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Last updated: : 25 August 2003

Embedding the APS Values

Promoting and upholding the Values

Promoting and upholding the Values requires commitment from the top reflected throughout the organisation, management processes and systems that at all times reinforce the Values, and assurance arrangements that demonstrate how the Values are being upheld and identify any areas of weakness that need to be addressed.

The following sets out for each of these three elements useful questions to help agencies identify the various components involved, followed by examples of good practice amongst the six agencies studied that might help agencies review and improve their approach.

Commitment: Good practice questions, principles and approaches

Leadership

The leaders whom we admire the most help to revitalise our shared beliefs and values. They have always spent a proportion of their time teaching the value framework. (Gardner 1990: 14)

The most effective way of undermining the Values is for senior managers to silently contradict them through their personal behaviour. The most effective way of building the Values into organisational culture is by both making them explicit and explicitly putting them into practice. This means raising awareness of and role-modelling the Values. Promoting the Values is described in section 35 of the PS Act as one of the key roles of the Senior Executive Service (SES). Agency Heads are bound by section 12 of the PS Act to promote and uphold the APS Values.

Making clear that conduct consistent with the APS Values is expected

In the Department of Transport and Regional Services (DOTARS) Link: Go to case study 1 newly promoted and newly engaged SES employees are addressed by the Secretary soon after their promotion or engagement in the department. The Secretary's presentation includes a discussion about personal conduct, during which he sets out his threshold expectation that SES employees will model the Values and act consistently with ethics-driven behaviour. During this and other presentations to the department, the Secretary sets the standard and defines what a valuesbased agency means in practice. He makes it clear that, in embracing the Values and the Code of Conduct, the aim has been to develop a culture in which people can perform at their best. In this way a line is drawn between the agency's cultural objective, the legislative reality and individual decision making, so that the logic of each reinforces the other.

The Secretary also provides employees with six-monthly oral reports on departmental achievements and challenges, creating a shared understanding of what needs to be achieved. Special emphasis is given to linking a values-driven ethical culture with individual behaviour, and highlighting that legal, ethical conduct is a key standard by which the department will be judged.

While it is important to be clear about the behaviours that reflect the Values, judgement is critical to applying the Values in changing circumstances. One of the most important ways of fostering sound judgement is to encourage discussion and disclosure about ethical dilemmas. Employees should be comfortable raising questions about ethics openly with supervisors, subordinates and peers.

Encouraging discussion and building commitment to the APS Values

At DOTARS, the Secretary has made it clear in discussions with staff at all levels that it is appropriate to talk about values and ethics and that successful organisations of the future will need to feel comfortable with raising ethical issues and questions, and confident in confronting them. For this reason discussions are focused on new issues as they arise case by case.

In order to build the commitment of DOTARS' employees to the Values, the leadership approach is formalised through agreement making. All SES employees acknowledge the APS Values and DOTARS' values explicitly by means of a signature for each set of values in their Australian workplace agreements (AWAs). Similarly, DOTARS' certified agreement commits the parties to providing a working environment that encourages behaviours that accord with the APS Values and departmental values. In order to close the loop, its reward and recognition schemes are correspondingly sensitive to such behaviours.

Dealing appropriately and effectively with misconduct

DOTARS has sought to achieve a balance between a trust-based approach to its management arrangements, founded on values, and a prescriptive approach. The Secretary and senior leaders in DOTARS make clear to employees the intention to deal appropriately and effectively with misconduct at all levels. To help ensure that misconduct action does not fail because of procedural deficiencies, DOTARS has focused on making its guidelines on the process to be followed in cases of suspected breaches to the Code of Conduct clear and easy to read and understand.

Strategic direction setting

Values and principles are as important as outcomes and outputs. Outcomes and outputs may be achieved in the short term without values and principles but not in the medium term. (Management Advisory Committee 2001: 49)

A high-level approach to demonstrating commitment to the Values is to integrate the Values with strategic direction setting, so that incentives and processes that lead to outcomes are aligned with the Values. Such an approach allows a cascading of values-based decision making through planning and performance frameworks at all levels. The aim is to ensure that the application of the Values is not compartmentalised, but fully integrated into an agency's culture, so that separate elements are both consistent and mutually reinforcing.

The Department of Defence (Defence) Link: Go to case study 2 Renewal process was based on three priority themes and, critically, their interaction:

New ways of working in Defence and the defining and shaping of the new leadership culture could not have been effectively achieved without beginning with the Government's policy directions for Defence, and ending with desired behaviours in the performance management framework.

