Newly released court transcripts show how businesses have used agents in China to make cash payments for contracts, write Angus Grigg and Lisa Murray.
At a popular tea house in the southern Chinese city of Changsha, the head of a local college is being handed an envelope stuffed with 50,000 yuan ($10,400) in cash.
It's mid-2010 and Australian education providers are scrambling for a piece of China's newly opened vocational training market.
But while the sector promises riches for those able to get their curriculum accepted by local universities, most foreign institutions don't have the connections to go it alone in China. 
That's how a travel agent, who claimed to be representing Melbourne's Box Hill Institute, a government-funded TAFE college, came to be delivering envelopes of cash in a Chinese tea house. As recently released Chinese court documents detail, this was not an isolated example.
The Australia Financial Review reported this week two other Australian education providers and two companies were named in corruption cases which resulted in jail sentences ranging between five years and 10 years for the government officials who accepted the bribes.
And there promises to be more names to come, as President Xi Jinping's corruption campaign enters its fourth year and prosecutors investigate business deals going back more than a decade.
All but one of the Australian organisations named by the Financial Review used an agent or third party, who ultimately delivered the illicit payments.
It is a structure commonly used in China, allowing foreign firms and institutions to distance themselves from any potential acts of bribery, while enjoying the benefit of deals negotiated by their local agents.
All the Australian institutions named in the Chinese cases have denied any knowledge of the bribery and promised "reviews" and "investigations" into their business practices. But the example of the Box Hill Institute shows how easily a foreign institution can lose control of the process.
According to a statement by the Box Hill Institute, it engaged an agent, International Applied Education Group, to help with its expansion across China. This agent was paid "fees as a result of their ongoing administration and for liaising directly with the college".
But the local agent, employed by the Box Hill Institute, appears to have secretly engaged a middleman in Hunan, who doubled as a travel agent, to help with introductions in that province.
This ultimately saw the Box Hill Institute get its syllabus accepted by the Hunan Trade and Business Vocational College.
For this to happen, however, the local agent, named only as Mr He, needed his cut.
The court files show the Box Hill Institute's Chinese agent paid Mr He a fee of 319,200 yuan ($66,500) or the equivalent of 1000 yuan for each student enrolled in the course.
This was then shared with the head of the Hunan College, Huang Jianzhong, who had the ultimate authority to make a decision on use of the Australian syllabus.
According to the court documents Huang received 90,000 yuan ($18,7600) in two payments as a "thank you" from the travel agent - the last of these in the tea house - and was sentenced to 10 years jail in 2014 for accepting these and other bribes.
"We are greatly disappointed to find out that an international agent purportedly working on our behalf has been involved in this case," said the group chief executive of the Box Hill Institute, Norman Gray.
"We will be conducting a thorough review of all of our existing international agent agreements."
The University of Southern Queensland and Melbourne Polytechnic were also named in a separate corruption case.
This involved a 100,000 yuan bribed, paid by a third party, for the extension of their co-operation agreement with a university in Zhejiang Province, outside Shanghai.
Both have denied any knowledge of the bribes being paid and have pledged to conduct investigations and review their business practices in China.
The bigger question is how widespread are these practices? This is especially pertinent given Australia provides an estimated 30 per cent of the nearly 700 joint foreign education programs in China.
Australian TAFE colleagues alone had 91 partnerships in China providing course to 42,500 students in 2014, according to education academic Liu Yufeng.
Michael Mills, a partner with law firm Quinn Emanuel Urquhart & Sullivan and a specialist in white collar crime, said Australian companies could still be liable for bribes paid by agents or a third party.
"The fact that payments were made through an agent will not of itself prevent a conviction," he said.
"We also note that the agent may themselves face criminal charges under Australian or foreign law."
These cases in China have come to light at a time when the Australian government is under pressure to strengthen its foreign bribery laws, which are currently the subject of a Senate inquiry.
The International Bar Association said in a submission Australia's foreign bribery laws were ineffective and there was "almost no enforcement action".
While the laws have been in place since 1999, the first criminal prosecution only began in mid-2011.
In contrast, both the United States and United Kingdom have strong legal frameworks to prevent corruption.
The senate economics references committee is due to report its findings on   July 1 and an overhaul of the laws is expected. But even before this, the federal government has shown a willingness to toughen related laws.
This week new legislation was introduced to parliament in an effort to strengthen Australia's criminal code. The new laws will allow regulators to more easily investigate and punish companies "facilitating, concealing or disguising" bribery through their books and records.
Mills noted these laws in "in some respects" go further than is required by Australia to meet its obligations under the OECD Convention on Combating Bribery of Foreign Officials.
For Transparency International, the stiffened laws mean Australian firms now have to take the issue more seriously.
"It is now critical for Australian companies to review their anti-bribery compliance regimes to enhance payment disclosure protocols, internal controls and monitoring," said the chief executive of Transparency International Australia, Phil Newman.
"There is a lack of awareness among Australian companies about our foreign bribery laws. It is not well known that if one of its agents participates in bribery, the Australian company is also responsible."
Newman is pushing for the government to provide more support for Australian companies operating overseas.
"The big multinational companies have considerable resources to invest in risk and compliance and, predominantly, they will do the right thing.
"They have the necessary systems in place, but smaller to medium-sized firms don't always have the capacity and resources to invest in that area."
Newman's comments are particularly relevant as it is small and medium enterprises, which are pushing into China, looking to profit from rising incomes and the opening up of the services sector.
And apart from healthcare a key area of focus for Australia companies is education, a sector, which is notoriously corrupt.
"Corruption in the education sector is systematic and normalised.
It is part of everyday life and people don't even think about it as corruption," says Rakesh Gupta, a senior lecturer at Griffith Business School in Brisbane.
"It's the reputation of the Australian education system which is at stake rather than just one business."P