Management of the Detention Centre Contracts-Part A
The objective of the audit was to assess the effectiveness of DIMIA's management of its detention agreements with ACM to operate Australia's mainland immigration detention centres. In particular, the ANAO examined: DIMIA's strategic approach to the management and coordination of the contract; how DIMIA defined the services to be delivered by ACM; the systems in place to monitor and report against contract performance; the effectiveness of controls over contract payment arrangements; and DIMIA's management of infrastructure through the detention agreements.
Since 1994, the Migration Act 1958 (the Act) has required that all non-citizens who are unlawfully in Australia must be detained. The purpose of immigration detention is twofold; to determine the immigration status of an unlawful non-citizen, and to allow for the removal of an unlawful non-citizen who is not permitted to remain.
Providing services to people in detention including accommodation, security and safety is inherently challenging and was complicated by external factors that arose at certain times during the contract. For example, in 1999–2000 and in 2000–2001 there was a surge in the number of unauthorised arrivals seeking asylum in Australia. The number of unauthorised arrivals (by boat) in this period represented a ten-fold increase in the numbers that arrived in the early 1990s, and this resulted in a large increase in the number of people in detention. Since then, the number of persons in detention has declined, largely due to a fall in the number of unauthorised boat arrivals on the Australian mainland since August 2001.
Until the end of 1997, the security of Australia's detention facilities was managed on behalf of the Department of Immigration and Multicultural and Indigenous Affairs (DIMIA) by the Australian Protective Service, a Commonwealth government agency. Other services at the centres, such as food, medical, education and welfare services were provided either directly by DIMIA or through individual contractors. In February 1998, the provision of detention services at immigration detention facilities was contracted to Australasian Correctional Services Pty Ltd (ACS 1). This contract was entered into at a time when the public sector had limited experience in contracting with the private sector for delivering services.
The contracting out of detention services provided an opportunity to replace the previous service delivery arrangements and, for the first time, detention service requirements were formalised into a set of principles and standards. Australasian Correctional Management (ACM) operated the mainland immigration detention facilities until early 2004. Between 1 December 2003 and 29 February 2004, the new contractor for the provision of detention services, Group 4 Falck Global Solutions Pty Ltd2, commenced operations.
The Detention Services Contract with ACM ran for six years at a cost to the Commonwealth of more than half a billion dollars. The ANAO considers that the cost and the duration of the agreements with ACM justify independent examination of these arrangements.
Audit objective and scope
The objective of the audit was to assess the effectiveness of DIMIA's management of its detention agreements with ACM to operate Australia's mainland immigration detention centres. In particular, the ANAO examined:
- DIMIA's strategic approach to the management and coordination of the contract;
- how DIMIA defined the services to be delivered by ACM;
- the systems in place to monitor and report against contract performance;
- the effectiveness of controls over contract payment arrangements; and
- DIMIA's management of infrastructure through the detention agreements.
The audit focussed on DIMIA's management of its contract with ACM, and did not separately examine the outcomes of the detention program, nor the quality of the services provided by ACM. The audit examined DIMIA's contract with ACM for Australia's mainland detention centres. While the detention services contract applies to the facilities on Christmas Island and Cocos Island these were not examined by the ANAO. The ANAO did not examine the arrangements in place for the offshore processing centres outside Australia that are managed by the International Organization for Migration.
During the course of the audit, DIMIA requested that particular information should not, pursuant to section 37(2) of the Auditor General Act 1997, be included in this report. There were insufficient grounds to support this request.
The ANAO intends to conduct a second performance audit of the management of the detention centre contracts. The second audit will be concerned with the transition arrangements to the new provider and management of the second contract.
Key audit findings
In order to examine DIMIA's management of its contract with ACM, the ANAO asked several key questions in each of the following areas:
- DIMIA's planning and strategy for contracting out its detention services (Chapter 3);
- the structure of the contract between DIMIA and ACM (Chapter 4);
- DIMIA's management of ACM's delivery of services under the contract (Chapter 5);
- DIMIA's processes for making payments to ACM under the contract (Chapter 6);
- DIMIA's approach to managing detention infrastructure through the contract (Chapter 7); and
- DIMIA's procedures to manage any renewal of the contract (Chapter 8).
The key questions in each chapter, and the ANAO's related findings, are set out below.
