BENSON, Dr Sarah, Chief Executive Officer, Sport Integrity Australia FITTON, Ms Emily, Director, Legal, Sport Integrity Australia HAYES, Ms Lara, Director, Sports Wagering and Competition Manipulation, Sport Integrity Australia MOLLER, Mr James, Head of Strategy and International Policy, Sport Integrity Australia PERRY, Ms Alexandra, Treaties Manager, Department of Foreign Affairs and Trade Committee met at 15 : 10 CHAIR ( Ms Chesters ): I declare open this public hearing of the Joint Standing Committee on Treaties for its inquiry into the Council of Europe Convention on the Manipulation of Sports Competitions. I begin by acknowledging the traditional custodians of the land on which we meet and pay my respects to elders past, present and emerging. I also extend that respect to any Aboriginal or Torres Strait Islander peoples that might be joining ustoday. In accordance with the committee's resolution of 31 July 2025. this hearing will be broadcast, and a proof and official transcripts of the proceedings will be published on the parliament's website. I remind all present that, as chair, I will ensure that the proceedings are conducted in an orderly, respectful and courteous way. I remind members of the media of the need for fair and accurate reporting of the proceedings of the committee. I now welcome our witnesses. Although the committee does not require you to give evidence under oath, this hearing is a legal proceeding of the parliament. Therefore, it has the same standing as the proceedings of the respective houses. The giving of false and misleading evidence is a serious matter and may be regarded as contempt of parliament. The evidence given today will be recorded by Hansard and attracts parliamentary privilege. It is the responsibility of witnesses to accurately record any questions that may be taken on notice. Would any of you like to make an opening statement before we proceed to a discussion and questions from committee members? Dr Benson : I will. Thank you for the opportunity to address the committee today on the proposed ratification of the Council of Europe Convention on the Manipulation of Sports Competitions. Sport Integrity Australia was established over five years ago as the national agency dedicated to safeguarding the integrity of sport in Australia. The agency consolidated multiple integrity functions under one roof to provide a coordinated, proactive and comprehensive approach to threats facing sport. The role of SIA as an independent statutory agency is to prevent and address threats to sport integrity and to co-ordinate a national approach, with a view to achieving fair and honest sporting performance and outcomes, promoting positive conduct on and off the sporting arena, achieving a safe, fair and inclusive sporting environment at all levels and enhancing the reputation and standing of sport in Australia. Australia's sporting culture is deeply embedded in our national identity. Sport underpins community trust, drives significant economic activity and connects Australia to global sporting markets and institutions. Competition manipulation—more often referred to as match fixing—and sports betting related corruption are not isolated to domestic issues. They are transnational, technologically sophisticated and highly profitable, and seek to undermine the integrity of sport. Whilst not widespread in Australia, the threat of match fixing to Australia is high. This is driven predominantly by advancements in technology, the rise of globalised betting markets and the involvement of organised crime within match fixing. With the major events being hosted within Australia leading up to the Brisbane 2032 Olympics and Paralympics, the influx of international athletes and the high volume of betting make Australia a potential target. The Macolin convention establishes a global framework for preventing, detecting and sanctioning the manipulation of sports competitions whilst strengthening the cooperation between governments, sporting bodies, betting operators and law enforcement agencies across both national and international borders. Australia's consideration of ratification was informed by the findings of the 2018 Review of Australia's Sports Integrity Arrangements, led by the Hon. James Wood AO, KC. The Wood review found that, while Australia had strong foundations, the existing framework was fragmented and not sufficiently equipped to respond to emerging and transnational integrity threats, specifically match fixing and betting related corruption. The review recommended a more coordinated national approach and explicitly supported Australia becoming a party to the Macolin convention as a means of strengthening international cooperation and reinforcing domestic integrity arrangements. Australia signed the Macolin convention in early 2019 and, soon after, Sport Integrity Australia was established in July 2020. I acknowledge the time that has passed since signing the Macolin convention. To date, progress has included a strong focus on consultation. Through this consultation, Sport Integrity Australia has built strong stakeholder relationships. Sport Integrity Australia has an enduring commitment with a strong path forward to continue embedding obligations under the Macolin convention. Ratifying the convention legally binds Australia to a number of obligations. Ratification obligates Australia to criminalise competition manipulation and the use of inside information, which will be achieved through proposed national sport integrity offences by way of an amendment to the Commonwealth Criminal Code Act 1995. Consultation with stakeholders will continue as the ratification process continues. Ratification will formalise a number of functions and ways of working already performed by Sport Integrity Australia, such as the national platform serving as an information hub, centrally receiving, analysing and disseminating information on irregular and suspicious bets placed on sports. Through the national