Learning and development

To ensure values are ingrained in the daily work of employees, organisations must continually train and offer follow-up sessions including interactive discussion with upper management (Corporate Leadership Council 2001a: 10).

The OECD advises that communication and training can do much to ensure that public servants internalise basic values, understand ethical issues and develop the judgement and skills needed to deal appropriately with ethical problems (OECD 1997). The most enduring and effective form of communication is the modelling of the Values by the Agency Head and senior managers. Other forms of learning and development that provide either more formal or operational advice will take on additional relevance and importance to employees to the extent that they correspond with the observed behaviour of senior managers. For this reason it is important that the APS Values are incorporated into all leadership development programs.

Induction

In the Attorney-General's Department (AGD) Link: Go to case study 3 the induction process ensures that new staff are aware at an early stage that the department attaches importance to the APS Values. The process consists of the provision of an information booklet and related documentation that accompanies the letter offering employment, an intranet-based new employees' program which is accessed during the first weeks of employment, and a morning tea hosted by the Secretary for new employees.

Documentation provided in an offer of employment includes a copy of the Values, the Code of Conduct, and extracts from the Crimes Act, and advice to recruits that they should familiarise themselves with these. Recruits are asked to certify their agreement to the contents of the offer of employment, including that they have read and understood statements setting out the Values, the Code of Conduct and extracts of other related legislation. The intranet package includes a section dealing with the establishment and maintenance of appropriate ethical standards and further reinforcing the APS Values and their application to all employees in AGD.

Importantly, the APS Values are presented as an integrated package early on so that employees have an understanding of the total framework within which the APS works. For example, there is information on the department's Service Charter and its relationship to the delivery of services fairly, effectively, impartially and courteously to clients. The package also consists of detailed information promoting programs relating to equity and workplace diversity. The inclusion of a morning tea hosted by the Secretary provides an opportunity for senior management to give life and meaning to the written and electronic advice.

Guidance and direction

Centrelink Link: Go to case study 4 has developed an expectations statement that aims to help all employees meet the required standard of conduct and performance by informing them of:

The Expectations Statement provides directions on how Centrelink employees should interact with customers, client departments and each other. It is accompanied by a firm commitment from the Agency Head to support and respect each person who works in Centrelink.

Senior management presentations

The Australian Statistician at the Australian Bureau of Statistics (ABS) Link: Go to case study 5 regularly addresses staff (particularly new recruits) on, among other things, the APS Values and the ABS Corporate Plan, including the ABS Principles and mutual obligations. The intention is to demonstrate senior management support for and leadership in promoting the APS Values, as well as to set ABS corporate messages and information into the broader context of employees' roles and obligations as public servants. In seeking a solution to the need to ensure that these important corporate messages reach all employees nationally at appropriate times, without being dependent on the Australian Statistician's availability, a series of professionally produced topical videos has been developed which can be delivered directly to employees at their desktop. The first video produced was of an interview on the APS Values with the Public Service Commissioner. ABS staff can also 'tune in' to live broadcasts as well as replay 'live' or prerecorded video presentations at a time which suits their availability.

Personal development

DOTARS Link: Go to case study 6 has introduced a corporate citizenship program, Leading in DOTARS, for all staff. It focuses on ethics, values, leadership and emotional intelligence as part of its move toward a high-performance culture and sets these in the context of the APS Values and DOTARS' values. Leading in DOTARS is the foundation component of the department's leadership agenda. It seeks to maximise the capacity of staff at all levels to lead and focuses on behaviours the department seeks to foster to achieve its objectives. It also develops awareness of the changing management and policy directions of the department to encourage creativity and wider participation in corporate affairs.

Ethics awareness

On occasions in the course of an APS employee's duties, dilemmas may arise and employees may need to make difficult decisions. Agencies should have processes that enable employees to recognise such dilemmas and make considered ethical judgements. The Department of Health and Ageing introduced an ethics awareness program for all staff a few years ago entitled The Fork in the Road Café, which includes a 'Hypothetical' video. The program encourages staff, when faced with ethical dilemmas, to stop and talk to respected colleagues, discover precedents, legal factors and any available guidelines, and make a considered decision taking all relevant information into account.

The APS Commission is proposing to develop a toolkit to guide all APS employees, particularly managers, on workplace discussion on values and ethics. It is envisaged that the toolkit will include examples of the range of judgements and dilemmas faced by employees in broad areas of activity. The kit will look at the considerations and issues that need to be taken into account in reaching decisions consistent with the APS Values.

