Integrity framework resources

Commissioner's instruction 40: Ethical Foundations requires public sector bodies under the Public Sector Management Act 1994 to have an integrity framework in place with the following minimum requirements:

• clear expectations of employees/board members in relation to integrity
• roles and responsibilities under the framework
• management of integrity based on identified risks
• development of integrity knowledge, skills and competencies of employees and board members
• reinforcement of a culture built on integrity
• review and updating of the framework
• assurance to the head of the public sector body that the framework is working as intended.

Are we required to have an integrity framework?

A comprehensive, well-coordinated and implemented framework demonstrates a strategic and proactive approach to promoting integrity and preventing misconduct and corruption. The Public Sector Commissioner encourages all public authorities to have an integrity framework. It makes good business sense.

Who can use the Integrity Framework Template and Guide?

All public authorities can use the template and guide to help them develop an integrity framework or evaluate and strengthen an existing framework. Develop and contextualise the framework to meet the authority’s legislative and operating conditions and risk profile. No 2 frameworks are the same.

Is there a link between the Integrity Strategy for WA Public Authorities 2020-2023 and an authority’s integrity framework?

Yes. The Integrity Strategy focuses on 4 improvement areas to promote integrity and help prevent misconduct and corruption. Under each improvement area are actions for the Public Sector Commission, authorities and individuals. A key action in the strategy is for authorities to develop their own integrity framework.

A framework describes in detail the instruments, structures and cultural factors that guide how an authority practices, manages and accounts for integrity. The framework builds on work an authority may have started when completing the Integrity Snapshot Tool.

We already have an integrity framework. Do we need the template and guide?

Some authorities have an established integrity framework in place while others have elements of one in place.

For those with an established framework in place, the guide can help identify any gaps in the authority’s current approach. Consider the ideas for good and better practice in the guide to strengthen established instruments, structures and cultural factors.

For those developing a new framework, the template provides a basic structure. Use the guide to help populate the template.

We have a fraud and corruption control plan. Do we need an integrity framework?

A fraud and corruption control plan is a core part of an authority’s framework as it focuses on preventing, detecting and responding to fraud and corruption risks. An integrity framework has a broader scope which considers all integrity risks as well as the instruments, structures and cultural factors an authority requires to promote integrity and prevent misconduct and corruption.

Do we need to implement all the ideas for good and better practice?

No. Some authorities may already have in place many of the ideas for good and better practice.

While authorities are encouraged to consider the ideas in the guide, not all may be necessary or feasible, or the authority may deal with things in different ways because of its size. The actions and initiatives implemented by the authority should be practical for its circumstances and contextualised for its legislative and operating conditions and risk profile.

Regardless of size, all authorities have integrity risks and a well-coordinated and implemented integrity framework helps manage them. There are many low and no cost ideas for actions and initiatives in the guide.

Does it matter who has responsibility for integrity actions and initiatives in our authority?

One of the benefits of an integrity framework is that it brings all of an authority’s integrity actions and initiatives – and those responsible for them – together.

A coordinated approach helps keep track of who is responsible, and whether the actions and initiatives under the framework are completed, evaluated and updated. The authority head also gets better oversight of the authority’s approach to integrity and assurance that the framework is working as intended.

In some authorities, individuals or teams from across the authority are custodians of the different elements of the framework. They may meet to discuss progress on actions assigned to them. In other authorities, coordination of the framework may sit with one or 2 senior officers with functional responsibilities for integrity.

How should we present our integrity framework?

The framework includes, but is not limited to, a collection of new and existing documents. For ease of access, the framework may be on the intranet with links to documents such as the code of conduct. One benefit of this approach is that it makes it easier when it comes time to evaluate or update documents in the future.

Once we have developed our integrity framework is that it?

No. Designing and documenting a framework requires leadership buy in, time and commitment to implement – but this is only the first step. The framework and approach to integrity are not effective unless the actions and initiatives are implemented. Given the framework guides an authority’s approach to integrity, it needs to be regularly monitored, evaluated and updated.

Accountability [in an ethics and governance context]: Answerability, blameworthiness, liability and the expectation of account-giving.

Approach to integrity: Way authority practices, manages and accounts for integrity.

Code of conduct: Authority’s expectations of how officers behave (minimum standards of conduct). Describes these behaviours and puts values into practice.