Contracting for detention services (Chapter 3)
The documented objectives of the General Agreement between DIMIA and ACM were to deliver quality detention services with ongoing cost reductions. DIMIA advised that because of large numbers of asylum seekers arriving by boat in 1999–2001, these objectives were changed to focus on ensuring there was adequate detention capacity to accommodate the sudden influx. This indicates a volatile environment involving many jurisdictions and the need to focus on the risks and develop agreed plans that draw together relevant legislation and operations across the department. Such an approach would allow DIMIA to articulate its priorities and allocate resources according to whether cost reductions, quality services, or capacity enhancements, were being pursued.
The ANAO considered DIMIA's overall approach to contract management, in particular, the management of risks, strategic planning, internal and external coordination arrangements, as well as the need for research into immigration detention.
Were the risks associated with contracting out detention services identified, assessed and treated appropriately?
DIMIA's management of the program, together with the delivery of services under the contract and the prioritisation of tasks, focused on risks that materialised, rather than systematic risk analysis, evaluation, treatment and monitoring. A systematic approach to risk management, including the establishment of an appropriate and documented risk management strategy, should have been an integral part of contract management, given the complexity of the task and the numerous stakeholders involved. Although DIMIA acted appropriately to deal with program and other risks as they occurred, the majority of risks were managed in response to an incident or event. It is better practice to put in place, preferably on an enterprise wide basis, effective preventative action or at least action that minimises and/or ameliorates, a risk event. This applies not just to financial risks but also, importantly, to strategic and operational risks associated with delivery of the services.
Did DIMIA have a strategy for managing its contract with ACM?
The ANAO found that DIMIA had not developed and documented a strategy for its detention function, nor put in place a contract management plan. Other than the contract itself, there was no documentation of the means by which the detention objectives would be achieved. This meant that DIMIA was not able to assess whether its strategies were actually working in practice. DIMIA did develop a number of operational plans through ACM, and conducted contingency planning for major events and further boat arrivals. The ANAO also notes that DIMIA conducted two workshops in 2000 and 2001 involving all relevant sections of the department to help plan for the management of the detention function.
Did DIMIA establish coordination arrangements with external agencies?
The ANAO notes that DIMIA has made progress towards introducing a comprehensive range of Memoranda of Understanding (MOU) with a range of external agencies, including State Departments, but the extent to which the MOUs have been formally finalised and implemented varies.
Were DIMIA's internal coordination arrangements for contract management adequate?
The geographic location and operational culture of the immigration detention facilities are diverse, making contract management a complex task. While there were informal arrangements in place the ANAO found that DIMIA's internal arrangements to coordinate detention services through its contract with ACM were unclear. There was a lack of clarity around the roles and responsibilities of key personnel and very low levels of contract management training for DIMIA officers. Although DIMIA used a range of mechanisms such as teleconferences and Migration Series Instruction (MSIs) to communicate internal roles and responsibilities, a manual for DIMIA centre managers was not issued until December 2001; some four years after the contract commenced. This manual has not been kept up to date.
Did DIMIA conduct research into immigration detention?
The detainee population has changed over time and at one point there were 77 different nationalities represented in detention centres. Immigration detention is funded by substantial Commonwealth investment and it carries potential risks to the detainees and to the Commonwealth. The ANAO found there was limited research into the management of detention services which could be used to provide a sound basis for evaluating the effectiveness of the program and as guidance for informing future directions and operations.
Contract structure (Chapter 4)
A critical issue in contractual arrangements is striking an appropriate balance between the degree of purchaser oversight of service delivery and the operational flexibility afforded to a contractor. Better practice guidelines consistently state the case for providing reasonable operational flexibility to the provider. Specifying contracts in terms of outputs, not inputs, allows for contractor innovation and consequent efficiency gains. However, this approach is contingent upon the purchaser being able to clearly specify the outputs, including appropriate service quality measures.
Contract guidelines also emphasise the ultimate responsibility of the purchaser for service delivery and the importance of performance monitoring. Therefore, in cases where outputs are difficult to define and/or to state unambiguously, it is appropriate for the purchaser to specify and monitor contractor performance based on inputs as well as on how the service is being provided. The ANAO examined the detention agreements between DIMIA and ACM and asked the following key questions.
Was there a clear statement of the services to be provided under the detention agreements?
The ANAO notes that DIMIA's detention agreements with ACM were designed to focus on contractual outcomes; the service outputs to be provided. The ANAO was advised that DIMIA's detention agreements described only in general terms the services to be provided by ACM and it was DIMIA's view that detailed quality standards were incorporated in the Immigration Detention Standards (IDS).