Management: Good practice questions, principles and approaches

From the first interview to the last day of work, employees should be constantly reminded that core values form the basis for every decision the company makes. (Lencioni 2002: 117)

Management policies, instructions and guidance play an important part in creating an environment conducive to behaviour that is consistent with the APS Values and Code of Conduct. If day-to-day management of the APS does not reflect the Values and Code of Conduct employees may see them as dead letters.

The APS Values and Code of Conduct need to be integrated into management policies, guidance and instructions. This approach is consistent with overseas research into private sector organisations, which suggests that there is a requirement for fit or correspondence between an organisation's guidance systems taken as a whole and the expectation inherent in values. It is also consistent with advice from the OECD that integrity measures should not be a distinct activity, but rather an integral part of all management systems in which they provide complementary support for the overall management environment (OECD 2000).

Management policies

Management policies should have due regard to the relevant APS Values. Information management and financial management policies, for example, are likely to address issues which require or overlap with values-based decision making, from appropriate use of Internet access to conflict of interest issues associated with procurement or contract management.

People management and related policies and strategies also intersect with particular Values. For example, Values relating to merit, equity and a career-based service will be especially relevant to succession management policies. Values relating to communication, consultation and cooperation and input from employees together with equity and a career-based service will be important to policies on the re-assignment of duties.

Articulating a commitment to the Values in key corporate documents (such as corporate plans, service/client charters, Australian workplace agreements (AWAs) and certified agreements) helps to demonstrate that an agency takes them seriously. Some agencies in the study have included a commitment to the APS Values in their corporate plans (the Insolvency and Trustee Service Australia (ITSA) and DOTARS), future directions (Centrelink), and in certified agreements and AWAs (DOTARS, AGD and Defence). In DOTARS, commitment to the APS Values and the department's values is further articulated in other corporate documents, and the staff survey is used to monitor the place of values within its working culture and governance environment.

Certified agreements

DOTARS has structured its certified agreement to set out eight objectives for the agreement, including how they are to be achieved. The description includes many of the principles contained in those APS Values relating to workplace relationships, such as equity, diversity, communication, consultation, cooperation, fairness and flexibility.

People management

The ABS has chosen to head each chapter of its Manual of Personnel Management with the relevant APS Value(s). This provides a useful signal to employees, particularly if it can be extended to integrating the Values and the Code of Conduct within each chapter, to help them understand the instructions that the chapter contains and to guide decision making.

Performance management

Managing performance is a requirement under the APS Values. The government's policy guidelines for agreement making also require that remuneration outcomes should be linked to higher productivity and performance.

The 2001 Management Advisory Committee report, Performance Management in the Australian Public Service: A Strategic Framework, advised that performance management was fundamentally an important tool that could help agencies improve organisational capability, meet broad organisational objectives, and deliver high-quality policy advice and program administration to government.

The report summarised the success factors for performance management as:

The report also identified an increasing emphasis on the need for a balanced performance management system that takes account of both the outputs delivered and the leadership behaviours and organisational values displayed. This supports the view of the Corporate

Leadership Council and others that it is not enough just to make values clear during recruitment and re-enforce them during training: organisations need to link them to performance management and related compensation so that employees and executives are held accountable for practising the values (Corporate Leadership Council 2001b). In the APS, values expressed in performance management systems should continue to be based on and complement the APS Values.

ITSA'S performance management scheme

In ITSA's performance management scheme Link: Go to case study 7 indicators for the APS Values and Code of Conduct are included within one of the capabilities at each classification. The scheme is designed around ITSA's generic capabilities. The organisation is of the view that the use of generic capabilities in performance management ensures that expectations about professional behaviour and conduct are clearly and consistently articulated throughout ITSA. Features of the scheme include:

ITSA employees are encouraged to identify the key accountabilities of their role based on information in the business plan and other corporate documents. The system also encourages employees to identify development needs related to their current role and longer-term career goals. Individual development needs identified through this process are collated at a branch level and national level to determine the trends in employee development requirements and to help identify training priorities. This information is also linked to other people management processes such as workforce planning and succession planning.

Management instructions and guidance

The current APS environment allows for a significant degree of managerial discretion. Public servants at all levels are more frequently expected to make principled judgements within broad guidelines. This does not mean there is no role for rules and controls in agencies. For example, legislative requirements, agency rules and strong controls will be reflected in guidelines about managing programs and contracts. Where there is scope for discretion, however, the APS Values are able to guide employees to the preferable decision. Chief executive instructions (CEIs) serve as the vehicle for decision making at both levels.

