers and trade, criminal sophistication targeting all aspects of the border (travellers, cargo and mail) and a challenging global economy. Factors including shifts in economic and geopolitical power, advances in technology and changing trade patterns will continue to impact on the way the border is managed. In addition to the factors noted above, ACBPS will have to continue to respond to operational issues. Decisions on resource allocation in response to urgent and/or tactical operational issues all impact on the ability of the ACBPS to maintain other existing functions. Threats that criminals will attempt to infiltrate law enforcement agencies like the ACBPS, or subvert ACBPS staff, to gain access to information, or even active support for criminal operations, is very real. The Board has noted with concern the large number of vulnerabilities identified by law enforcement agencies at both the Sydney Airport and Port Botany facilities. The identification of vulnerabilities in addition to allegations of corruption, misconduct and illegal activity involving ACBPS officers has made it clear that there are cultural issues within the ACBPS and that organised crime syndicates are attempting to infiltrate and corrupt public organisations and officials. These challenges will need to be addressed in a difficult fiscal climate where achieving efficiencies within the Service will be paramount. The Board is keenly aware that the reform programme (which includes a broad range of transformation initiatives) will require investment in capital and human resources in the near future This investment will need to be supported by a financial injection from Government and by redirecting funds from within the existing ACBPS budget to reform activities. ACBPS funding since 2009-10 is outlined in the table below. Actual Financial Year Total Net Cash Based Funding 2009-10 $m 1,113.53 2010-11 $m 1,098.22 Forecast 2011-12 $m 1,155.57 2012-13 $m 1,147.72 2013-14 $m 1,158.58 Identifying the challenges noted above and developing appropriate responses is only half of the equation. Given the length and breadth of the reform programme being proposed, ACBPS will face a significant challenge in maintaining high levels of service while continuing to drive change over the medium to long term. A strong culture, open to change and continuous improvement, and capable 8|Page of maintaining a sustained effort, will be essential if the reform programme is to be implemented successfully. The Board recognises the complexities that exist within the varied roles and responsibilities of the ACBPS, which sees the ACBPS attempt to balance tensions between the protection of the Australian border and facilitation of legitimate trade and travel. The geographically dispersed nature of the ACBPS workforce can foster the development of regional and/or role specific cultures and attitudes, contributing to the difficulty in establishing a Service with one culture and one purpose. The Board identifies that a unified culture open to change, with the core values of integrity and professionalism instilled, must be embedded within the Service; this will be critical not only in the implementation of lasting reform, but in the achievement of long term reduction of corrupt activities within its ranks. In response to a call for submissions from relevant law enforcement agencies on barriers to investigating integrity and corruption issues within Government agencies, the Board received submissions from the AFP and ACLEI. The Board believes there is significant merit in the submissions and supports further consideration of the issues raised. 3.1. Board observations on the ACBPS response to identified challenges Reform of the ACBPS is being managed in a staged process. The first phase, focusing on immediate integrity issues was implemented in 2012-13 following the culmination of investigations into a number of ACBPS officers at Sydney Airport, and the recognition of the need to strengthen ACBPS integrity arrangements. This reflected a process begun in January 2011 when ACLEI first gained jurisdiction over ACBPS, and the referral of a number of issues to ACLEI by the then CEO of ACBPS. However, there remains a broader need for further Service-wide reform if the ACBPS is to keep pace with the accelerating evolution of the border environment. The second phase of the reform programme will address this need, taking a holistic view of the ACBPS to identify appropriate reforms to business systems, the ACBPS’s people and operating model, and additional measures to enhance integrity. The Board’s observations on these phases of reform are outlined below. First phase of reform The most senior leaders of the ACBPS have a strong sense of the integrity challenges being faced and the need for reform. The Government has legislated the first phase of reform focusing on immediate actions to strengthen integrity measures, and ACBPS has implemented these reforms. They include: integrity testing – this provides the power to conduct targeted integrity tests on officers suspected of corruption drug and alcohol testing – the CEO of ACBPS now has the power to authorise drug and alcohol testing on all Customs workers the power to make a declaration that an officer has been terminated for serious misconduct, and the power to make specific CEO Orders for the control of the Service, including the mandatory reporting of serious misconduct, corrupt conduct or criminal activity. 