Did the contract specify the standard to which services will be delivered, and contain performance measures able to measure and/or assess the service delivery?
The ANAO found that DIMIA's Immigration Detention Standards (IDS) were not clear statements of detention service requirements. Rather, key IDS listed statements and activities, and used ambiguous language to define the nature and level of service required. In addition, many of the performance measures did not specify a target that needed to be achieved or articulate the method of assessment. From a total of 107 IDS and sub-standards, 38 were not covered by any performance measures and a further 37 were only partially covered. As the IDS were derived from poorly specified standards and targets, it was difficult for DIMIA to effectively monitor ACM's performance against accepted pre-determined levels of service delivery. Based on this evidence, the ANAO formed the opinion that DIMIA's IDS were not clear statements of detention service requirements for either outputs or inputs.
Did the detention agreements contain mechanisms for managing underperformance by the contractor?
The ANAO found that the contract contained mechanisms for managing underperformance. Three per cent of the contractor's fee was directly linked to performance. However, the fee at risk and the points method used in calculating its application, meant that, in isolation, it was an ineffective mechanism for sanctioning persistent below-standard delivery. The detention agreements contained other mechanisms for dealing with serious breaches.
Did the detention agreements set up structures for communication between the contractor and DIMIA?
The general agreement indicated that the parties should establish a management committee with agreed structure and functions prior to the commencement date of the service contract. The membership of the group was agreed in 1997. However, the ANAO found incomplete; and therefore inadequate documentary evidence of the agreement relating to the forum's functions as stipulated in the contract. DIMIA established a close relationship with ACM staff, both at the senior levels, through the Contract Operations Group and the Contract Management Group, and at the operational level with on-site DIMIA business managers. These groups were the main scheduled method for DIMIA and ACM contact. Although it is not essential that such methods of communication are laid down in a contract, the functions and operations of both the Contract Management Group and the Contract Operations Group lacked an agreed formal basis beyond discussions at the meetings. Agreed, formal procedures would have provided greater direction and authority for the two groups and facilitated management of the contract.
Did the detention agreements contain mechanisms for dealing with changes?
The General Agreement contained a clear mechanism for variation, which was used for one formal amendment. All other changes to service requirements were negotiated through the partnering relationship rather than formal contact amendments, carrying additional risks. Both DIMIA and ACM identified further gaps and ambiguities in the detention agreements and there were also considerable changes in the service requirements over the life of the detention agreements caused by the increase in unauthorised boat arrivals, the increase in detainees coming directly from state prisons, and the increasing number of long-term detainees.
The lack of formal amendments to the contract indicates to the ANAO that suggested solutions to changing service requirements were negotiated on an ad hoc basis. The risks involved in this were that; the solutions relied on specific people, and were lost when personnel changed; the solutions did not necessarily fit into DIMIA's overall strategic plans and objectives; any informal requirements were not adequately documented, monitored and assessed; the service requirements differed markedly from centre to centre; and an uncertain legal position could arise if amendments in writing (which were not known to DIMIA as formal contract variations) had the effect in law of formal amendments. DIMIA advised that it considered the issue of contract amendments, but in the view of the complex issues arising from consideration of contract extension or renewal, decided to drive change through the new contract for detention services. The ANAO notes that this decision was taken in March 2001 and the new contract was signed in August 2003.
Managing contract delivery (Chapter 5)
Under the detention agreements DIMIA required ACM to deliver certain services. In order to ensure the services were being delivered in accordance with the contract, the ANAO expected to find DIMIA had in place administrative processes to manage its contract with ACM, including the collection and analysis of performance information and the application of incentives and penalties.
Did DIMIA have processes in place to collect all relevant information for effective contract management?
The audit found that, the majority of methods used by DIMIA to collect information were exception-based. The ANAO acknowledges that exception reporting is a standard contract management tool. However, unless underpinned by quality assurance methods, the use of exception reporting carries the risk of not identifying substandard performance until a service delivery failure has occurred.
From 2001, DIMIA implemented more systematic strategies to allow for more comprehensive information collection. However, at the time of the audit these strategies were not fully implemented across all centres, nor were these strategies connected to an overall contract monitoring plan. As a result, DIMIA could not be assured that all of the information necessary for effective contract management was being collected.
Did DIMIA analyse complaints and use that analysis to improve service delivery?
