3.3 Organisation culture

Organisation culture is a combination of shared assumptions, norms, values and beliefs understood and demonstrated by officers.

Culture influences decision making, focus, systems and behaviours. It is often described as, “the way things get done around here”.

Cultures built on integrity are characterised by openness, transparency, accountability and trust. Leaders play a significant role in normalising integrity by modelling, communicating and reinforcing it as part of everyday business – but it is everyone’s job to maintain it.

A culture that values and prioritises integrity does not emerge by chance. It takes time and effort, and involves clear expectations, recruiting the right people, inducting new officers, ongoing education, and leaders modelling and reinforcing the desired behaviours. Each element of an authority’s integrity framework is a lever for the authority head to establish and maintain a culture built on integrity.

Why is organisation culture important?

Organisation culture influences attitudes and behaviours. It determines the behaviours and expectations of the authority’s senior leadership in practice. This includes whether policies, procedures and other internal controls are followed and implemented.

A culture built on integrity, with an alignment between what leaders say and do, gains the trust of the workforce. This trust supports an environment where officers may be more willing to speak up and report integrity breaches. Corruption by nature is hidden, so reporting by officers to uncover it helps minimise loss and damage.

Ideas for good and better practice for organisation culture

Good practice

  • Base all decisions on merit and transparency.
  • Provide examples of successes and failures related to integrity including reasons why and lessons learnt. The more officers understand what acting with integrity looks like, the more likely they are to conform to values and standards.
  • Educate officers how to respectfully challenge behaviours that do not align with expectations, values and standards. Encourage officers to hold themselves and colleagues accountable.
  • Align practice with expectations, values and standards. Take action if there are inconsistencies.
  • Make risk awareness part of the culture. For example, leaders demonstrate their commitment to identifying and managing risks, and officers accept collective responsibility for managing risks and reporting control weaknesses.
  • Identify indicators that may suggest integrity is eroding such as:
    • not or no longer addressing non-compliance
    • leaders no longer demonstrating values
    • practice no longer aligning with expectations, values and standards
    • growing reluctance among officers to raise integrity concerns.
  • Evaluate and manage practices.
    • Ask questions about integrity and ethical behaviour in the workplace such as via a workforce perception or climate survey. Focus groups can add depth to the information gathered. Deal with identified gaps as a priority – the workforce expects things to be done as a result of the exercise.
    • Examine officers’ awareness of integrity and their attitude towards it by:
      • asking them to describe what integrity looks like in their team
      • testing their knowledge of reporting pathways
      • asking if they are comfortable reporting integrity breaches
      • testing their knowledge and application of expectations.
    • Evaluate data to identify trends and integrity themes including:
      • discipline cases, misconduct reports and public interest disclosures (with appropriate confidentiality observed)
      • exit interview and survey results
      • grievances lodged (subject and outcomes)
      • rates of officer turnover and unplanned sick leave
      • stakeholder complaints and compliments.

Better practice

  • Have a dedicated integrity or conduct and standards function led by a member of the senior leadership team.
  • Establish senior integrity positions such as a chief risk officer and chief integrity officer.
  • Set up specific committees and forums dedicated to risk and/or integrity matters.
  • Establish formal reporting channels to the senior leadership team.

3.3.1 Integrity communications

Integrity communications lets an authority’s stakeholders know about its approach to integrity, informs officers about integrity and reinforces ‘tone from the top’. A communications program needs to:

  • be consistent and have a pro-integrity message
  • express expectations, values and standards
  • be clear that behaviour that lacks integrity is not tolerated and is treated seriously if it occurs or is reported.