9|Page The Board supports these integrity measures, and strong action against corrupt behaviour. Further, an evaluation of these measures should be undertaken within twelve months of implementation. Second phase of reform A proposed second reform phase will place the ACBPS in a position to address existing and future challenges. The change process is expected to take a number of years and will be developed in a way to provide a series of discrete bodies of work enabling targeted project management. ACBPS has established three distinct reform tracks: - The ACBPS People and Operating Model: A professional and agile Service that is adaptive to change. Modernisation: Efficient business systems, streamlined processes and sophisticated intelligence. Integrity: A disciplined Service culture and workforce hardened against corruption. Modernising ACBPS systems and processes will improve the service delivered to clients and facilitate detection of criminal behaviour. Community confidence in the ability of the ACBPS to carry out its significant responsibilities will be ensured by hardening the Service against corruption, and instilling integrity and professionalism as core values. Equally as important, the ACBPS must adopt a dynamic operating model that allows it to quickly adapt to change, aided by a workforce that is skilled, professional and high performing. The Board supports the ACBPS approach to the second phase of reform identified in its Blueprint for Reform and has identified key areas for the ACBPS to consider as it moves forward. These areas reflect the Board Members’ own experiences with significant reform implementation and change management initiatives. 10 | P a g e 4. Board-identified ‘key issues’ for ACBPS consideration 4.1. Core considerations specific to change management and reform implementation In the Board’s view, clear evidence exists, especially in relation to integrity issues, that change is required within the Service. To successfully implement positive change a strong and united leadership must: 4.1.1 establish a clear aspirational vision, purpose, and agreed set of values that contribute to a single overriding culture built on the foundations of professionalism and integrity establish effective communication to engage all staff in the change management process, and provide appropriate human and technological resources to facilitate the desired change. Strong and united leadership As the ACBPS consists of separate enforcement, facilitation and trade regulation pillars, creating ‘one team’ with common goals and objectives may be a challenge. Visible and accessible ‘reform champions’ throughout all levels of management will positively promote the reform programme. Leaders at all levels in the ACBPS must be empowered and accountable. Targeted leadership training and development opportunities must be made available to strengthen workforce capability and leadership skills. The development of leaders at various levels will place the ACBPS in a strong position to embrace and respond to change and rise to the challenges of an evolving border environment. 4.1.2 Effective communication and staff engagement Consultation and continuous communication across the Service are critical to securing staff support and creating a shared vision. ACBPS Senior Executive Service officers appear to have a good understanding of the challenges and the need for change. Other staff have indicated a willingness to accept and proceed with change, but were uncertain of management’s direction and agenda. This represents a challenge for the ACBPS. Communication across the ACBPS is challenging due to its size, geographic diversity, and shift rotations with non-standard hours. The location of the majority of the senior management in Canberra, away from the operational officers, may create a disconnect between strategic direction and delivery. The Board was encouraged to hear from staff and union representatives that the majority of the ACBPS’s staff have pride in the organisation and are concerned by the integrity/corruption allegations of the recent past. These attitudes indicate an openness to eliminate such activity and should be harnessed in the development of a culture of integrity and professionalism within the ACBPS. The Board strongly supports a communication strategy that provides all staff with a strong sense of what is to be achieved and how success is to be measured. It should set out the different aspects of 11 | P a g e the reforms, implementation processes, clear timeframes and goals, and identify those responsible for each reform. Critically, it must involve continuous engagement by the most senior leaders of ACBPS with the front line personnel, to ensure the vision is understood by all levels. 4.2. 4.2.1 Considerations specific to the ACBPS Blueprint for Reform The ACBPS People and Operating Model: A professional and agile Service that is adaptive to change The ACBPS must be a dynamic, skilled and high performing workforce with the capacity to respond and adapt to change if it is to succeed in the face of an increasingly complex and constantly evolving border environment. Performance management and assessment processes should ensure staff have meaningful goals and recognition. Along with a focus on ‘what’ an employee has achieved, emphasis should also be placed on the ‘how’ with measures to assess how well staff perform in relation to professionalism and integrity. The Board notes there is a need to complement reform activities which are enforcement based with positive activities and proactive measures. These can include: 4.2.2 ongoing transparency in recruitment (both internal and external) and staff mobility processes ensuring that clear career progression is available and visible for staff wishing to advance within the ACBPS ongoing merit based selection processes, and ensuring that there are strong policies around performance management and that these policies are actively implemented between managers and staff. Modernisation: Efficient business systems, streamlined processes and sophisticated intelligence Increasing trade and travel volumes place strain on ACBPS’s human resource intensive transaction based operating processes. This trend is expected to continue. Sophisticated intelligence approaches must be developed if the ACBPS is to successfully implement its intelligence-led risk based approach and meet these challenges. The numerous disparate and stand-alone systems used contribute to an inhibited flow of information, which in turn reduces the ability to be responsive to demands. A commitment to information sharing and to investment in the right IT systems, facilitating information sharing and allowing for integration of intelligence that will support big data1 analytics, is required. The Board encourages the ACBPS to break down any internal barriers to intelligence related information sharing, develop further strategic relationships with partner agencies working in the border environment, and other relevant law enforcement areas, to improve overall intelligence capability. 