Chief Executive Instructions

The Secretary of the Attorney-General's Department, Link: Go to case study 8 as Chief Executive Officer, fully revised the department's CEIs in January 2002. They replaced the previous instructions, which were difficult for some employees to understand, with a set that is more user-friendly, relevant, current, and practical. In many cases rules have been replaced with clearly stated principles. This has made the guidelines more accessible to all employees rather than only those with sufficient specialist knowledge.

It is also important that employees are informed of, and can easily access, the legislation, rules and policies that apply to them. The revised AGD CEIs contain electronic links to relevant legislation, other policies and reference material, thus making it as easy as possible to access all the information needed to undertake a particular task or make a particular decision.

Guidance on the design, development and maintenance of CEIs is contained in the companion volume to this guide.

In summary, while ensuring that policies and guidance accord with and promote the APS Values and Code of Conduct, agencies should also make their management policies, instructions and guidelines comprehensive, current, accessible and user friendly so that employees will use them.

Management policies, instructions and guidelines that are grounded in the APS Values and Code of Conduct will reinforce the commitment and assurance elements of the APS Values Framework.

Assurance: Good practice questions, principles and approaches

In an environment where rules and prescription have been reduced, accountability and assurance mechanisms gain in importance. Service-wide and agency-specific accountability and assurance mechanisms can be used to good effect to sustain compliance with the APS Values and Code of Conduct.

Controls

Accountability mechanisms play a major role in an ethics infrastructure by providing a clear management framework, supported by reporting and review capacities and, if necessary, investigation. (OECD 1997: 9)

Control mechanisms underpin accountability by ensuring that management processes operate as designed without irregularities, fraud and other misconduct. For example:

The range of control mechanisms available to APS agencies can provide a robust framework for preventing fraud and other misconduct. But agencies need to monitor how control mechanisms are operating in practice so that they remain effective while allowing for flexible management and discretion. This calls for day-to-day vigilance by managers as well as attention to ANAO financial and performance audits on the effectiveness of financial controls, including performance of internal audit processes.

Code of Conduct controls

Employees need to know and adopt the standards of conduct required by the Code of Conduct, the PS Regulations and any supplementary conduct requirements within an agency. They also need to know the consequences of breaching the Code of Conduct and be confident that their agency will address suspected breaches in a timely, vigorous and systematic way and in a manner consistent with relevant legal principles. Employees should be aware of and have access to the agency's procedures for determining whether an employee has breached the Code of Conduct.

Where it is found that an employee has breached the Code of Conduct, an appropriate sanction may need to be imposed. Consistency of approach in applying sanctions within an agency is necessary if the process is to be fair and seen to be fair. While each case needs to be treated on its merits, misconduct action should be seen to be even-handed. The threat of sanctions will only act as a deterrent where they are seen as having substance and have the respect of employees.

Agencies should ensure that employees involved in managing suspected breaches of the Code of Conduct and making decisions on the imposition of sanctions are equipped with, or have access to, the appropriate skills and training to perform these roles. They should also be fully briefed on, and have an understanding of, the procedures for determining breaches of the Code of Conduct in their agency.

Managing suspected breaches of the APS Code of Conduct

AGD Link: Go to case study 9 has developed procedures that give clear directions to managers and decision-makers about determining and managing breaches of the Code of Conduct. In terms of good practice, the procedures contain a clear statement of policy objectives and operating principles. The responsibilities and accountabilities of all employees, and managers and decision makers in particular, are clearly set out. There is a statement of the general principles for handling suspected breaches of the Code of Conduct. The statement includes the principles of procedural fairness and equity and other principles consistent with APS Values. There are also indicative time frames for case management. There is guidance on issues to be considered in deciding whether to instigate a formal investigation into a suspected breach of the Code of Conduct or take some other less formal action. Record-keeping responsibilities are also stated clearly.

As a means of ensuring consistency of approach in managing breaches of the Code of Conduct, the ABS Link: Go to case study 10 limits the number of people involved in the management of the determinative process, including the application of sanctions. Once it has been determined that misconduct action should proceed, suspected breaches of the Code of Conduct are normally managed centrally in the ABS through the relevant corporate service area in the national and regional offices. Decisions in relation to sanctions are made by a senior executive in the Corporate Services Division, a regional director or the Australian Statistician.

