The investigation discovered Ms Bellamy commenced a relationship with Soil Water's owner, Adam Pratt, in late 2016, and began working for his consultancy in an informal capacity as a 'business manager' in mid-2017. Emails and texts between the pair revealed she called herself his "secret agent" and leaked confidential information to him to give him an advantage during tender processes. She also encouraged him to keep his quotes, where possible, under $10,000 so she could sign off on an invoice without scrutiny. The CCC said Soil Water had suffered financially from the mining downturn. In March 2017, Ms Bellamy told her department she was completing a field trip to an abandoned nickel mine in the Goldfields as there was no one else available to go.

The CCC alleges she organised to go on the one-day trip with Mr Pratt, and signed off on his $6000 invoice for his time shortly afterwards, despite him having not provided any formal report from the trip. Loading When other department employees questioned where the report was, she edited a draft report by Mr Pratt on his behalf, and told him she would tell her management she had "misplaced the final report". As Ms Bellamy's involvement in Mr Pratt's consultancy firm increased, the couple moved in together. By this time, she had not disclosed her relationship with Mr Pratt, or her conflict of interest when favouring quotes from the firm, and approving payments.

Another consultant, working in the same office space as Mr Pratt, mentioned to a department acquaintance he thought Ms Bellamy was involved with Soil Water. When Mr Pratt found out, he emailed the consultant in August 2017 and told him to keep the relationship quiet, saying he wanted to use Ms Bellamy as "an ace up my sleeve to win jobs". Ms Bellamy handed in her notice the next month. During 2016 and 2017, Soil Water invoiced a total of $162,738 to the department, including work at the pilot rehabilitation sites of Black Diamond Pit Lake in Collie, Bulong Nickel Tailings Storage Facility in the Goldfields and Ellendale Diamond Mine in the Kimberley. Three of the payments were between $6000 and $10,000, and approved by Ms Bellamy, while another $110,000 payment was awarded to Soil Water by a panel, which included Ms Bellamy, after Mr Pratt allegedly became aware that figure was the department's maximum budget for the job.

Shortly after the panel shortlisted Mr Pratt's quote, Ms Bellamy sent him a text saying "Secret agent update, everything is with the boss for sign off/approval". Ms Bellamy was called into a meeting with Human Resources in mid-October, less than two weeks before she was due to resign, after an anonymous envelope was left on the chair of a manager, containing a copy of an email showing Ms Bellamy's Soil Water email signature, describing her as 'business manager'. In response, she did not disclose her relationship with Mr Pratt, and minimised her involvement with Soil Water, saying she was assisting with a "pressing matter" for a potential future employer. She then began collecting confidential reports and information relating to the Mining Rehabilitation Fund, to take with her following her resignation. On the same day as the meeting with HR, Mr Pratt texted Ms Bellamy, "Hi love, how's the afternoon rape and pillage of the data for your own personal benefit?"

To which she replied, "I am copying contacts as we speak". The CCC alleged Ms Bellamy, who was nominated for Telstra Business Woman of the Year in 2015, engaged in serious misconduct and corruptly used her position within government to procure payment to Soil Water on three occasions, and twice disclosed information to Mr Pratt that was confidential. "Her behaviour shows the need for ongoing vigilance and oversight of procurement, even when relatively low amounts are involved," the CCC said in a statement. "It also shows the need for an early disclosure of potential conflicts of interest. "Had there been an early disclosure, the problem may not have escalated."