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Last updated: 20 October 1992
Circular 1992/12: Frequent flyer schemes
This publication remains current but needs to be read taking into account the repeal of the old Act and the proclamation of the new Act
Background
1. Recent commercial developments in the civil aviation industry appear to have produced a new round of promotions of frequent flyer schemes. It is therefore necessary for me to draw your attention once again to the difficulties that these schemes may have for APS officers and employees in terms of the Guidelines on Of ficial Conduct of Commonwealth Public Servants. Participation in these schemes could amount to a significant breach of those Guidelines.
2. This circular replaces Circular No.1991/11 of 4 September 1991.
Some features of the frequent flyer schemes
3. Previous frequent flyer schemes promoted by Australia's domestic airlines offered benefits such as free travel, consumer goods and holidays to individuals who accumulated bonus points by flying with the airline concerned, as well as through the use of nominated hotels, rental cars and credit cards.
4. Under the current schemes, bonus points resulting from an international flight can be redeemed through the domestic partner of an airline company and vice versa. Bonus points already accrued with the international or domestic carrier now in a new company relationship will be recognised under the current frequent flyer schemes.
5. It also appears that only individuals are eligible for membership of current schemes, meaning Commonwealth Government Departments and Agencies can no longer gain a corporate benefit from the schemes. However, if Departments and Agencies can negotiate ways of ensuring that participation in the schemes is used for official travel, that is in order, but arrangements must be consistent with APS legislation and the Guidelines on Official Conduct of Commonwealth Public Servants.
6. Additionally, it seems participants in the schemes can nominate certain family members as recipients of benefits from the schemes.
Conflict of interests
7. The effect of the current frequent flyer schemes on APS officers and employees is to create a conflict of interests, and possibly a breach of regulation 37 of the Public Service Regulations.
8. Regulation 37 requires that:
- an officer (or employee) must not take, or seek to take, advantage of official duties in order to obtain a benefit; and
- an officer (or employee) must not, unless they have the written approval of their Department, accept a benefit from any person concerned with any matter connected with their functions.
9. The requirement for Departmental or Agency approval to accept a benefit or reward extends to a nominated family member if the gift or reward derives from the expenditure of public moneys i.e. if it derives from official travel and the performance of official duties. There is no restriction on an officer or employee, when travelling in a private capacity, gaining or using bonus points, gifts or rewards.
10. An APS officer or employee who breaches regulation 37 may have committed misconduct, and could be subject to disciplinary action under the Public Service Act 1922.
Policy on frequent flyer schemes
11. It is Government policy that of ficial travel and associated arrangements (accommodation, car rental etc.) should not be used to accumulate bonus points for 'frequent flyer' benefits for private purposes Further, it is Government policy that where an APS officer or employee has already accumulated bonus points which would otherwise entitle them to obtain a benefit, they should not accept such a benefit.
12. When travelling on official business, officers and employees should not enter competitions, or lottery-style promotions on offer by the airline companies, e.g. by placing boarding passes or business cards in competition containers. Regulation 37 applies to this situation as well.
13. Should you have any questions on this matter please contact the PSMPC phone (02) 6202 3859.
Peter Kennedy
Acting Public Service Commissioner
20 October 1992