Whistleblowing

Internal reporting systems which allow for the making and management of internal complaints and provide protection and confidentiality for those who provide information concerning irregularities in the workplace are a valuable risk reduction tool which is, regrettably, widely misunderstood. They are valuable because they enhance the capacity of management to find out quickly what is happening that should not be happening. (O'Keefe 1999)

The PS Act and the Public Service Regulations establish a scheme for the reporting of alleged breaches of the Code of Conduct-a whistleblowing scheme. This broadly based scheme provides protection from victimisation and discrimination for APS employees who report breaches of the Code of Conduct. It encourages reporting of mismanagement and corruption in the APS and is part of the accountability framework. The purpose of the scheme is to encourage employees to expose wrongdoing without fear of victimisation. It is important to raise awareness of the whistleblowing scheme and to ensure that the scheme is accessible and easy to use.

The scheme may operate at both an informal and formal level. Informally, staff should feel confident that they can raise issues of concern directly with supervisors or other senior managers outside of the whistleblowing scheme. Formally, agencies must have a process outside of the line management through which staff may report alleged breaches of the Code of Conduct. Such reports may also be made to the Public Service Commissioner or the Merit Protection Commissioner, who may investigate, usually where it is inappropriate for the matter to be investigated within the agency concerned.

Gaining the confidence of those considering reporting inappropriate conduct is an essential part of any whistleblowing scheme. If employees are not confident that the scheme will ensure the investigation of their disclosure and their own protection, then they will not make disclosures and the scheme will not be used.

Encouraging employees to report wrongdoing

In support of a culture in which employees are encouraged to report wrongdoing, Defence has established a whistleblower hotline to enable whistleblower reports to be made by telephone and to enable employees to seek information about how the scheme works in practice on an anonymous, confidential and no commitment basis. The hotline provides employees with an opportunity to understand how the department may handle a disclosure. It also provides an additional means for concerns to be raised by employees who may not be confident with raising concerns through other avenues. The hotline is staffed during business hours, and an answering service is available at all other times. People using the hotline service may elect to remain anonymous and, if so, they are advised about how this will affect the handling of their report.

Decision review systems

Decision review systems offer agencies the opportunity for systematic feedback not only on compliance with relevant legislative requirements, but also on the capacity of the decision makers consistently to meet their obligations towards the Values and to handle the discretionary judgements allowed by the delegations they exercise.

In most program areas, agencies have internal processes for reviewing decisions, as well as external arrangements under administrative law. External review processes that can be usefully monitored for feedback include ANAO audits and Ombudsman reviews. Feedback both from significant individual cases and from statistical reports can be used to identify weaknesses in service delivery and in training of staff. Apart from specific aspects of program management, this feedback can also help to identify broader issues about the relationship APS employees are demonstrating towards the public, or about their understanding of accountability requirements, and so on.

The PS Act and the Public Service Regulations also establish a review of action scheme. The scheme allows employees who are not SES employees to seek redress when they believe that an action taken in relation to their employment was either unfair or unreasonable. In addition to resolving employee concerns with employment decisions and actions, the scheme can be used by Agency Heads to identify areas where APS Values relating to workplace relationships are not being applied as well as they could be. Raising awareness of the scheme and providing appropriate support to employees who choose to seek reviews of decisions about their employment helps to develop a relationship of trust between employees and management.

Raising awareness of the review of action scheme

The ABS Link: Go to case study 11 aims to manage its review of action scheme in a manner that ensures employees are generally aware of the scheme and are reminded of their review rights from time to time without, at the same time, stimulating a grievance mentality. Information about the review of action scheme is provided in internal procedures on resolving workplace issues, which are available on the ABS intranet. Awareness is also raised through induction programs and manager development programs. Where it applies, employees are also reminded of the scheme from time to time in relation to decisions taken about them as employees-for example, in relation to Code of Conduct action. Managers are also encouraged to provide reasons for decisions affecting employees, and independent advice is available for employees from ABS's People Management Advisory Unit.

Client and staff surveys

Sound ethics management not only sets standards of behaviour but also monitors compliance with these standards. (OECD 2000: 4)

Client and staff surveys are key tools in gaining information about the confidence clients and staff have in the integrity of the organisation, and also about the overall culture of an organisation.

Client surveys

ITSA uses a number of methods to consult and communicate with clients. These include the conduct of a client opinion survey every two years by an independent consultant designed with assistance from client focus groups. Regular conduct of a client opinion survey based on key indicators of service attributes allows for the tracking of trends and benchmarking of service performance. More importantly, it gathers clients' views on developments in business and the community to inform ITSA about emerging issues and changing client needs for planning purposes. It also highlights concerns about how services are being delivered, any fall off in service standards and the strength of ITSA's relationships.

