Strengthening Integrity in the APS

Overview

Integrity is fundamental to public trust in government and the Australian Public Service as a whole. As a custodian of the APS Values, APS Employment Principles and Code of Conduct, the Australian Public Service Commission plays a lead role in upholding high standards of integrity and conduct in the Australian Public Service through administration of the employment and integrity framework under the Public Service Act 1999 . This strategy outlines the APSC’s approach to administering the framework: working collaboratively with agencies to uphold high standards of integrity and conduct in the APS, as required under the Act.

The strategy sets out four key objectives, three focus areas, and an action plan that will enable progress towards achieving the strategy’s intent.

Context

The employment and integrity framework is described collectively in the Public Service Act, the Regulations, the Commissioner’s Directions, the Classification Rules, and guidance documents provided by the APSC. It sets expectations for how the APS behaves and how people are to be treated as APS employees.

The cornerstone of the framework is the Public Service Act. It sets out high level principles and expectations through the APS Values, APS Employment Principles and Code of Conduct. It provides Agency Heads with the management flexibility required to respond to emerging challenges while taking into account their agency circumstances. This flexibility is accompanied by an obligation to uphold and promote the APS Values and APS Employment Principles, to act in accordance with the APS Code of Conduct, and to operate with accountability under legislation.

The framework is part of a broader system that requires the public sector to act with integrity. It supports and reinforces other key frameworks, strategies and action plans such as:

• the Commonwealth resource management framework under the Public Governance, Performance and Accountability Act 2013 , which requires integrity in the way public resources are used and managed, supported by the Department of Finance
• the Commonwealth Integrity Maturity Framework, to support corruption prevention in Commonwealth agencies, published by the National Anti-Corruption Commission, and
• the significant program of work set out in Louder than Words: An APS Integrity Action Plan to be complemented by the development of a whole of Commonwealth Integrity Strategy lead by Attorney-General’s Department.

The APSC partners with Secretaries in the stewardship of the APS as a member of the Secretaries Board. As an agency with significant visibility across the APS, the APSC is uniquely placed to shape priorities that strengthen integrity across the service. We are well positioned to explain how the APS Values, APS Employment Principles and Code of Conduct work in concert with other legislative frameworks.

This strategy has been developed to specifically articulate the APSC’s role as a framework owner in the employment and integrity system, and how this responsibility is administered.

Objectives

Under this strategy, the Commissioner’s functions with regards to integrity will be strengthened through the pursuit of four objectives. These objectives are:

1. pro-actively using data to develop insights to monitor and evaluate the extent to which agencies incorporate and uphold the APS Values and Employment Principles
2. developing dynamic and engaging promotional activities that support people to know what integrity means in the APS, building awareness and understanding of the APS Values, APS Employment Principles and Code of Conduct to drive ethical behaviour
3. making it easier to find guidance, advice and resources to build capability and support people to take action and make decisions that are consistent with the framework, and
4. increasing the capability of agencies to deliver on workforce management with particular effort on uplifting investigative and recruitment skills as two important fundamentals of integrity.

These objectives are underpinned by an aspiration that agencies consider more than whether policies and procedures are in place. Agencies should consider how the APS Values, Employment Principles and Code of Conduct are being embedded, how policies are followed and whether they are achieving the intended outcomes. T he APS Values, APS Employment Principles and Code of Conduct set standards and expectations for how people will be treated, and how the APS conducts itself every day. Leaders in agencies must provide context, relevant examples and incentivise ethical behaviour and practices for employees in their agencies. Leaders set the cultural tone for their organisation through their behaviour, and culture is powerful in determining how people behave.

Focus areas

The three focus areas for delivery of the strategy are: monitoring and evaluation, assurance, and promotion and capability. The focus areas are linked to enable continuous improvement and strengthen how the employment and integrity framework is administered.

Monitoring and evaluation

The APSC will maintain awareness of how agencies are delivering on their obligations under the Act, to support high standards of integrity and conduct. Data and information captured through existing relationships and engagements will be used to monitor and evaluate the likely effectiveness of agencies in managing their integrity and employment obligations. An evaluation methodology will be used to ensure a logical and consistent approach to developing insights into APS integrity capability.