1 Big data is a collection of data sets so large and complex that it is difficult to process using traditional database management tools or data processing applications. Big data is typically characterised by its velocity, variety and volume. 12 | P a g e New systems and processes must be prioritised so as to best support the goals of moving to big data analytics and increasingly sophisticated intelligence approaches. 4.2.3 Integrity: A disciplined Service culture and workforce hardened against corruption Integrity and professional standards function within the ACBPS This important function performed by the ACBPS’s Integrity and Professional Standards Branch, in ensuring that key reform objectives of ethics and integrity are being met, must be clearly defined, well-resourced, respected and visibly supported across the ACBPS. The Board considers that placement of the integrity and professional standards function within the organisational structure must demonstrate its relative independence, with a direct line of reporting to either the CEO or a Deputy CEO. The head of the function should have integrity and professional standards as his or her sole focus. Selection of suitable officers for this role will be vital. The officers need to be carefully chosen for their intellectual capacity, ability, investigative experience, and above all, their integrity. This process may require the external recruitment of experienced and multi-disciplined personnel. Access to relevant information, intelligence gathering and interpretation capabilities will be important for this function. Liaison with other border agencies and federal and state and territory law enforcement agencies with responsibility for integrity and professional standards will also be important. The development and ongoing delivery of prevention, disruption and assurance strategies to target and test potential vulnerabilities, throughout the ACBPS, will be critical. The Board supports the appointment of a Special Integrity Advisor to provide the Chief Executive Officer independent advice on anti-corruption measures and assurance systems. The Special Integrity Advisor should also have the necessary powers and resources to undertake investigations as directed by the Chief Executive Officer. The Board sees this appointment as a priority within the next 12 months. The Board supports the introduction of an ACBPS specific code of conduct and the establishment of core values within the Service. These will provide a strong sense of purpose throughout the ACBPS and clearly articulate appropriate and professional behaviour. It is key that these are effectively promoted throughout the ACBPS. Integrity Impact Statement The Board considers integrity considerations should be embedded in all activities including the development of new policies, practices and IT systems. Including an ‘Integrity Impact Statement’, for example in project plans, will be a trigger for officers to consider the project/change from an integrity and anti-corruption perspective, and bring the issues of integrity to the forefront at the beginning of any initiative. This will work to infuse the ongoing consideration and awareness of these issues into all aspects of ACBPS work and culture. ACBPS response to ACLEI/AFP identified vulnerabilities at Sydney Airport 13 | P a g e A number of mitigation strategies to address the issues identified by ACLEI and the AFP at Sydney Airport have been identified including stronger supervision and accountability, implementation and enforcement of internal policies, vetting and training and introduction of better access controls and increased scrutiny. These should be implemented as soon as possible. The ACBPS should test the vulnerabilities identified at Sydney Airport once mitigation strategies have been fully implemented to determine whether these strategies have been effective in reducing the corrupt activities and whether mitigation measures have pushed the risk of vulnerabilities to other areas of the Airport. The Board further notes that vulnerabilities exist outside of ACBPS controlled areas and its direct chain of command within the airport environment (for example, passenger screening and baggage processes). Containing corruption should not stop with the ACBPS. The Board notes that further review of these vulnerabilities should be conducted, with appropriate Government action taken. 