Ideas for good and better practice for integrity communications

Good practice

  • Have an integrity communications plan with:
    • objectives
    • target audiences
    • key messages for each audience
    • channels to be used
    • frequency of communication
    • resources needed and how much they cost
    • risks that may affect success
    • measurement and evaluation.
  • Run integrity campaigns to build trust and engagement around integrity; focus attention on high, new and emerging integrity risks; and help change attitudes and behaviours on an integrity issue. Campaigns can be simple, produced in-house at low cost or be more complex. International Anti-Corruption Day (9 December each year) is an ideal time to raise anti-corruption awareness.
  • Tailor messages to the target audiences. Use a variety of internal, verbal, team and electronic channels when communicating with different internal and external audiences to maximise the reach of messages.
  • Make information about integrity accessible via the intranet (including the framework, integrity policies and procedures, and campaign materials).
  • Publish a statement on the website to communicate the authority’s position on integrity and how it does business (sometimes called a statement of business ethics).
  • Include integrity statements or integrity/probity clauses in contracts and dealings with suppliers. Require integrity declarations in requests for quote and tenders.

Better practice

  • Reinforce the importance of integrity at key times, for example during the holiday season when gifts are more likely to be offered.
  • Deliver integrity messages via blogs, vlogs, interactive games and scenarios.
  • Use de-identified case studies to demonstrate the importance of complying with expectations, values and standards, and the consequences of non-compliance.
  • Explain to clients, suppliers and stakeholders the standards expected of them and inform them of the standards expected of the officers they work with. Tell them how to report suspected integrity breaches they may see or experience.

3.3.2 Speaking up

Speaking up is where officers openly identify and raise concerns about how integrity is practiced; ask questions and offer new ideas; identify mistakes early; and respectfully challenge the status quo without fear of reprisal, retaliation or penalty.

Common barriers to speaking up include officers not knowing how to report integrity concerns, believing that speaking up is unwelcome or, if they do speak up, that no action is taken.

Officers who perceive the organisation culture as open, transparent and trusting are more likely to speak up. Speaking up needs to be genuine and a shared behaviour, modelled by leaders, and supported by formal internal and external reporting pathways.

Ideas for good and better practice for speaking up

Good practice

  • Provide clear instructions for how officers – and, where relevant, clients, suppliers and stakeholders – report. Incorporate advice about what to report and when, type of information required, how to report and to whom.
  • Have multiple reporting pathways for officers and, where relevant, clients, suppliers and stakeholders. External pathways like the Public Sector Commission (minor misconduct) and Corruption and Crime Commission (serious misconduct and unexplained wealth) are examples.
  • Provide for anonymous reporting. This can ease fear of reprisals and may be the difference between finding out about an integrity breach or practice matter or it remaining hidden. If there are limitations on anonymous reports, make sure these are stated upfront.
  • Support and protect officers who report and take action to avoid adverse outcomes for them. Victimisation of people who speak up cannot be tolerated and those who engage in victimisation should be identified and dealt with appropriately.
  • Educate managers about pathways to report integrity concerns. This includes the public interest disclosure process (PID) and who the PID officers are.
  • Give leaders and managers the skills to be responsive and credible when dealing with integrity concerns. What leaders say and do can influence whether officers feel safe to speak up.
  • Reiterate to officers, clients, suppliers and stakeholders that reporting integrity concerns is both positive and encouraged. It helps protect the authority and wider community from the effects of integrity breaches and provides information that can be used to address issues early.
  • Collect and analyse data on the number of reports received, what they are about and which pathways are used to report. Use this to make necessary improvements.

Better practice

  • Offer a telephone or online ‘hotline’ that can be used to seek integrity advice and report suspected integrity breaches. Hotlines complement other reporting pathways. Public interest disclosures cannot be lodged through hotlines unless the person staffing it is a designated PID officer.
  • Follow-up with those who report breaches and monitor for any signs of reprisal.
  • Use integrity concerns raised or reported as lessons learned in integrity education (with confidentiality in mind).
  • Thank officers who raise and report integrity concerns. This recognises that in many cases it takes courage to speak up.

Completing the integrity framework template

In this section of the framework, outline the actions and initiatives that develop and maintain a culture built on integrity including:

  • how the authority communicates with stakeholders and any planned integrity-focused campaigns
  • pathways for officers, clients, suppliers and stakeholders to speak up
  • protections and support for officers who report suspected integrity breaches.

Describe how integrity practices are evaluated and managed such as through:

  • workforce surveys
  • focus groups and specialist committees
  • data holdings/sources that are assessed
  • reports and dashboards on cultural indicators.
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