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Last updated: 9 March 1994
Circular 1994/2: Participation in 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
The purpose of this circular is to remind departments and agencies of the policy on staff participating in frequent flyer schemes.
2. These schemes create difficulties for public servants and a number of circulars have been issued outining the Commission's policy. The Acting Public Service Commissioner last wrote to Secretaries and Heads of Agencies on this matter on 20 October 1992 in Circular 1992/12.
3. The policy is based on the principle that officers must not obtain personal benefit, or seek to do so, from the exercise of their normal duties. This principle is embodied in Public Service Regulation 37 which requires that:
- an officer must not take, or seek to take, advantage of his or her functions in order to obtain a benefit for that officer or any other person or body and
- an officer must not, unless he or she has the written approval of the Secretary, accept a benefit from any person concerned with any matter connected with his or her functions
4. The reasoning behind this regulation, which has broad application to the acceptance of any benefit or gift, is that public servants must be seen to be free of corruption and able to act without the possibility of reward beyond normal entitlements.
Individuals must not benefit from frequent flyer schemes
5. In the light of subregulation 37(1), it is clear that where an individual accumulates points under a frequent flyer scheme resulting from travel undertaken for the Commonwealth and paid for by the Commonwealth, he or she must not redeem those points to gain a personal benefit.
6. Where an individual has redeemed accumulated points for personal gain, he or she is likely to have breached regulation 37 and disciplinary action may result.
7. The PSC has also received legal advice that participation in lottery-style competitions associated with air travel, where passengers are invited to place boarding passes or business cards in competition containers, will breach Regulation 37. Officers are therefore not permitted to take advantage of their official position by participating in these competitions. The latest Qantas promotion offering holidays on the Great Barrier Reef is a case in point.
The Commonwealth may benefit from frequent flyer schemes
8. If departments and agencies are able to negotiate with airlines arrangements which allow the department or agency to benefit corporately, either through discounted fares on a general basis or through individual officers redeeming the points to undertake further travel, this would not give rise to a breach of regulation 37. In considering an approach to these arrangements, however, departments and agencies should be careful that no real or apparent conflict of interest arises. For example, in approving individual travel plans, departments should be certain that both the travel which is accumulating the points and the travel which results from the redemption of the points is essential and is being undertaken in the interests of the Commonwealth.
9. Where individuals travel in a private capacity and accumulate frequent flyer points, there is no breach of regulation 37 when those benefits are taken also in a private capacity. Nevertheless, where there is a mix of private and official travel, departments and agencies should be satisfied that the accumulation and redemption of points is based entirely on private travel activity.
10. Should you have any questions on this matter, please contact the PSMPC on phone (02) 6202 3859.
Denis Ives
Public Service Commissioner
9 March 1994
