Submission to the National Anti-Corruption Commission (NACC)
Alleged Systemic Corruption and Procurement Misconduct Involving Dee Madigan, Campaign Edge, and Campaign Edge Sprout
Date: 13 July 2025
Submitted by: Burchell Wilson
Executive Summary
This submission presents evidence of serious and systemic breaches of procurement integrity involving political strategist Dee Madigan, her communications firm Campaign Edge, and its Northern Territory arm Campaign Edge Sprout.
Dee Madigan is not a commercial figure in any conventional sense. She has few, if any, genuine commercial clients. Her firm, Campaign Edge, works predominantly for trade unions and the Australian Labor Party. The business operates less as a private sector communications agency and more as an embedded political service provider to the Labor movement.
Since 2015, her firms have received over $2.5 million in government contracts, many without open tender, many politically adjacent in content, and many awarded under circumstances that breach procurement norms or suggest political patronage. These contracts often escaped scrutiny through mechanisms such as direct sourcing, selective tendering, and contract splitting—tactics that appear calibrated to avoid the transparency and accountability mandated by the Commonwealth Procurement Rules (CPRs) and equivalent state frameworks.
This pattern also extends to Campaign Edge Sprout, led by Anya Lorimer in the Northern Territory, which has operated under the Campaign Edge brand since 2017. While nominally independent, Sprout's political alignment and commercial relationship with Madigan’s firm strongly suggest a coordinated model of influence and preferential access to public contracts.
We respectfully submit that this is not isolated conduct but a coordinated and systemic use of taxpayer-funded procurement to reward political allies. The conduct appears to meet the definition of corrupt conduct under the NACC Act, including improper influence in public administration, abuse of office, and the misuse of public resources. It demonstrates a breach of public trust, raises serious probity concerns, and demands thorough scrutiny.
Dee Madigan and Campaign Edge
Dee Madigan is:
Creative Director and principal of Campaign Edge.
A core strategist in multiple ALP state and federal campaigns.
A regular ABC panellist (Gruen, The Drum), and partisan political commentator.
A board member of progressive think tanks (Australia Institute, Centre for Responsible Technology).
Her firm, Campaign Edge, is structurally and ideologically embedded within the ALP's electoral and advocacy machine. It does not operate as a conventional commercial agency competing in an open marketplace. The overlap between its political work and taxpayer-funded contracts raises acute probity risks.
Campaign Edge has performed little to no work for commercial clients in competitive markets. Its revenue stream is overwhelmingly derived from union campaigns, political party advertising, and public sector communications projects awarded without competitive tender. This reality undermines any claim to commercial independence and instead suggests that the firm’s survival relies on political alignment and insider access.
These projects were awarded under ALP governments or departments with long-term ALP-aligned senior staff. Many were issued during periods of urgency or "sensitive communication needs"—common justifications used to bypass open tendering. Notably, several contracts were subdivided to remain below thresholds that would otherwise require public advertising and market testing.
Comparison with Other Communication Firms
To assess whether Campaign Edge/Sprout received unusual treatment, we examined how how similar-sized communications and advertising firms fare in public procurement:
In the Commonwealth sphere, many small agencies compete for communications contracts. For instance, Audience Group and Heard Agency (independent firms) also did DHA projects, but typically at lower values than Sprout and presumably focusing on different regions or campaigns. None of these firms, to our knowledge, had principals who were simultaneously high-profile political campaigners for the government of the day. They likely won work based on capability and locality (Audience Group is Brisbane-based; Heard Agency in Sydney, etc.). If those firms were required to go through open tenders or panels for comparable contracts while Campaign Edge/Sprout was hand-picked for some of theirs, that discrepancy is telling. The Commonwealth Procurement Rules apply equally to all – no firm should get a shortcut. A preliminary review shows that much government communications work is sourced via established panels or at least multiple quotes. The pattern of recurrent direct engagements of Campaign Edge Sprout by DHA in 2019–21, for example, stands out and should be benchmarked: did DHA ever openly advertise those marketing contracts or invite multiple agencies to propose concepts? Or was Sprout uniquely approached (perhaps due to being local to NT)? At a minimum, the lack of transparency around those awards is concerning – we have only the end-of-year disclosures, not any tender records.
