A procurement exception is a question to test, not a fraud finding. This review method helps a board, agency or legal adviser reconstruct a tender or supplier decision from source records. The Commonwealth Fraud Prevention Centre identifies risks and control points across the pre-award process, but the governing rules differ by agency, jurisdiction and private organisation. Start with the actual policy and delegation in force for the transaction. Commonwealth Fraud Prevention Centre: procurement risks.
Define the decision and preserve the record
Identify the procurement, value, period, decision-maker, evaluation criteria, approval thresholds and the precise concern: for example, a score changed after moderation, a supplier was introduced late, or a bank account changed before payment. Preserve the invitation, bids, declarations, evaluation versions, meeting notes, approval history, contract variations, invoices and system logs. Note what is missing and who controlled the record. Do not overwrite a shared evaluation sheet while reviewing it.
Reconstruct the sequence, not just the final score
Make a dated timeline: requirement approved; market approached; bids received; conflicts declared; criteria applied; scores moderated; recommendation made; delegation exercised; contract signed; variation and payment approved. For every deviation, record who authorised it, under which rule and with what contemporaneous reason. Compare the current record with earlier versions and access logs. A legitimate correction may look irregular until the underlying method is visible; a neat final summary may conceal an unexplained change.
Use a discrepancy worksheet
- Observation: what changed, with document and version identifiers.
- Rule: the criterion, policy clause or delegation in force at the time.
- People and permissions: who could edit, approve and benefit; what access logs show.
- Competing explanations: error correction, authorised clarification, formula recalculation, undocumented exception or improper influence.
- Tests: source bid, formula, panel note, conflict declaration, communications, approvals and participant responses.
- Finding and limit: what is established, what remains unresolved, and who must decide the next step.
Worked example — a changed evaluation score
Hypothetical example. A supplier’s score rises from 68 to 75 after a panel meeting. The final spreadsheet shows 75 but no reason. The reviewer preserves both files and their histories, recalculates the published criteria and obtains the panel minutes. One hypothesis is an authorised correction of a formula error; another is an unapproved change favouring the supplier. The reviewer checks whether all bids were treated with the same corrected formula, who edited the sheet and who approved the change. The relevant participants are asked about the discrepancy. If the formula correction is documented and applied consistently, the finding can explain that. If the edit source remains unclear, report the unresolved control gap rather than asserting bribery or bias.
Check relationships proportionately
Compare conflict declarations with lawful official company records and information supplied by participants. A relationship does not by itself prove influence; its relevance depends on timing, disclosure, role and decision authority. For Australian entities, ASIC’s register supports name and identifier checks, while paid extracts may provide further officeholder and historical details. It does not give a universal view of ultimate control. ASIC registers. If a potential undisclosed interest is material, refer it to the authorised probity or legal adviser before characterising misconduct.
Close with an action record
Separate the factual finding from a policy breach, criminal allegation or disciplinary outcome. Record which procurement step should be paused, independently reassessed or corrected; who has authority; what evidence must remain preserved; and when a control change will be checked. Escalate if records suggest collusion, deliberate deletion, payment diversion or a conflict involving the decision-maker. The commissioning organisation remains responsible for the procurement decision and its obligations.