‘Monitoring and evaluation’ is the first focus area of the strategy.

Assurance

Assurance is provided through a structured process to review themes that emerge through monitoring and evaluation, and consider what response is required to support compliance with the employment and integrity framework. Themes that emerge through monitoring and evaluation may be at the individual agency level, or present as trends across a range of agencies. Differences in size, function, agency priorities and operating environments may all impact on the approaches taken. Strategically targeted assistance and ongoing monitoring will provide assurance that the APSC is upholding high standards of integrity and conduct in the APS.

‘Assurance’ is the second focus area of the strategy.

Capability and promotion

Intelligence based on ‘monitoring and evaluation’ and ‘assurance’ will contribute to the wide range of ongoing capability and promotion activities delivered by the APSC. Dynamic, targeted communication; advice; policies (including legislative change where appropriate); guidance; resources; well-designed capability building programs; communities of practice and networks are deployed strategically to uplift compliance with the employment and integrity framework.

‘Capability and promotion’ is the third focus area to deliver this strategy.

Linked together, these three focus areas provide a holistic way of working to drive APSC integrity activity. Identifying areas of greatest risk will underpin how we deliver support to strengthen integrity in the most effective way. Over time, data driven approaches will provide the ability to measure impact at the system level and will form part of the evaluation of this strategy.

What this means for agencies

The APSC’s implementation of this strategy will help agencies to strengthen their integrity practices by increasing visibility of areas for improvement. This means:

• agencies may experience more check-ins from the APSC as we seek to understand their employment and integrity practices and challenges
• the APSC will be proactive in monitoring and responding to indicators that employment and integrity practices require improvement, in a way that is proportionate and collaborative
• there will be a feedback system between emerging issues and new or updated capability, promotional and guidance resources produced by the APSC, and
• agencies will achieve greater confidence they are operating in accordance with the employment and integrity framework, through increased collaboration with the APSC.

Initial areas of interest are in recruitment and conflict of interest management. These activities carry inherent integrity risks that require appropriate management. Feedback from agencies – through interdepartmental committees, individual agency engagement and the APSC’s advice services – indicates there is a need for increased support to identify and respond to risks in these areas.

What will success look like?

Effective delivery of the strategy is intended to achieve:

• greater assurance that APS Agency Heads and employees are aware of their obligations under the Public Service Act , understand how to act, and know where to go for information and support
• increased awareness and understanding of workforce and integrity risks across the APS, to prevent and mitigate integrity issues before they arise, and
• greater assurance of high standards of accountability, effectiveness and performance in agencies with regards to employment and integrity.

Roles and expectations

Shared understanding and expectations are critical to working collaboratively. In this strategy, the APSC’s expectations for agencies are underpinned by the roles, functions and principles set out in the Public Service Act. The Act establishes the Australian Public Service and its operation, including the role of the Australian Public Service Commissioner, Agency Heads, and APS employees.

The APSC’s approach is to support and enable agencies to build good practice and help agencies to prevent workforce integrity issues before they occur. APS agencies also have a role in modelling, reinforcing and maintaining a culture of integrity. Leaders in agencies must provide context, model high standards of integrity and incentivise ethical behaviour and practices for employees in their agencies.

The APSC’s role

The Act emphasises the Australian Public Service Commissioner’s obligation to uphold high standards of integrity and conduct in the APS . Section 41 of the Act specifically assigns functions to the Australian Public Service Commissioner including:

• promoting the APS Values, APS Employment Principles and the Code of Conduct
• evaluating the extent to which Agencies incorporate and uphold the APS Values and the APS Employment Principles
• providing advice and assistance to Agencies on public service matters, and
• evaluating the adequacy of systems and procedures in agencies for ensuring compliance with the Code of Conduct.

These functions are reinforced by specific powers of inquiry.

The APSC supports the Australian Public Service to be aware of and understand its obligations, to achieve better outcomes across the whole of the service. As agencies adapt to legislative reforms, new policy requirements and the changing needs of the Australian people and government, there may be gaps in agency systems, processes or behaviour that need to be addressed. Where opportunities for improvement are identified, the APSC engages with agencies to support improvement in a way that reduces risk and is appropriate for the operating environment.