In general, the mechanism for detainees to make complaints to ACM or DIMIA operated effectively. However, while information about specific complaints could be raised at the Contract Operations Group as a service delivery issue, DIMIA did not analyse complaints to identify systemic issues that required attention.
Did DIMIA effectively analyse the information collected to assess the contractor's performance? \
Other than the contract, DIMIA did not have any assessment criteria or standardised process to analyse and assess performance information received from ACM or complaints. DIMIA's analysis was usually linked to identified breaches of a service standard, and did not measure whether the standard of service delivery was of the required quality.
Rewards and penalties
Did DIMIA use the performance-linked fee to provide an incentive for ACM to deliver continuous high standard services?
DIMIA did not have formal criteria to determine whether a breach of service performance would be included in the calculation of the performance-linked fee. Calculation of the performance-linked fee could be distorted by the use of multiple, retrospective or discretionary sanctions. The assessment of contractor performance against the performance-linked fee was more closely linked to identifiable breaches than to a continual high standard of service delivery.
Did DIMIA effectively use the available penalties for serious performance breaches?
DIMIA issued only one default notice, although there were several quarters where the bulk of the performance-linked fee was withheld. DIMIA advised that the use of these penalties took into account the seriousness of the breach, in light of the circumstances of the relevant case.
The ANAO notes the more serious penalties were not widely used and that a large percentage of the performance fee was withheld for the March 2002 and June 2002 quarters. The ANAO found no evidence that DIMIA considered using more serious mechanisms to address apparent persistent underperformance. The ANAO also notes that any perceived reluctance by DIMIA to use the default process would have undermined its ability to negotiate service improvements with the contractor.
Funding and payment process (Chapter 6)
The overall funding of detention, payment of accounts and the financial administration of the contracts are important administrative functions. Payments for detention services have been in the vicinity of $470 million over the life of the contract (not including the cost of repairs and maintenance, new infrastructure and use of consultants). Total outgoings for detention services and related ancillaries (not including capital expenditure) have reached approximately $570 million over the same period, taking into account a return of the Commonwealth's share of cost savings. 3
The ANAO examined DIMIA's procedures and processes to determine whether responsibility for managing funding and payments was appropriately structured to provide clarity and accountability to those involved.
Was there an appropriate financial reporting framework for contract management?
Recently, DIMIA's internal reporting in relation to its financial commitments for the detention contract has improved. Prior to this, routine management reports contained the average daily costs of detention, but did not include all of the costs of contract administration nor provide trend analysis. The more financially significant of DIMIA's commitments under the contract, and hence the areas of greatest financial risk, involved the operational cost of the contract, the payments for repairs and maintenance, and escorts and removals. Of these, the operational cost of the contract was the most significant. The ANAO found that the cost of detention, per detainee, per day, increased over the life of the contract. The ANAO also found that the costs of contract administration increased, and not always in proportion to the level of contracting activity. DIMIA advised that higher investments in contract administration coincided with higher levels of public scrutiny from external agencies, the requirements of developing a new contract and the demands of dealing with a more complex caseload. However, DIMIA's systems, and the level of financial reporting and analysis undertaken, did not provide assurance that increased investment in contract administration produced greater levels of operating efficiency and effectiveness.
Were financial delegations clear and appropriate?
Financial delegations had been set at a relatively low level of financial expenditure, which had not been subject to indexation nor needs assessment over the life of the contract.
Were there comprehensive procedures and instructions for payment of invoices?
There were comprehensive payment procedures and instructions. However, the control framework did not adequately protect areas of significant financial risk. There was also a gap in the invoicing procedures where the audit trail between the services provided and payments made did not provide senior managers with assurance that full value for money was being achieved.
Were the savings share arrangements managed to protect the interests of the Commonwealth?
The monitoring and management of the savings share arrangements in the contract were not consistent and placed the Commonwealth's share of the savings at risk. One of the two elements of the arrangement was not monitored and yielded no savings. Although the Commonwealth received a savings share in the early part of the contract for the other element of the arrangement, it fell away in the last three years, following the re-pricing of the agreements.
Detention infrastructure (Chapter 7)
In examining DIMIA's approach to managing detention infrastructure through the contract with ACM, the ANAO looked for systematic processes used by DIMIA to guide the development and acquisition, maintenance, and operation of the assets. In doing so, the ANAO acknowledges DIMIA's investment in infrastructure development over the life of the detention agreements. Specifically, the ANAO considered the following key questions.