platform, Sport Integrity Australia contributes to the detection and disruption of match fixing and betting related corruption. Internationally, the Macolin convention has fostered international cooperation through a global network of national platforms for sharing intelligence, called the Group of Copenhagen. In December 2025 Sport Integrity Australia's head of strategy and international policy was appointed to the Group of Copenhagen Bureau and will play an important role in further enhancing the national platforms network's global response to threats and supporting capacity-building initiatives and research. Ratifying the convention also aligns with the aims of Australia's Sports Diplomacy Strategy, which positions the nation to take advantage of the opportunities presented by increased international interest in Australian sporting excellence during and beyond this green and gold decade, whilst building a protective ecosystem around Australian sport. Ratifying the convention will further contribute to strengthening Australia's leadership in sport globally and underpins our commitment to ensuring sport remains fair and transparent. As a global sporting leader, it is important for Australia to ensure integrity frameworks are robust, fair and transparent. Ratifying the Macolin convention will demonstrate Australia's commitment to international best practice, contribute to global integrity efforts and proactively protect sport in Australia from corruption. CHAIR: Thank you for that opening statement. It looks like this treaty has been in force for some time. It was first opened to signatures in 2014, and it officially took effect in 2019. Why is it only coming to us now? Can you talk us through the history. Dr Benson : I will start off and then pass to my colleagues. As I mentioned in the opening statement, we became a signatory in February 2019. Also out of the Wood review was the recommendation to stand up Sport Integrity Australia as an agency, and that occurred, as I said, in July 2020. In standing up a new agency, and amalgamating agencies and functions from three different organisations, there was a phased approach. At the same time, a number of things were being put in place. Also during that period—particular 2019-20—COVID certainly impacted and resulted in some of the protracted timeframes. So whilst, absolutely, I acknowledge the timeframe that has occurred, the ratification milestones over this period have been consistent. Some have been delayed and protracted, but the foundations, the compliance and the ratification have slowly progressed over that period. I think one of the things that we're really mindful of that positions us well, moving forward, is the deep consultation with stakeholders that has occurred, just so that we all understand what the implications, real or perceived, are, with respect to the new convention, and that, too, has taken time. But I'll pass to my colleagues to further expand on that. There is a full timeline, but I've provided a bit of an overview there just to explain where we're at now as an agency. Mr Moller : I'd only add, in terms of being compliant, that it is a complex convention, from what we understand. In terms of being compliant, as Dr Benson mentioned, national match-fixing laws are required, and that has taken some time—from drafting that, and obviously having that extensive stakeholder engagement, to making sure that those offences are fit for purpose, are compliant with the convention and also complement the existing framework we have in place in this country. We have state and territory offences for match fixing. This is about strengthening that environment. CHAIR: That actually leads in to my next question. Currently, without this convention and these changes to law, what happens? We've had various media investigations, with journalists exposing this to be a challenge for us in Australia; it's not confined to Europe alone. We have had incidents of this occurring onshore, with local sporting games and matches. So what happens currently? Where's the gap? And why are this legislation and this treaty going to help fill that gap? Dr Benson : I'm happy for you to kick off and then I'll jump in. Mr Moller : Sure. The gap exists—I'll take you back to 2011. We had a national policy on match fixing in sport. States and territories agreed to bring in consistent match-fixing legislation. That didn't happen—not all states and territories brought in legislation, and those that did didn't bring in consistent legislation. So the gaps that exist include, for example, that, in some jurisdictions, the offences don't apply extraterritorially. So, if there's no nexus to the state or territory, they can't take action against potential match fixing. We have seen sophisticated organised-crime syndicates target Australian sport for match fixing, and we have seen limitations in some of those jurisdictions not being able to prosecute certain offenders. The purpose here is to bring in legislation; it's certainly not to take away from the work of the states and territories. Many of the police forces have done significant work in this space. As you mentioned, Chair, there have been investigations conducted successfully, and that would continue. This is, essentially, target hardening the environment to provide an extra layer of protection so that, where a gap does exist, it would give that ability to target all offenders. As we have seen, match fixing is a global threat. It is very rarely confined to one jurisdiction and it can't be managed from one jurisdiction; it requires the ability to interact internationally. Dr Benson : I will just jump in. As James has highlighted, the main gap identified—and the Macolin will bridge this gap—is inconsistent state and territory legislation and regulation through the national sport integrity offences. But it also strengthens and formalises that information sharing, both domestically and internationally, which is of significant benefit in