Integrity Strategy for WA Public Authorities 2020-2023

Policy
This strategy focuses on four key improvement areas with actions and controls to promote integrity and help prevent misconduct and corruption.

This strategy focuses on four key improvement areas with actions and controls to promote integrity and help prevent misconduct and corruption. Under each of the key improvement areas are actions for the Commission, public authorities, and for individuals.

From the Public Sector Commissioner

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Message from Public Sector Commissioner Sharyn O'Neill

Public Sector Commissioner Sharyn O'Neill

Integrity is a non-negotiable to assure Western Australians that public authorities act in the interest of the community each and every day through the decisions we make and the actions we take. 

Operating with integrity means using our powers responsibly for the purpose and in the manner for which they were intended. It means acting with honesty and transparency, making reasoned decisions without bias by following fair and objective processes. 
It also means preventing and addressing improper conduct, disclosing facts without hiding or distorting them, and not allowing decisions or actions to be influenced by personal or private interests.

Earning and maintaining community trust is essential for us to deliver the services that families, individuals, businesses and industry need for them to prosper – and for the State to grow.

We know that any breach of that trust has wide implications. The impact on our work and reputation affects us all. We also know that integrity goes beyond just legislative compliance – it is about doing the right thing because it is the right thing to do. 

Two things are critical for us to understand to see improvement – first, integrity does not happen by chance; and second, we are all responsible for protecting the integrity of public authorities. 

That is why a clear and focused approach to integrity must be at the core of our work. When integrity is a common frame of reference, it becomes a unifying force across different functions, different services and different employee groups.

Improved integrity helps minimise the incidence and impact of misconduct, including fraud and corruption. It also brings benefits in relation to performance, productivity and employee engagement. 

To ensure our work translates into exceptional public value and high community trust, I expect every public authority – and those within – to commit to implementing this strategy.


SHARYN O’NEILL
PUBLIC SECTOR COMMISSIONER

Commitment to improve integrity

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Integrity has to be embedded in all aspects of our work – in governance and administration, systems and controls, culture and attitude, and accountabilities and responses.

Improved integrity requires sustained effort which is why all public authorities are expected to commit to implementing this strategy and taking action.

Integrity has to be embedded in all aspects of our work – in governance and administration; systems and controls; culture and attitude; and accountabilities and responses.

Every day. By everyone.

All public authorities and individuals must take an interest in promoting integrity and preventing misconduct, including fraud and corruption.

While the Commission has a significant role to play, the primary responsibility for preventing misconduct, including fraud and corruption – and operating with integrity – lies with leaders and individuals in public authorities.

In this strategy, ‘public authorities’ refer to WA public sector bodies (including government boards and committees), local governments, public universities and government trading enterprises.

Those appointed to, employed in and contracted to public authorities are all covered by this strategy. 'Staff' refers to employees, board and committee members, and contractors.

Public authorities should see this strategy as an opportunity to demonstrate to the community that they are serious about integrity.

While there are no additional compliance obligations for public authorities arising from this strategy, changes may be made to the compliance framework to ensure it is contemporary and fit-for-purpose.

Over the life of the strategy, the Commission and its integrity partners will continue to ask leaders to report if and how integrity is improving. This may be through surveys, audits or reviews. Leaders of public authorities should consider how they monitor and evaluate integrity as a priority.

Integrity model for WA public authorities

Key actions to achieve our goals

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This strategy focuses on four key improvement areas with actions and controls to promote integrity and help prevent misconduct and corruption.

There are many well-documented dimensions needed to ensure strong integrity in public authorities.

This strategy focuses on four key improvement areas with actions and controls to promote integrity and help prevent misconduct and corruption.

Under each of the key improvement areas are actions for the Commission to implement to provide leadership and support to public authorities.

There is also a cohesive suite of practical and achievable actions for public authorities to put in place, and for individuals – those appointed to, employed by and contracted to public authorities – to do. 

This three tiered approach across the four improvement areas reflects the responsibilities that every aspect of the government sector has in relation to integrity. Actions at any one tier – or actions in only one area – are not enough. The strength is in the three tiers working together across the four improvement areas.

As public authorities have differing needs and contexts, they should adopt those actions appropriate for their circumstances in a way best suited to their needs.

The strategy also provides a common language for how we talk about integrity across public authorities.

The strategy has four key improvement areas, with actions for the Commission, public authorities and individuals.

1 Plan and act to improve integrity

Effective governance systems and frameworks are established.

2 Model and embody a culture of integrity

A culture of integrity exists, and is reinforced and communicated by leaders.

3 Learn and develop integrity knowledge and skills

Individual and authority integrity knowledge, skills and competence are grown.

4 Be accountable for integrity 

Prevention, detection and response to integrity matters are everyone’s personal and professional responsibilities.

1. Plan and act to improve integrity

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Effective governance systems and frameworks are established.
 