Were roles and responsibilities for managing those aspects of detention infrastructure specified in the detention contracts clearly defined?
There was a reactive approach to improving detention infrastructure. The development of detention infrastructure was complicated by the involvement of a number of stakeholders. The ANAO found that roles and responsibilities of the key stakeholders were not formally agreed. The lack of clear and formally agreed responsibilities for particular infrastructure works and repairs and maintenance affected DIMIA's ability to influence the quality of detention services and provide ongoing cost reductions through the contract.
Did DIMIA have an asset management plan for the detention facilities to inform ACM and itself of the need for maintenance and/or upgrade over the life of the contract?
Over the life of the contract between DIMIA and ACM there was not a coordinated approach to collecting and analysing information to support an asset management plan for the detention facilities. The absence of an asset management plan led to infrastructure decisions being taken with limited regard to how infrastructure quality contributed to overall detention objectives.
Australia's detention facilities were old, and in a suboptimal condition at the start of the contract with ACM. These facilities have, on balance, deteriorated over time. While DIMIA has invested significant funding in the development and maintenance of the facilities, detention infrastructure assets have not been subject to a systematic assessment to determine the need for maintenance and upgrade.
The age and configuration of the existing detention infrastructure did not assist ACM in providing high quality detention services. The risks involved in using poorly designed or no longer appropriate facilities were not methodically monitored, nor were the costs being incurred in operation, maintenance and upgrade. Major improvements to the facilities, which could have yielded cost savings to the Commonwealth, have been delayed. As a result, a reactive approach involving minor works and emergency repairs was necessary.
Did DIMIA manage the impact of the quality of the detention infrastructure on ACM's ability to operate the centres?
Shortcomings in both design and specific aspects of the existing detention infrastructure adversely affected operations at the centres. Better management of detention infrastructure would have assisted the achievement of higher quality detention services in accordance with DIMIA's IDS, as well as the cost-effective delivery of these services.
Contract renewal (Chapter 8)
The Detention Services Contract was for a three-year period from February 1998, with an option for the Commonwealth to renew.
Did the contract contain a transparent process for renewal?
The procedure under the Detention Services Contract was clear and set out the rights and responsibilities of both parties.
Did DIMIA follow the renewal process in the contract?
The ANAO found that DIMIA followed the process for the renewal of the Detention Services Contract outlined in the contract.
Did DIMIA have a strategy to minimise the risk to service delivery during the negotiation period?
DIMIA developed a strategy to identify and minimise possible risks to service delivery during the extension and negotiation period from August 2000 to August 2003. ACM advised that, during this period, it faced difficulty in attracting and retaining qualified staff and this lead to increased costs.
The ANAO acknowledges that the contract with ACM was entered into at a time when the public sector had limited experience in large scale contracting with the private sector for delivering services. Indeed, it was because of this lack of experience that several publications were produced including the Joint Committee of Public Accounts and Audit report on Contract Management in the Australian Public Service in 2000 and the ANAO's better practice guide on Contract Management in 2001.
The ANAO also acknowledges that, once the contract was in place, external factors influenced operational requirements resulting in considerable pressure on DIMIA in relation to the delivery of the detention program. Risks became more apparent and service delivery expectations evolved. For these reasons, the ANAO focused on DIMIA's ongoing management of its contract with ACM. In particular, the audit addressed how DIMIA administered this contract over a six-year period from 1998 to 2004 to: monitor progress and re-align its objectives; take into account known and emerging risks; and capture and use of the growing amount of information and better practice guidance on contract management.
The ANAO concluded that DIMIA's management of its contract with ACM suffered from a lack of clearly identified and articulated requirements. Through the life of the contract, considerable time and resources were expended by both DIMIA and ACM managing the emerging issues from an increasing workload. However, DIMIA did not take the initiative and clarify its objectives. DIMIA decided not to amend the contract to establish clear expectations of the services to be delivered, or refine the standards it used to monitor and report on ACM's performance. These shortcomings adversely affected DIMIA's ability to: assess overall service delivery; determine the quality of service required and delivered in key areas; manage shared responsibilities; and establish priorities for improvement.
