The code of conduct needs to reflect the agency’s legislative and other requirements, including Commissioner’s Instruction 40, and adequately cover integrity risks. There are many places to source information when developing a new code or reviewing and strengthening an existing one.
Legislative context: Identify relevant legislative requirements that set out how the agency is to operate including enabling legislation. Identify legislative or broader requirements that relate specifically to codes of conduct for the agency.
Risks: Identify integrity risks associated with the agency’s work, starting with the risk register. Data and other research can also help identify risk areas such as trends and lessons learned from past integrity breaches, and risks covered in reports by and resources from integrity and oversight bodies.
Internal expertise: Draw on the expertise and knowledge of key staff to identify what should be included in the code. This also creates a sense of ownership and a commitment to success. Touch base early with the senior leadership team and subject matter experts from areas such as audit, standards and conduct, governance, risk, finance, human resources and legal. Get input from the communications team about what to include in the code and how to make it easy to read and impactful. Involve staff with responsibility for delivering training on the code so they can consider whether current training need to be updated or revised.
Reference group: In larger agencies, a reference group with broad representation may be an efficient way to identify what should be included in the code. For example, bring together key representatives from each function/area.
External good practice: Review codes of similar agencies, other high profile organisations and employers of choice to identify what to include. Contextualise any inclusions to suit the agency’s circumstances.
Internal documents: Review existing documents that relate to the code such as mission, vision, values, policies and guides. This helps inform the code’s content and ensures consistent language, terms and definitions.