Actions for the Commission

Actions for public authorities

Actions for individuals

1.1

Publish framework

Publish an integrity framework which includes instruments, processes, conditions, systems and control requirements that public authorities should have in place to support integrity; and detect, respond to and prevent misconduct including fraud and corruption.

Improve integrity framework

Align approach to the integrity framework (as a minimum).

Understand and act

Ensure you understand your public authority’s code of conduct, policies and procedures; and act accordingly.

1.2

Encourage self-assessment

Develop a self-assessment tool for public authorities to assess the maturity of their integrity framework to assist in improvement planning.

Continue to improve

Use the integrity framework maturity self-assessment tool to assist in improvement planning.

Identify risks and opportunities

Alert managers/supervisors of any gaps in your public authority’s code of conduct, policies and procedures that may provide opportunities for misconduct.

1.3

Use data to drive change

Use data collected from public authorities to create an online dashboard with analytics for them to use in planning, including to benchmark their integrity environment against like public authorities.

Use data to drive change

Use tools such as the online data dashboard to benchmark against like public authorities, and use data to assist planning.

Be accountable

Take responsibility for the decisions you make and the actions you take to ensure they are in the public interest.

1.4

Provide planning guidance

Make exemplar misconduct prevention plans available for use by public authorities.

Reassess approach

Review regularly approaches to prevention and develop initiatives for improving integrity.

 

1.5

Investigate detection systems

Examine detection approaches that identify irregularities and provide early warning including software to monitor and evaluate data, systems to share intelligence, and a central register of individuals subject to adverse findings to assist with pre-employment screening.

Evaluate detection systems

Evaluate current systems, including pre-employment checks, and data to inform detection and prevention of irregularities and corrupt practice.

 

1.6

Link to audit and risk

Assist public authorities to assess governance controls which help identify, monitor and report on integrity matters.

Audit and risk controls

Ensure audit and risk controls are in place and aligned to identify integrity vulnerabilities and risks.

 

2. Model and embody a culture of integrity

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A culture of integrity exists, and is reinforced and communicated by leaders.

 

Actions for the Commission

Actions for public authorities

Actions for individuals

2.1

Prioritise integrity

Promote and prioritise integrity as a key value across public authorities.

Prioritise integrity

Review corporate values to ensure integrity is included and promote these values internally and externally.

Model values

Ensure daily behaviours, actions and decisions demonstrate your public authority’s values. 

2.2

Ensure a contemporary approach

Review integrity instruments and products to support contemporary approaches to integrity and guide conduct in public authorities.

Develop together

Involve staff in reviewing ethical codes, values, integrity policies and procedures so shared understanding is achieved.

Contribute to cultural health

Respectfully challenge conduct that is not in accordance with your public authority’s values and code of conduct.

2.3

Listen and respond

Develop resources to assist public authorities to seek and act on staff perceptions about their public authority’s integrity culture.

Evaluate and build

Use Commission and other high quality resources to evaluate and build an integrity culture.

Take action early to address matters

Speak up to ensure conduct that does not align with your public authority’s values is addressed early and, where possible, take action to avoid escalation or repetition

2.4

Give feedback

Build skills of leaders to set behaviour expectations for their staff, give feedback, manage conduct and have difficult conversations.

Build capability

Support leaders to promote a culture of integrity through professional learning, setting expectations for behaviour and building skills in having difficult conversations about conduct.

 

2.5

Set clear expectations

Support public authorities to set clear behaviour expectations through codes of conduct, recruitment and performance processes.

Set clear expectations

Recruit for values alignment and ensure behaviour expectations are clear in codes of conduct and staff performance agreements.

 

2.6

Promote a speak up culture

Share good practice in managing reporting to facilitate positive outcomes for those who speak up.

Embed practice

Embed good practices and mechanisms to encourage and support staff who speak up.

 

2.7

Promote an integrity mindset

Conduct campaigns to promote an integrity mindset such as “All in a day’s work” related to gifts and benefits.

Adopt the mindset

Use campaign materials to ensure staff are conscious of misconduct risk areas and how they should respond.

 

* ‘Staff’ refers to all employees, board and committee members, and contractors.

3. Learn and develop integrity knowledge and skills

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Individual and authority integrity knowledge, skills and competence are grown.

 

Actions for the Commission

Actions for public authorities

Actions for individuals

3.1

Share and collaborate

Establish an integrity practitioners’ group to collaborate on strategic approaches to detecting and preventing misconduct, and promoting integrity.

Participate actively

Participate in integrity promotion and misconduct prevention initiatives and share learnings with staff.

Participate actively

Participate actively in integrity learning opportunities provided by your public authority.

3.2

Be a functional area leader

Provide practical advice and information to public authorities including forums and community of practice sessions on integrity matters.

Induct and train staff

Deliver integrity training to new staff early in their employment and implement regular integrity training for all staff.

Support new staff

Inform new colleagues about your public authority’s code of conduct, policies and procedures associated with their work.