DIMIA's overall objectives in contracting out detention services were not clearly, or consistently, articulated over the life of the contract. After the contract was in place for about 18 months, an unexpected increase in unauthorised boat numbers tested the delivery of services being provided by ACM. DIMIA responded by re-aligning its objective of delivering high quality services at a reduced cost, to focus on ensuring adequate infrastructure to house the new arrivals. Documentation of these objectives and plans articulating how they were to be prioritised, achieved and measured, was not available. Neither was this new alignment reflected in the contract with ACM. As a result, there was insufficient relevant and credible information and reporting by DIMIA to support a firm conclusion about whether, and which, objectives were being met.
Prior to entering into the contract with ACM, DIMIA did not identify and document the risks associated with the private provision of detention services. More importantly there was no mechanism for monitoring and reviewing the risk profile as it changed over time. There was for example, no provision to allocate responsibility between DIMIA and ACM to control new risks that arose during the contract, before they materialised.
The detention agreements were based on the concept of a partnership; with the contractual agreements requiring ACM to deliver broadly stated contractual outcomes. While this gave greater flexibility to both parties, the contractual requirements lacked sufficient specificity to enable DIMIA to adequately monitor the quality and nature of the services provided by ACM. DIMIA responded to this lack of specificity by developing approaches, which relied on the cooperation of the detention services provider to monitor and improve contractor performance. This reactive approach meant that DIMIA's contract management was not based on any pre-determined assessment of DIMIA's requirements.
An important element of the accountability framework in managing contracts on behalf of the Commonwealth is to ensure that the interests of the Commonwealth are protected as far as possible. The ANAO concluded that there was a low level of assurance that the financial aspects of the contract operated as intended. Although there have been improvements in recent times, for the most part, financial performance measures and reporting in respect of the detention contract were limited. As well, DIMIA did not actively manage the savings share arrangements to protect the interests of the Commonwealth. The costs of the contract itself, and contract administration increased over the life of the contract, and not always in proportion to the level of contracting activity. The ANAO notes that, over the life of the contract, the human resources used by DIMIA to manage the detention function, including contract monitoring, increased from a section in DIMIA with 15 staff to a division with 150.
While the contract provided a basis for infrastructure management, it lacked clarity about DIMIA and ACM responsibilities. DIMIA did not translate key clauses contained in the contract into effective operational procedures for successful infrastructure management. ACM's ability to deliver detention services was not assisted by the quality of the existing detention infrastructure and the complexities associated with infrastructure improvement. While there was executive level oversight, DIMIA did not have a management plan that was strategically aligned to the overall objectives of its detention program. Consequently, the ANAO concluded that DIMIA's approach to managing detention infrastructure over the life of the contract was reactive.
The ANAO made six recommendations aimed at; improving DIMIA's risk management and planning; developing its knowledge base to improve contract management; controls for invoicing procedures; asset management plans and detention infrastructure standards.
Agency response: Department of Immigration and Multicultural and Indigenous Affairs
DIMIA welcomes this first part of the ANAO audit of the management of the detention centres contract. DIMIA is of the view that many of the identified areas of concern either have been or are being addressed in the management of the new detention centres contract. As this audit has been split into two stages, a complete picture of DIMIA's management of the contract will be clearer following the second audit report.
DIMIA agrees with the recommendations but, importantly, DIMIA also notes that the report does not fully reflect and take account of the complexity of the environment and the nature of the previous detention contract. In particular, there were significant and unpredictable changes to the detention environment following the unprecedented numbers of arrivals in 1999-2001 and the focus necessarily was on meeting basic needs. The detention services contract in question was also specifically founded on the concept of strategic partnership between the department and the contractor. While improvements to the contracting framework were deliberately built into the current contract, the ‘partnership' approach to the previous contract meant that many aspects of the contract were intended to be flexibly addressed through negotiation and discussion.
The environment for contracting out of detention services has changed considerably since 1997. DIMIA has also improved its processes and procedures in its management of the current contract. While DIMIA does not agree with all aspects of this report, DIMIA supports the recommendations and will continue to incorporate a strong focus on risk management, procedures and planning into its management of the detention program.
1 Although the contract is with ACS, services are delivered through ACS's operational company Australasian Correctional Management (ACM) which, in January 2004 changed its name to the GEO Group Australia. For ease of understanding, and to reflect operational realities, the contractor will be referred to as ACM throughout this report.
2 Group 4 was subsequently renamed to Global Solutions Limited (GSL).
3 The General Agreement provides for savings achieved through operational efficiencies to be shared at an agreed ratio between the Commonwealth and Contractor.