Complementary policies and procedures: Part of management fields like human resources, finance, and information and communication technology that, while all have integrity as an underlying principle, do not exist solely to advance integrity.

Core policies and procedures: Their main objectives and reasons for existing are to advance integrity.

Corruption: Corrupt conduct tends to show deliberate intent for an improper purpose or motivation. Corrupt conduct may involve exercise of a public power or function but for private benefit. It may involve conduct such as deliberate failure to perform the functions of the office properly, or exercise of a power or duty for an improper purpose.

Custodian: Holds a position responsible for an element of the framework (assigned or delegated).

Discretion in decision making: Making decisions based on reason and judgement rather than just on pre-determined criteria.

Governance (Governance Institute of Australia): System by which an organisation is controlled and operates, and mechanisms by which it and its people are held to account.

Instrument: Legal or otherwise formal written document which records and formally expresses an enforceable act, process, duty, obligation or right.

Integrity breach: Behaviours that range from small, culture-corroding behaviours to serious misconduct and corruption.

Internal control: Includes instruments, structures and cultural factors that seek to manage identified risks by minimising, maintaining or modifying them. Controls include, but are not limited to, processes, policies, devices, practices and systems. Controls may not always exert the intended or assumed modifying effect.

Mission statement: Supports the vision. Concise explanation of why the authority exists. Describes its purpose and intention, and communicates this to stakeholders

Policy: Purpose to address a problem, issue or change, or to control for an existing, emerging or new risk. Operationalises legislation but never overrides or conflicts with it. Source of truth for how decisions are made.

Position of trust: Role considered to carry a high integrity risk by virtue of its authority or responsibility, or due to the nature of supervisory controls operating on the position.

Public authority: Public sector agency (department, SES organisation and non-SES organisation), local government, public university, government trading enterprise, other entity and some government boards and committees.

Public officer (officer): Meaning given by section 1 of The Criminal Code and includes those appointed to, employed in and contracted to public authorities.

Procedure: Action (or ‘how to’) to progress to an outcome or produce a desired change. Operationalises policy but never overrides or conflicts with it. Where discretionary decision making is permitted, this is stated and delegations noted.

Responsibility [in an ethics and governance context]: Being in charge or being the owner of a task.

Rules-based approach to integrity: Emphasises the importance of external controls on officers’ behaviour. Characterised by formal and detailed rules and procedures to prevent misconduct and corruption.

Risk owner: Officer with responsibility for managing particular risks and implementing controls.

Authority head: Chief executive officer, director general, chief employee, board chair, vice chancellor and similar.

Values-based approach to integrity: Focuses on guidance and internal control where officers hold each other accountable for their conduct and integrity.

Vision statement: Looks forward and creates a picture of the desired state. Is inspirational and encourages officers to want to be part of the vision.

Taken together and contextualised for the Western Australian environment, these readings have informed the development of this guide.

Integrity practitioners may find them useful when designing and developing their integrity frameworks. The Public Sector Commission does not endorse all the views stated by each author.