being preventive in this space. CHAIR: Okay. Let's go next to Alison Penfold, who has a few questions. Member for Lyne, you've got the call. Ms PENFOLD: What entity will be designated as Australia's national platform? Dr Benson : Sport Integrity Australia assumed the responsibility for the national platform, effective 1 January 2025, and it was operationalised on 1 July 2025. That will continue in the current arrangement. Ms PENFOLD: Okay. Can I quickly pivot to AI and data protection and privacy. The question really goes to this: given that this treaty stems from the Council of Europe, and they have far stricter data protections than Australia, is there a requirement for Australia to match those data protections? This started as essentially a European commitment, and there's a quite a gap between where Europe is and where we are, with the EU General Data Protection Regulation. Dr Benson : That's a great question. I'll pass to James to go through the detail. Mr Moller : No, in terms of being compliant with the convention, there are no changes required to data protection. In terms of what information can be shared between national platforms, that obviously is dependent on the jurisdiction. For example, in the Australian environment, if suspicious betting were to be reported by a wagering operator, it's reported to AUSTRAC as our financial intelligence unit. There are a whole raft of obligations around the security of that information, which wouldn't change. The other thing I'd highlight is that, as match fixing is criminalised and would be further under this proposal, obviously those law enforcement protections are in place. As the national platform, we're essentially the international coordination point for referring information, but, once that information turns into a police investigation, it's those usual channels of law enforcement engaging through existing networks such as Interpol. Ms PENFOLD: So, in implementing the treaty, we don't have to change our privacy legislation at this point, essentially, to be able to meet the obligations once we're a signatory? Dr Benson : No. I'll jump in and then I'll pass to Lara. Part of the Macolin working group is establishing a number of committees that sit underneath that, and one of the work priorities that they're working on is developing a toolbox which goes through the principles and guidelines and the data exchange agreement, so we will have full visibility of what those are. At this stage of the process, we won't have to change any localised legislation with respect to that to ensure compliance. But that's not to say that along the way we won't identify opportunities to strengthen our agency data protection principles. There's always room for improvement across every agency, I think, and, as we learn and as technology comes in, there'll certainly be opportunities to strengthen. I'll just pass to Lara because she might have some detail. Ms Hayes : No, I just wanted to further strengthen that response and say that Sport Integrity Australia does take our obligations under data privacy and security very seriously. We do have provisions in place to make sure that we meet those obligations currently. But, no, we don't need to change anything, at this point in time, to be compliant with the convention. Ms PENFOLD: Just one more question: do you have a policy for how you utilise AI in terms of identifying match fixing? Because it's a bit of a double-edged sword, I guess, I'm interested to know what your views are on that. Dr Benson : Yes, as an agency we're in the process of developing a data but also a digital strategy, and that incorporates artificial intelligence, both to protect against that but also to leverage the power of that to inform our functions as an integrity agency. If others want to add to that— Mr Moller : Sure. I'd probably just add that the identification of match fixing or suspicious betting is actually done, generally speaking, by wagering operators. So they're the ones. In terms of their policies on AI, I can't speak to that, but they have various ways of assessing and analysing their data. They then have various reporting requirements when they do identify something suspicious, and it's that information that we receive. So we're not in receipt of the data to analyse it specifically. We get the referrals and then we make sure they go to the appropriate law enforcement body. Dr Benson : That's probably an important point because there have been various iterations of opportunities to strengthen how we function and perform our functions in the competition manipulation space. The ratification of Macolin is not seeking to have a data vault or a central repository. It is about information sharing, so that will guide those policies and protections as well. Ms PENFOLD: Thank you very much. CHAIR: We will now go to the member for Sturt. Ms CLUTTERHAM: Thank you, everyone, for being here this afternoon for this briefing. As best you can—I was interested in hearing about what our compliance with articles 4, 5 and 9 would look like in reality. I was particularly interested in article 9 1 b and c on how broad a compliance measure might be with respect to what are described as sports betting operators. I'm interested in articles 4, 5 and particularly 9. Ms Hayes : I will talk to article 9 for a second, and that talks about the regulation of sports betting. As you would be aware, states and territories currently have responsibility for regulating wagering within Australia. That article there really speaks to what the states and territories have in place already. As part of our ratification process, we worked with the Office of International Law and the Australian Government Solicitor, and we really interrogated articles 9 and 10, particularly around what the states and territories currently have in place from a legislative and regulatory perspective to ensure we are compliant with those articles. At this point in time, there are no changes to that