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Managing integrity risk

Following the conviction of four members of the Australian Customs and Border Protection Service (ACBPS), with others awaiting trial for similar or related offences, this year saw a sharper focus on identifying and managing risks to the integrity of the APS and its agencies.

The Australian Commission for Law Enforcement Integrity reported on investigations into alleged corrupt conduct among officers of ACBPS at Sydney International Airport and private illicit drug use by three ACBPS officers10, illustrating the challenges of integrity reform in law enforcement agencies. This has implications for the wider APS about the risks of failing to report misconduct or being reckless or indifferent with information security.

The ANAO report on the management of conflicts of interest in APS agencies11 released in June this year drew attention to the variable compliance with the requirement for Senior Executive Service (SES) employees to make annual declarations of their private interests that could involve a real or apparent conflict of interest. The ANAO recommended that agencies pay specific attention to conflict of interest matters as part of their normal enterprise-wide risk reviews.

ANAO reports provide detailed insight into risk-management practice in the APS. While the capability maturity approach provides the opportunity to compare and contrast agency assessments of risk management as a business process, ANAO reports provide insight into how practices are implemented. Two ANAO audit reports highlight specific issues in the communication of risk, the culture of risk and the impact on programme implementation.12 In particular, these reports highlight the need to continuously monitor risk profiles in line with changing circumstances and keep stakeholders informed of those changes.

This year the Commission asked agencies a new question about the strategies used during 2013–14 to manage integrity risk. Most agencies have policies designed to manage conflicts of interest that may arise through outside employment and the receipt of gifts and benefits, and a small number of agencies conduct drug or alcohol testing of employees. Perhaps most surprising is the high proportion of agencies (41%) that do not conduct regular ethics training as a strategy for managing integrity risk. New data was also collected this year on employee perceptions of integrity risk, and the experience of agencies in managing corrupt behaviours. This data is reported in Appendix 6.


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Footnotes

8 Australian National Audit Office 2013, Defence's Implementation of Audit Recommendations, audit report no. 25 2012–13, Commonwealth of Australia, Canberra; Australian National Audit Office 2013, Agencies' Implementation of Performance Audit Recommendations, audit report, no. 53 2012–13, Commonwealth of Australia, Canberra.

9 Hanger, I 2014, Report of the Royal Commission into the Home Insulation Program, Commonwealth of Australia, Canberra, p. 309.

10 Australian Commission for Law Enforcement Integrity 2013, Operation Heritage—a joint investigation of alleged corrupt conduct among officers of the Australian Customs and Border Protection Service at Sydney International Airport (Interim Report), investigation report 02/2013, Commonwealth of Australia, Canberra; Australian Commission for Law Enforcement Integrity 2014, Operation Myrrh—An investigation into ‘private’ illicit drug use by certain Australian Customs and Border Protection Service officers, investigation report 01/2014, Commonwealth of Australia, Canberra.

11 Australian National Audit Office 2014, Managing Conflicts of Interest in FMA Agencies, audit report no. 47, 2013–14, Commonwealth of Australia, Canberra.

12 Australian National Audit Office 2011, Home Insulation Program, audit report no. 12 2010–11, Commonwealth of Australia, Canberra; Australian National Audit Office 2011, Medicare Compliance Audits, audit report no. 26 2013–14, Commonwealth of Australia, Canberra.