• A guide to building workplace integrity: Indicators and practice, December 2009, Independent Broad-based Anti-corruption Commission
• Accountability vs. Responsibility, Diffen.com, Diffen LLC, accessed 20 April 2020
• Continuous improvement resources, American Society for Quality, accessed
• 26 June 2020
• Attitudes and Behavior, 21 May 2018, Simply Psychology, accessed 17 August 2021
• Attributes of Good Mentors and Mentees, Integral blog, accessed 13 August 2020
• Australian Standard 31000:2018, Risk Management Guidelines, SAI Global Infostore
• Australian Standard 8001:2021, Fraud and Corruption Control, SAI Global Infostore
• Clean as a Whistle: a five step guide to better whistleblowing policy and practice in business and government, 6 August 2019, Griffith University
• Corruption and integrity in the NSW public sector: An assessment of current trends and events, December 2018, Independent Commission Against Corruption New South Wales
• Corruption in focus: A guide to dealing with corrupt conduct in the Queensland public sector, January 2020, Crime and Corruption Commission Queensland
• Creating an Ethical Workplace, 1 April 2014, Society for Human Resource Management Foundation
• Fraud: A guide to its prevention, detection and investigation, July 2008, PricewaterhouseCoopers
• Fraud and Corruption Control – Best Practice Guide, 1 March 2018, Crime and Corruption Commission Queensland
• Fraud risk management: A guide to good practice, January 2009, Chartered Institute of Management Accountants United Kingdom
• Fraud risk management: Developing a strategy for prevention, detection and response, May 2014, KPMG Forensic China
• Guidelines on Complaint Handling, September 2020, Ombudsman Western Australia
• Guidelines: Procedural fairness (natural justice), April 2019, Ombudsman Western Australia
• Handbook of Global Research and Practice in Corruption, 2011, Edited by Graycar and Smith
• Handing misconduct: A human resource manager’s guide, November 2017, Australian Public Service Commission
• High-Quality Ethics & Compliance Program Measurement Framework, 2018, The Ethics & Compliance Initiative
• How to create a culture that encourages people to speak up, Culture Amp, accessed 9 October 2020
• How to Design an Ethical Organization, May-June 2019 Issue, Harvard Business Review
• How to turn values into standards, January 2015, Inside HR, accessed 9 October 2020
• Internal Audit: Why it’s important, 2014, The Institute of Internal Auditors Australia
• Looking back 2020: A report by the Hon. Bruce Lander QC Independent Commissioner Against Corruption, 27 August 2020, Independent Commissioner Against Corruption South Australia
• Managing Culture: A good practice guide, First Edition, December 2017, Chartered Accountants Australia New Zealand, The Ethics Centre, Governance Institute of Australia and Institute of Internal Auditors Australia
• OECD Public Integrity Handbook, 20 May 2020, Organisation for Economic
• Co-operation and Development
• Organisational design: an ideas sourcebook for the Victorian public sector, 2013, Victorian Public Sector Commission
• Perfect Place Syndrome and the 10-80-10 Rule to Ethics, Board and fraud blog, accessed 12 October 2020
• Prevention in focus, Discretionary decision-making powers: Identifying potential corruption risks, March 2020, Crime and Corruption Commission Queensland
• Public servants will devise ways to work around the rules – often with no evil intent at all, 1 September 2020, The Mandarin, accessed 1 September 2020
• Public Service and Corruption : The Palgrave Handbook of the Public Servant,
• 4 February 2020, accessed 20 July 2020
• Real integrity – Practical solutions for organisations seeking to promote and encourage integrity, 2018, University of Leeds for the Institute of Chartered Accountants in England and Wales
• Red flags…red faces: Corruption risk in public procurement in Western Australia,
• 14 May 2020, Joint Standing Committee on the Corruption and Crime Commission Western Australia
• Report of the Inquiry into the City of Perth: An Inquiry under Part 8, Division 2 Local Government Act 1995, 30 June 2020, Department of Local Government, Sport and Cultural Industries
• Report on the Misconduct Intelligence Assessment of the Western Australian Public Sector, 26 March 2015, Corruption and Crime Commission Western Australia
• Report to the nations: 2020 global study on occupational fraud and abuse, 2020, Association of Certified Fraud Examiners
• State government integrity frameworks review, 26 June 2019, Independent Broad-based Anti-corruption Commission Victoria
• The Challenge of Leadership Accountability for Integrity Capacity as a Strategic Asset, December 2001, Journal of Business Ethics, 34: 331-343
• Tone at the top: How management can prevent fraud in the workplace, Association of Certified Fraud Examiners
• Towards a Sound Integrity Framework: Instruments, Processes, Structures and Conditions for Implementation, 4-5 May 2009, Global Forum on Public Governance, Organisation for Economic Co-operation and Development
• United Nations Convention Against Corruption, adopted by the UN General Assembly 31 October 2003, United Nations Office on Drugs and Crime
• Values and Standards of the British Army, 2018, Accessed 12 April 2021
• Victorian Government Risk Management Framework Practice Notes: Risk Culture, March 2016, Victorian Managed Insurance Authority
• What is Oversight and How Does it Relate to Governance – Practice Guide to Auditing Oversight, Canadian Audit and Accountability Foundation, accessed 16 April 2021

The Public Sector Commission’s integrity framework is provided as an example for authorities.

As explained in the integrity framework guide, each authority’s framework needs to be practical for its circumstances – developed and contextualised for its legislative and operating conditions and risk profile.

The example provided is specific to the Commission, and should not be used as a template for other authorities, whose circumstances and context will be different.