14 | P a g e 5. Conclusion The priority for the Board has been to provide advice and recommendations to aggressively target corruption and oversight the implementation of reforms to embed an improved culture of professionalism and integrity within ACBPS. Since its first meeting on 1 February 2013, the Board has been provided with an extensive range of documentation, briefings, and facility tours to establish a strong understanding of the challenges being faced by the Service and opportunities to address these challenges. The Board notes that a first phase of reform is already being implemented and that a second phase of reform, which is currently being developed, will constitute the significant proportion of the total reform programme. Given the size and scope of the second phase of reform, the time taken to implement change will naturally take longer. It is essential that timeframes are closely monitored and managed so as to effect change within an acceptable period, noting that some modernisation processes will be dependent on external factors including the pace of technological advances. Through its consultations, the Board is satisfied that the challenges faced by the Service are very real and require appropriate reform. The Board is also satisfied that the first phase of reforms already implemented are appropriate, and that the three reform tracks identified in the ACBPS Blueprint for Reform accurately capture the areas where the Service needs to change in order for it to meet existing and future challenges. Identifying the issues and supporting mitigation strategies is in some ways the easiest part of the task faced by the ACBPS. By far the biggest challenge the ACBPS will have is the successful implementation and integration of the reforms into its everyday business. Meeting this challenge will require strong, effective and professional leadership at all levels and a commitment to ongoing staff engagement and effective change management. The Board acknowledges its role is only partially complete in providing advice on the challenges faced by the ACBPS. The Board has an ongoing role as an independent observer oversighting the implementation of the reforms. The Board will continue to provide advice to the Minister for Home Affairs and Justice on the effectiveness of the reform strategy. 15 | P a g e Appendix A: Terms of Reference Terms of Reference 1. Preamble The Government has committed to the comprehensive reform of the Australian Customs and Border Protection Service (ACBPS) to improve its law enforcement capability, its business operations and its integrity culture. A particular challenge facing the ACBPS is the sophistication of organised crime, which is actively seeking to infiltrate and subvert border controls. Investigations following the extension of the jurisdiction of the Australian Commissioner for Law Enforcement Integrity to cover ACBPS have revealed apparent corruption of ACBPS staff. The Board’s top priority is to provide advice and recommendations to aggressively target corruption and oversight the implementation of reforms. The first stage of reforms were implemented last year. The Law Enforcement Integrity Legislation Act 2012 provides for integrity testing of ACBPS staff, mandatory drug and alcohol testing of ACBPS staff, mandatory reporting by ACBPS staff on a range of issues, and gives the CEO of ACBPS the ability to terminate the employment of ACBPS staff for serious misconduct without remedy under the Fair Work Act. The second stage of reforms will be released this year. This will set out a blueprint to overhaul Customs business operations, law enforcement capability and integrity culture. 2. Purpose The Board will advise the Minister for Home Affairs on strategic reform for the ACBPS and help drive the implementation of reforms already introduced. The Board will not be a decision making body. 3. Terms of Reference The Customs Reform Board will make recommendations to the Minister to: • • • • 4. Improve the business operations, law enforcement and integrity culture of the ACBPS embed an improved culture of professionalism, collaboration, innovation and adaptability within the ACBPS make operational, administrative and legislative changes required to support the reforms; and any other relevant matters. Methodology 16 | P a g e The Board is composed of a senior representative of the integrity sector, a senior representative of the law enforcement sector, and a senior representative of the business sector, appointed by the Minister for Home Affairs. The Board will be part-time and will meet on a regular basis. The Secretary to the Attorney-General’s Department will act as Secretary to the Board, participating fully in Board discussions and deliberations, and the Board will be supported by a Secretariat situated in the Attorney-General’s Department. It will receive and consider recommendations and proposals developed by the ACBPS and/or other Government Departments and Agencies, but will also be free to develop its own recommendations and proposals. The Board may task Government Departments and Agencies, through the Secretary, with responding to its questions. 5. Consultation The Board may consult with relevant stakeholders, including Government Departments and Agencies, as it sees fit, with arrangements to be made by the Secretary. Submissions may be sought by the Board. 6. Reporting The Board will report directly to the Minister for Home Affairs, as required by him. 17 | P a g e Appendix B: Customs Reform Board Meeting Schedule The Customs Reform Board met formally on the following dates: February 2013 Friday 1 February 2013 March 2013 Friday 15 March 2013 April 2013 Wednesday 10 April 2013 May 2013 Thursday 2 May 2013 May 2013 Tuesday 28 May 2013 June 2013 Friday 14 June 2013 At its meetings the Board regularly took the opportunity to hear from and put questions to the CEO of ACBPS, the Australian Commissioner for Law Enforcement Integrity, and the Commissioner and Deputy Commissioner of the AFP. The Board also came together on separate occasions as part of its consultation and discovery process, outlined below. In addition to these meetings, the Board met regularly with ACBPS representatives to discuss reform initiatives. 13 March 2013 Australian Commission for Law Enforcement Integrity (ACLEI) Australian Federal Police Operational familiarisation tour of Sydney International Airport and ACBPS facilities at Port Botany 10 April 2013 Community and Public Sector Union Australian Institute for Marine and Power Engineers Australian Public Service Commission Capability Review Team 22 April 2013 Customs and Border Protection Senior Executive Service Customs Brokers and Forwarders Council of Australia 28 May 2013 ACLEI 18 | P a g e 7 June 2013 Minister for Home Affairs and Justice 19 | P a g e