article. What is currently happening at the state and territory level will be happening from here on in. There's no material new to that. Ms CLUTTERHAM: That's helpful. So existing regimes are compliant, as it were, with article 9. Ms Hayes : Yes. Ms CLUTTERHAM: Is it the same philosophy for articles 4 and 5? Mr Moller : In terms of article 4, on domestic coordination, that's that national platform role that we spoke about earlier. We are already performing that function. In terms of Article 5, on cooperation with sports betting operators, as Lara mentioned, there is the state and territory gambling regulation which occurs. There is also that federal overlay with AUSTRAC that I mentioned. Wagering operators are already considered reporting entities under anti-money laundering legislation and already have those reporting requirements. Again, there are no changes. They provide that reporting to AUSTRAC, and then we as the national platform have access to that, as do law enforcement agencies. Ms Hayes : I will just make a further comment on the national platform, particularly in relation to that article. We have established a joint working group on match fixing for major sporting events, which does bring together stakeholders around major sporting events to work together to identify suspicious activity and potential competition manipulation during the lead-up to and during event time. The working group has been set up recently and will be focusing on the Women's Asian Cup, which is commencing on 1 March. That'll be a really good time for us to be able to test that. But it certainly builds upon the existing relationships, and there's nothing new, really, that has to happen other than consolidate and formalise those ways of working. Ms CLUTTERHAM: Just one more question, if I may, Chair. Thank you for that. What I'm hearing so far is that existing regimes, frameworks, laws et cetera are compliant with what we're proposing to ratify. It does suggest in our papers that Australia must also create laws that criminalise laundering of proceeds of crime relating to sports manipulation and to consider including sports manipulation within its existing money laundering prevention systems. That, to me, suggests that new legislation—laws, frameworks and what have you—is required. Is that right, through that context? Dr Benson : That is 100 per cent accurate. Yes, absolutely. We're partway through the process and working through that process. That's a critical aspect to ensure our compliance; we need those new, national, sport integrity offences to be in place in order to ensure compliance. That is the one aspect of implementation that requires that extra, additional work and the new approach. If you want more detail, there will be some more detail to my left or right. Ms Hayes : In terms of the offences, they are very much focused on criminalising match fixing, competition manipulation and the use of inside information. Existing laws and offences around money laundering and things like that we will not duplicate. These are very much carved out to be sport specific. We have done a lot of work consulting with, again, the Office of Parliamentary Counsel, the Australian Government Solicitor, the Attorney-General's Department and the AFP to ensure that the laws that we are proposing are fit for purpose and they are complementary to existing laws at a Commonwealth level. Ms CLUTTERHAM: Yes, and it's not like we're establishing a new AML/CTF regime—that already exists. Ms Hayes : No, not at all. Ms CLUTTERHAM: It's ensuring that this fits within the existing framework. Ms Hayes : Yes. Ms CLUTTERHAM: Thank you very much. CHAIR: I've got a couple of follow-ups, but before I do those we'll go to Mr Zappia. Mr ZAPPIA: If the individual states don't agree with Australia signing the convention or at least don't follow through with the intent of it, where does that leave the ability of the federal government to apply the convention, given what you said earlier, that individual states have a different way of responding and drafting their laws relating to sports fixing and the like? Ms Hayes : We can certainly talk to the level of consultation that we have done with the states and territories. As part of the Wood review, there was extensive consultation with all stakeholders, and the states and territories were a key component of that. In relation to articles 9 and 10 of the convention, we did interrogate the existing legislation and regulatory frameworks within states and territories and found that there was no additional obligation on states to do anything differently at this point in time. In the feedback that we have got as part of that Wood review and in the ongoing process of ensuring Australia's compliance in the formal ratification process, states and territories have been supportive of us ratifying the convention, so I don't at this time foreshadow any pushback from states and territories. We will continue to engage with them in an ongoing manner as we continue to mature all of these pieces of work—the national platform, the implementation of the offences and also just making sure that the joined-up approach to address that patchwork framework at the moment will continue. Mr ZAPPIA: There are other countries that I understand have now ratified the convention, and I don't know how long ago they did that. Have we been able to learn anything from those countries that have already implemented and ratified the convention? Mr Moller : We are part of what's called the Group of Copenhagen, which is a network of national platforms. Other signatories have all joined this group, essentially, for information sharing. The whole point of that network is to learn from others but also to share intelligence on match fixing. As we talked about earlier, it's an international problem, and it requires input from ideally as many countries as possible. So we certainly engage with other countries. Different countries have had a different pathway in