The Commonwealth uses a multi-agency approach to promote integrity, transparency and accountability and to prevent corruption, fraud and misconduct. In order to build an integrity system greater than the sum of its parts, a strategic approach to governance is required. There is a rich vein of untapped cross-sectoral knowledge, insight and experience within integrity policy and oversight agencies. Bringing together agency heads who know the integrity picture across the whole APS will enable discussions on risk and learning, ensure actions are coordinated and clarify integrity roles and responsibilities across the Service. This smaller senior strategic group could be supported by two groups with membership covering policy and operational integrity. The three governance levels should collaborate, coordinate effort and share information and knowledge. Civil society groups, such as the Open Government Forum, should also be involved in efforts to build a strategic approach to integrity.

Actions

1. Secretaries Board to establish a Strategic Integrity Advisory Group consisting of heads of those agencies with cross-sectoral oversight and integrity roles (the Commonwealth Auditor-General, Commonwealth Ombudsman and National Anti-Corruption Commissioner) co-chaired by the Secretary of AGD and the APS Commissioner. The Strategic Integrity Advisory Group will provide insights which could assist members to fulfil their respective integrity mandates including through reporting on strategic trends, championing an integrated approach to integrity and sharing insights domestically and internationally.
   • Invite the Strategic Integrity Advisory Group to make recommendations to the Secretaries Board on themes and issues for focus in the Commonwealth public sector.
   • Invite the Commonwealth Auditor-General, Commonwealth Ombudsman and National Anti-Corruption Commissioner to present at least once a year to Secretaries Board on cross-sectoral integrity themes.
2. APSC to refocus the Integrity Agencies Group chaired by the APS Commissioner to address operational and tactical issues and other priorities identified in the current review of its terms of reference.
3. AGD to continue the SES Integrity Forum it initially established for NACC preparation. The Forum brings together SES integrity policy makers and implementers across the public service and could share best practice, learn from integrity challenges and clarify integrity leadership roles and responsibilities. The Forum could provide a place to prioritise and coordinate effort on integrity initiatives across government and consider policy responses to issues identified by the Strategic Integrity Advisory Group and Integrity Agencies Group.
4. AGD, in partnership with the APSC, to develop an APS Integrity Strategy which articulates a clear narrative for the integrity activities and reforms underway across agencies, and identifies what agencies need to do to improve integrity across the service. This could include enhancements to coordination, information-sharing, evidence-gathering and reporting to strengthen integrity efforts and promote continuous improvement.

Agencies need reassurance that their integrity frameworks are effective and that their fraud and corruption risks are mitigated. Integrity maturity self-assessments not only embed a culture of continuous improvement but also start an important cultural conversation about what integrity means to each agency and its staff. This work has already begun with almost two-thirds of departments and agencies having completed or planning to complete an integrity maturity self-assessment under the Commonwealth Integrity Maturity Framework.

Actions

1. Secretaries to upscale integrity maturity across the Commonwealth by:
   • undertaking an agency self-assessment against the Commonwealth Integrity Maturity Framework and reporting back to Secretaries Board by September 2024 on plans to upscale their agency’s integrity maturity
   • supporting agency heads within their portfolios to do the same
   • circulating the Integrity Good Practice Guide
   • establishing Deputy Secretary-level Integrity Champions to act as stewards of a pro-integrity culture and foster informal integrity conversations.
2. AGD to scope mechanisms to provide tailored, expert integrity guidance to agencies seeking to improve their integrity frameworks and identify capability needs or to address integrity risks.

Suppliers (including consultants, contractors and outsourced service providers) can be held accountable to the terms of their contract and are now subject to the jurisdiction of the NACC. However, suppliers are not APS employees and are therefore not held to the same standards and values as public servants. A Supplier Code of Conduct, under development, will assure the Australian public that entities undertaking work on behalf of the Commonwealth will be expected to uphold the same values and behaviours expected of public officials. 

Across the APS, the decentralised nature of the Commonwealth procurement network provides a level of anonymity for poorly-performing contract service providers. Centralised knowledge sharing would enable delegates to make more informed decisions and reduce the risks of departments operating in a siloed manner.

Actions

1. The Department of Finance to continue the development of a Supplier Code of Conduct, covering consultants, contractors and outsourced service providers, which would be enforceable as a material breach of contract.
2. The Department of Finance, in collaboration with AGD, to scope establishing a centrally-held register of all supplier contracts to improve knowledge sharing on prior performance, including information on suppliers who have been removed from government contracts or for breaches to the Supplier Code of Conduct.

Career mobility between the public and private sector presents opportunities and risks. To maintain public confidence in the integrity of public officials, the ‘revolving door’ and the management of conflicts of interest across the APS needs to be strengthened. We need to enforce clear expectations of staff pursuing private sector opportunities in areas of related competency where a conflict could arise. Currently, only around half of Commonwealth agencies have a formal post-employment conflict of interest policy in place. We have also identified a gap in mechanisms to monitor compliance with conflict of interest policies. The APS would benefit from dedicated, ongoing education for staff at all levels about the rules, practice and significance of managing conflicts of interest.

Actions

1. Secretaries Board to task Chief Operating Officer (COO) Committee to review conflict of interest management frameworks of all agencies from a risk mitigation perspective with a view to recommending agencies share good practice and establish the following:
   • Clear conflict of interest management policies and processes, including conflicts of interest arising in the context of previous employment, secondary employment and post-separation employment (the ‘revolving door’).
   • Specific processes for declaring and managing the actual, potential or perceived conflicts of interest of agency heads and SES officials, particularly after they leave the APS.
   • Regular, scenario-based training and guidance for staff at all levels on how to identify, declare and, most importantly, manage and monitor conflicts of interest to uphold integrity.
   • Centrally-recorded conflict declarations and conflict management plans within agencies, with monitoring and assurance processes in place.

We need to be able to measure the APS’s integrity issues in order to address them, and to evaluate the efficacy of our responses. Integrity data collection and analysis should take place both at the agency level and APS-wide, showing ‘hotspots’ and areas of good practice. There is a variety of data available which can tell different stories about integrity across the APS, such as the annual Australian Institute of Criminology Fraud Census. The APSC’s Integrity Metrics Resource is a useful reference and some agencies are already reviewing their data through an integrity lens. A common baseline for measuring and reporting on integrity is needed and should cover measuring data on compliance and culture (quantitative and qualitative sources). We also need to build up our databank to allow for evaluation over time.

Actions

1. Secretaries Board to seek advice on how to measure integrity in the APS from the Strategic Integrity Advisory Group, supported by the APSC. The project could:
   • identify best practice for measuring integrity both within agencies and across the APS
   • provide practical guidance to help agencies engage with and interpret the data
   • cover qualitative factors that contribute to integrity, such as psychological safety, as well as more clear-cut metrics such as adjudicated instances of fraud and corruption
   • align with the work on psychological safety indicators to be undertaken by the Future of Work Committee (recommendation 4)
   • deliver a plan for a coordinated APS approach to collection, analysis, ongoing monitoring and reporting to Secretaries Board of this data.