3.3

Offer online training

Introduce online integrity learning modules for use by public authorities.

Educate for prevention

Inform staff about misconduct and their role in reporting and preventing it.

Inform yourself

Seek information about, and advice on, situations where integrity matters arise.

3.4

Induct new staff

Work with other integrity agencies to develop an online integrity induction program for public authorities to use with their staff.

Improve continuously

Be proactive in looking for integrity improvements and learning by completing the Integrity Snapshot Tool.

 

3.5

Share information

Publish insights from data and the work of integrity partners to inform public authorities about current and emerging integrity risks and strategies.

Capability gaps

Evaluate the capability of key integrity staff, and identify knowledge and skill gaps that require further training or development.

 

3.6

Share resources

Establish an integrity section on wa.gov.au with accessible, practical and up-to-date information and resources.

Use insights

Learn from Commission and other integrity agency insights; and use them to review and reassess the approach to integrity risks, areas of vulnerability and prevention.

 

3.7

 

Adopt contemporary practice

Keep up to date by referring to the integrity section on wa.gov.au when developing and reviewing integrity policies and systems.

 

4. Be accountable for integrity

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Prevention, detection and response to integrity matters are everyone’s personal and professional responsibilities.
 

Actions for the Commission

Actions for public authorities

Actions for individuals

4.1

Clarify accountability

Ensure public authority leaders understand their responsibilities for preventing, detecting and responding to integrity matters; and take proactive action.

Report misconduct online

Use Commission and Corruption and Crime Commission online reporting tools to notify of misconduct in a timely manner.

Report issues

Assist your authority to detect misconduct by reporting suspected misconduct either through internal or external reporting processes.

4.2

Provide authority

Investigate models of misconduct management that enable more local decision making while maintaining appropriate oversight.

Oversee integrity

Have leadership teams lead, own and oversee processes for identifying, detecting, managing and preventing misconduct.

Lead at all levels

Contribute to creating an environment where everyone is comfortable with and confident to report any suspicions of misconduct.

4.3

Improve online reporting

Redevelop existing online misconduct reporting tools to improve the quality and types of notifications and reports made.

Review for learning

Use learnings from Commission reviews to evaluate current practices and make changes.

Responsible teams

Take responsibility for operating with integrity in your team and encourage others to do the same.

4.4

Review for performance

Conduct specific and thematic reviews, and use information from capability reviews to identify areas of good practice and those requiring improvement.

Respond to risks

Understand that specific risks change over time and take steps to ensure these are responded to and addressed.

 

4.5

Collaborate for improvement

Partner with external experts to participate in research and projects that identify contemporary approaches, including behavioural insights and technology to enhance detection and prevent misconduct and corruption.

Take action

Put processes in place to support staff and community reporting, and empower leaders to act on reports of misconduct.

 

4.6

Leverage expertise

Pursue methods that enable greater shared use of expertise and trained investigators across public authorities.

Be accountable

Ensure integrity is a standing agenda item at leadership meetings to provide a forum to interrogate data, and identify and respond to emerging trends.

 

Measures of success

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To know how we are progressing towards building and sustaining a high integrity culture across public authorities, we need ongoing evaluation of our success.

To know how we are progressing towards building and sustaining a high integrity culture across public authorities, we need ongoing evaluation of our success. The ultimate success is stamping out misconduct, including fraud and corruption.

Commission signs of success Public authority signs of success
  • Approaches to integrity are maturing across public authorities over time, as demonstrated by reviews conducted by the Commission.
  • Public authority leaders acknowledge the value of assistance provided by the Commission and seek to collaborate with the Commission on integrity matters. 
  • In surveys conducted by the Commission, staff report perceptions that public authorities and leaders operate in a high integrity culture.
  • There is increased usage of the Commission’s products and tools, including online learning modules.
  • Commission forum/sessions are well attended and evaluations indicate knowledge has increased as a result of attendance.
  • Amendments to online reporting tools assist reporting and notification processes, and the quality of reports to the Commission improves over time. 
  • Public authority has implemented or exceeded the requirements of the integrity framework. 
  • Commission evaluation and benchmarking tools indicate the public authority is well positioned in regards to governance, culture, education and accountability.  
  • Survey data shows high staff perception of integrity in the public authority. 
  • Survey data shows staff have a good understanding of policies, procedures and ethical codes. 
  • Training and information sessions related to integrity are well attended.
  • Time taken to resolve integrity matters is reasonable and results in improvements where necessary.  
  • Evaluations of reports to integrity bodies indicates reports are timely. 
  • Responses to integrity matters and results of reviews and audits are considered and implemented.

Monitoring signs of success are commenced from the start of this strategy and reviewed each year. Progress against these measures is reported periodically over the next four years.

Consider what other internal measures may indicate integrity is improving. Evaluations should be shared with staff.

 

Documents

Integrity Strategy for WA Public Authorities 2020-2023
Page reviewed 3 March 2020