terms of ratification. We obviously have a federated model here, hence the requirement for national match-fixing legislation. Some countries without that state and territory jurisdiction might have had a different approach, but for us that is the one thing that we need. Mr ZAPPIA: Yes, but have we learnt anything from what any other country has done in terms of what sort of legislation we should have in place and how to ensure that it's effective? Ms Hayes : Something that is quite interesting is that Australia has always been quite at the fore of these efforts to combat match fixing and competition manipulation internationally. We were certainly part of the group that drafted the Macolin convention. I'm not aware of very many other countries—and I'll defer to James for clarity—that do have this sophisticated match-fixing offence regime in place. I think Australia is always at the fore of this, and other countries actually look to us in terms of what our efforts are and what our focuses are, which is why I think, again, for us to continue the process of ratification is very important to us internationally from a reputation but also from a leadership perspective. So it's a really good point. I think that Group of Copenhagen and that national platform mechanism, as we mature with that and engage more internationally, will certainly help us with the way we do mature and operationalise our work. Mr ZAPPIA: Just lastly, Sport Integrity Australia was established some five years ago. Have there been any cases detected and prosecuted for match fixing since Sport Integrity Australia was established? Dr Benson: I'll pass to James to talk to the ones in the public domain. Mr Moller : Thank you. There absolutely have. I just would not want to overstate Sport Integrity Australia's role in those. As the national platform, we coordinate the response to match fixing, but we don't investigate or prosecute it. The examples that I can talk to are in the public domain. We obviously can't talk to any operational activities, but, certainly, we have played a role in terms of receiving intelligence from overseas. It's come to us as the national platform, we've referred it to the relevant police force and they've conducted an investigation and a prosecution. Mr ZAPPIA: No worries. CHAIR: Following on from Mr Zappia and taking on board that there are probably some cases that you can't refer to because they are currently under active investigation for potential prosecution, we know from one of the submissions we received that there has been a challenge in community football. I was wondering if you could highlight any other sports of concern. Anecdotally, I've always heard things around tennis, but, as you do as an MP, you report it to the police if you've got concerns. But I note that you have engaged extensively with quite a few sporting bodies. Are there any codes that you're particularly concerned about? Mr Moller : We haven't seen the submissions, so I'm not sure about the one you're referring to specifically, but I can talk generally to this. It might be helpful just to explain the environment more broadly. Australian sport is hugely popular for wagering, not just domestically but internationally. So what we see are significant global gambling markets and pools of money bet on our sports. When that happens in illegal markets that we have no control over, it can happen at a very low level. We can see betting markets in our amateur-level sport and in our under-18s-and-below levels of sport. So, for one, our concern is generally that illegal betting space, where we have less visibility but where we benefit from ratifying the convention. In terms of sports that are at risk, I don't necessarily want to call out specific sports, but they're generally those ones that are hugely popular in the international environment. Those sports that attract significant interest generally see large volumes wagered on them, and it's not necessarily relevant whether Australians are betting on them or not. We saw an example in Victoria many years ago where an organised crime syndicate targeted Victorian football, or soccer. The wagering was entirely offshore. There was wagering domestically but at a very low level, and it wasn't suspicious. The match-fixing syndicate was based offshore, but the athletes were in Australia. The matches were in Victoria. In that instance, police were able to take action, but, due to the limitations of the legislation in that jurisdiction, they weren't able to target all of the offenders involved. It is a really good case study as to the risk and how this convention can help in response. CHAIR: On whom you consulted with, I note that you did consult with Responsible Wagering Australia, and we have invited them to appear before us as one of the witnesses. Did you also consult with any of the alliances around gambling reform? Did you invite them? Did they choose not to participate? I am thinking of alliances like the Alliance for Gambling Reform—the one that is headed up by Reverend Tim Costello. Ms Hayes : No, we haven't explicitly engaged with those stakeholders. Our focus is very much on sport integrity outcomes and aligning with the Macolin Convention, which is very much focused on sport integrity outcomes and the links between match fixing and betting related corruption. So, no, we haven't. CHAIR: We've invited them to come and give evidence to our inquiry to see if they've got a view on the treaty that is before us at the moment. It doesn't look like my other colleagues have any questions, so I've just got a few concluding remarks before we finish this hearing for today. Thank you for your attendance here today. You will be sent a copy of the transcript of your evidence and will have the opportunity to request corrections to transcript errors. If you've been asked to provide any additional information, please forward it to the secretariat by close of business Friday 27 February 2026. Committee adjourned at 15 : 45