Staff surveys

Defence Link: Go to case study 12 has developed a range of surveys to seek staff views and monitor their needs. As well as providing valuable information to develop the internal services and support to enable people to perform at their best, the surveys are used to identify emerging problems in the workplace, including adherence to the Values. The department is committed to analysing responses from these surveys and adopting processes for addressing employee concerns and reviewing systemic issues.

For example, the department's attitude survey completed in 2001 revealed that a significant proportion of civilian employees did not agree that employment decisions were based on merit. In response to this feedback the department started an external evaluation of how the merit Value was being applied in employment decisions. The purpose of the evaluation was to discover how the Value was being upheld and to develop proposals to improve, as necessary, the application of merit in employment decisions.

The Department of Transport and Regional Services conducts a staff survey every two years. The department has designed its successive surveys to provide longitudinal data as well as comparative data with other government and non-government organisations.

Consistent with the focus of its survey instruments on values, the Secretary convenes all-staff meetings to provide open and transparent feedback on the survey findings. These meetings are complemented by similar open and transparent feedback at divisional and lower levels.

These practices are designed to build confidence among members of staff that their feedback in the surveys are understood and are being acted upon.

Agencies can also draw on employee (and agency) surveys conducted for the Public Service Commissioner's State of the Service Report, which may also provide guidance on the relative performance of the agency, and the confidence of the agency's staff relative to that of APS employees in general.

Contractual arrangements

Contractual arrangements are also a form of assurance. An important part of recent public service reforms has been to bring the specialist skills and knowledge of the private sector and community to bear in delivering the outcomes required of the public service through contractual arrangements.

Increased contracting with the private sector and community organisations has also introduced new levels of complexity and risk to public service agencies and presented challenges for accountability. The OECD suggests that given the increasing interaction between the public and private sectors more attention should be placed on public service values, and the role of contracts in requiring external partners to observe them (OECD 1998). The APS Commission's APS Values and Code of Conduct in Practice-A guide to official conduct for APS employees and Agency Heads provides guidance on the matters for agencies to consider when seeking to apply the Values and the Code of Conduct to contractual arrangements.

Developing a common understanding of appropriate behaviour with induustry

Defence has worked to develop a common understanding of appropriate behaviour with the industries with which it transacts business. In 1998 Defence developed a statement, Defence and Industry: an ethical relationship, providing guidelines for ethical behaviour appropriate to its business dealings. The document also serves to raise staff awareness of the issues involved, and is a practical recognition of the aims of both industry and Defence, the constraints affecting each, and their mutual obligations. In recognition of the actual role it plays in guiding ongoing relations with industry, the statement is being reviewed.

Responsibility for contracting is devolved within Defence, but the Contracting Policy and Operations Branch of the Defence Materiel Organisation has developed a suite of contracting templates, many of which are used across the portfolio. In particular, it has developed a clause designed to ensure that employees cannot be employed by contractors for a period of 12 months where they have been engaged in:

Attaching the APS Values and Code of Conduct to contracts

The APS Commission attaches the APS Values and Code of Conduct in full to its own contracts and uses a standard clause:

The Consultant acknowledges that it is aware of and understands the APS Values and Code of Conduct as set out in [.] and agrees to provide the Consultancy Services in a manner consistent with that awareness and understanding, including ensuring that Key Personnel conduct themselves in accordance with the APS Values and Code of Conduct.

Accountability and transparency

Record keeping is an essential enabler in any organisation's corporate governance and critical to accountability. Just as for other governance elements such as financial management or audit, it needs to be strategically and professionally managed. (ANAO 2002: 11)

Control mechanisms and transparency are closely related. Transparency of process and decision making acts as a preventative measure against misconduct. If transparency of process and decision making, and good record keeping are normal practice in an agency, then it becomes more difficult to commit fraud or other misconduct and similarly such conduct is much easier to detect.

Some guidance on good practice in keeping records is set out in the APS Commission's publication, APS Values and Code of Conduct in Practice-A guide to official conduct for APS employees and Agency Heads.

Record keeping in Centrelink

Centrelink recognises the link between good record keeping practices and its commitment to providing excellent service delivery to clients and customers while also meeting its obligations for accountability and transparency in the public forum. For this reason, Centrelink is undertaking the following initiatives to support good record keeping practices: