Once a code is implemented it should be regularly monitored and reviewed so it remains fit for purpose and is working as intended.
Monitoring can take many forms, for example:
- identify trends by analysing reports of suspected non-compliance and discipline processes
- have a process for managers to comment on how the code is working in practice.
Some matters may not be the result of a deficient code but may relate to other factors such as a lack of knowledge or understanding about ‘what is acceptable’. This may be better dealt with through training so staff deepen their understanding of the code.
Set a date to review the code. It may be necessary to review and update the code outside this timeframe such as in response to legislative or policy changes (internal or external), findings of reviews by external integrity bodies, significant restructures, or feedback from staff and stakeholders about how the code could be strengthened.
Effective monitoring and review
- Assign a position or team to:
- regularly/periodically review the code – schedule review dates with the option of additional reviews if the agency operating context and/or risk profile change
- remain informed of current code related advice from external oversight bodies
- ensure all links to related policies and guides are up to date
- consider any trends identified through a review of actions taken in response to breaches and feedback from staff and stakeholders.
- Identify who is responsible for monitoring the code and set this out in the code and/or integrity framework. For example, leaders and managers report suspected breaches to HR as needed; HR reports to senior leadership team quarterly.
