Integrity framework resources

Helping WA public authorities develop or strengthen their integrity framework
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The Integrity Framework Template and the Integrity Framework Guide help an authority develop or strengthen its integrity framework. The template and guide should be read together; neither is exhaustive.

A comprehensive, well-coordinated and implemented framework helps an authority:

  • manage identified integrity risks
  • prevent misconduct and corruption
  • develop a culture built on integrity
  • have leadership oversight
  • build robust planning, performance, monitoring and review processes
  • continuously improve its approach to integrity
  • inform stakeholders, including integrity bodies, about its approach to integrity.

While the authority head is accountable for the framework, all officers are responsible for helping to prevent misconduct and corruption in their authority.

The underlying assumption is that the effectiveness of integrity management depends as much on the synergies between the instruments as on the effects of the individual instruments separately. An ethics code by itself will not have much impact; an integrity training session will not really make a difference; one inspection will probably not leave a lasting impression. It is the combination of such measures that will have a significant effect, a joint effect that is much larger than the mere sum of the effects of the individual instruments.
Organisation for Economic Co-operation and Development

What is mandatory?

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.

Questions and answers

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.

Glossary

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.

Readings

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.

Example Integrity Framework

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.

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