In the Northern Territory, as described, Campaign Edge Sprout sits alongside many peers on formal panels. The difference is the extra-contractual favouritism it seemingly enjoyed. Other NT communications firms – e.g. Associated Advertising & Promotions, Captovate, True North Strategic Communication, KWP! – do significant government work but none have been reported to receive similar off-panel financial benefits or to have their rejected grant applications mysteriously approved by a CEO. In fact, the NT Independent’s investigation highlighted Sprout as an outlier in receiving stimulus funds that 1300 other businesses got only by meeting the criteria (many of those being hospitality and tourism outfits for whom the fund was intended). This suggests a double standard in how rules were applied.
Another benchmark is how previous federal governments approached communications contracting with politically affiliated firms. It has been observed that governments often avoid using advertising agencies overtly tied to their political party, to prevent perceptions that public funds are indirectly subsidizing party campaigning. For example, a firm known for running a Liberal Party campaign would likely not be hired for a major federal government advertising contract under a Liberal government, for fear of critique (and vice versa for Labor). In the case of Campaign Edge, Ms. Madigan’s profile as an ALP campaign strategist is well known. Despite this, her company obtained multiple contracts from government entities especially once Labor governments were in power (NT Labor from 2016, federal Labor from 2022, etc.). The timing and pattern could indicate that normal reluctance was overridden – which again points to possible political interference or bias in procurement decisions.
In summary, compared to peers, Campaign Edge/Sprout appears to have benefited from more frequent sole-source or limited competitions and even one-off financial awards that others did not get. This unequal application of procurement rules undermines the level playing field that should exist and suggests improper influence.
Structural Conflict of Interest
Dee Madigan’s concurrent roles as:
ALP campaign strategist,
Media commentator on government policy,
Contractor to government departments,
constitute a structural conflict of interest. These roles are not disclosed in procurement registers, nor is there evidence of any formal mitigation.
It is reasonable to infer that public servants awarding contracts to Campaign Edge were aware of Madigan’s political role, particularly given her high-profile media presence. The failure to treat this affiliation as a declared or perceived conflict of interest reflects systemic weakness in public sector governance. This constitutes a likely breach of procurement probity standards across jurisdictions and undermines confidence in government neutrality.
Breach of Procurement Rules
Both Campaign Edge and Campaign Edge Sprout were engaged:
Without open tender,
With limited or no justification recorded,
With repeated splitting of projects to avoid thresholds,
In circumstances that favour politically affiliated suppliers.
This appears to violate the following principles:
Commonwealth Procurement Rules (CPRs):
Rule 6: Value for money
Rule 7: Encouraging competition
Rule 10.9: Prohibition on contract splitting
NT Procurement Framework:
Principles of fairness, value, and transparency
Open tender required for contracts over $100,000
Public procurement is governed not only by statutory compliance but also by public trust. These rules exist to ensure taxpayer money is spent transparently, competitively, and without favour. The consistent failure to test the market or provide justification for direct awards to Madigan's firms suggests a breach of these fundamental expectations.
This timeline underscores a close relationship between ALP political control and procurement activity favouring Campaign Edge and Sprout. While correlation is not causation, the pattern is sufficiently consistent to raise serious concerns.
Legal Context – Potential Corrupt Conduct
Under the National Anti-Corruption Commission Act 2022, conduct may be considered corrupt if it involves:
Improperly exercising public power,
A breach of public trust,
Misuse of information or resources for personal or political gain.
The systematic awarding of contracts to Dee Madigan's firms, without proper process and under politically favourable conditions, appears to fall within this scope.
Additional applicable laws:
Relief Sought
We respectfully request the NACC:
Initiate a full investigation into all government contracts awarded to Campaign Edge and Campaign Edge Sprout since 2015.
Examine the personal role of Dee Madigan in securing work through political association.
Investigate whether government officials were influenced by Ms Madigan’s profile or political connections.
Assess whether any criminal conduct or maladministration has occurred.
Recommend procurement reforms to prevent recurrence, including disclosure requirements for politically affiliated contractors and mandatory public tender for communications contracts over $50,000.
Conclusion
The pattern of government dealings with Dee Madigan’s Campaign Edge and Campaign Edge Sprout, as detailed above, suggests a convergence of private political interests with public resource allocation that may have crossed the line into corruption. We urge the NACC to use its mandate to follow the money and the decision-making trail. If public officials breached public trust or abused their offices in these transactions, they should be held to account and the integrity of procurement processes restored. Conversely, if the NACC finds legitimate explanations for each instance, that transparency will equally serve the public interest by clearing the air. The goal of this complaint is to ensure that government contracting is free from patronage and corruption, and that any wrongdoing in this case is exposed and prevented in the future.
Appendix
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