Agency Heads

The Act balances workplace autonomy and flexibility with a high level of accountability. Agency Heads are provided with the rights, duties and powers of an employer for employees in their agency. This confers significant responsibility to engage with and understand the framework under which they operate.

Acting lawfully is fundamental. In doing so, considering the intent and objective of applicable principles is critical to ensure organisational culture and practice are aligned with expectations and values. Delivery at the expense of integrity undermines confidence in the integrity and performance of the APS. Conversely, high standards of ethical conduct strengthens confidence in the APS, building trust in the work of Government. Ensuring agency culture incorporates and upholds the APS Employment Principles and APS Values is an important element of integrity. Building a culture that respects and embeds integrity is foundational for an Agency Head.

SES employees

The function of the Senior Executive Services is to provide APS ‑ wide strategic leadership of the highest quality that contributes to an effective and cohesive APS. It is a requirement of the Act that each SES employee, by personal example and other appropriate means, promotes the APS Values, the APS Employment Principles and compliance with the Code of Conduct.

APS employees

All APS employees must behave in a way that upholds the APS Values, Code of Conduct and Employment Principles, and the integrity and good reputation of the employee’s agency and the APS.

Action plan

The action plan sets out practical initiatives to support implementation of the strategy. Implementing the strategy will require ongoing effort to mature in each of the focus areas. Implementation will occur over three sequential horizons:

1. Horizon one (12 months)
2. Horizon two (1 to 2 years)
3. Horizon three (ongoing)

The first horizon will design and establish an operating and assurance model to implement the strategy into APSC work programs, including building data capability. Use of data to inform insights will likely evolve over multiple horizons. Documenting how monitoring occurs forms a key part of the monitoring and evaluation and assurance focus areas.

The second horizon will embed and improve the operating model, including enhancing the link between Capability and Promotion activities and insights gained through Monitoring and Evaluation. It may include adjusting and introducing new actions.

The third horizon will continue to review, strengthen and enhance the relationship between strategy outcomes and broader public sector integrity initiatives.

A high level intent has been established for each horizon. Further planning will occur as the APSC moves into the second horizon to ensure implementation remains focused and adaptive to ongoing progress, implementation outcomes, and broader developments in the APS integrity landscape.

Horizon one (2025 – 2026)
Focus area	Initiative	Description
Capability and promotion	APSC.gov.au website update	Website is updated with a focus on the accessibility of integrity and employment principles information.
	APSC Flagship Product Suite	‘Flagship’ guidance products are defined, identified and prioritised for increased visibility to uplift the accessibility of existing products and support consistency in new products over time.
	Integrity Communications Strategy	An integrity communications strategy is developed with a focus on building awareness about integrity in the APS through a wide range of channels.
Monitoring and evaluation	Employment and integrity insights operating model	Processes to analyse existing data and information are designed and embedded to generate ongoing insights about how agencies are applying the employment and integrity framework.
Assurance	Assurance model	A structured assurance model is put in place which describes the governance process for considering themes and responses, to build assurance in the effectiveness of the implementation of the employment and integrity framework.
	Evaluation methodology	An evaluation methodology to support the strategy is designed and implemented to ensure it is achieving stated outcomes.
	Protocols to share and report across the APS	Protocols to improve sharing with other integrity agencies are established in order to better understand whole of system integrity risk.

Appendix A

The APS employment and integrity framework

The APS employment and integrity framework consists of legislation, policies and guidance that relate to the employer-employee relationship, and how these may be applied in agencies. While the APSC predominantly advises on the elements of the framework derived from the Act, the framework also interacts with broader employment and integrity legislation, including policy and legislation administered by other Commonwealth integrity agencies.

The Act sets out high level principles and expectations, enabling the operating flexibility required to adapt to changes in public needs and expectations of government, respond to emerging challenges, and meet the diverse needs of agencies that operate within the APS. The APS Values, the APS Code of Conduct and Employment Principles are enshrined in the Act and represent core foundations of the culture within the Australian Public Service. These standards are reinforced by provisions of the Public Service Regulations, Commissioner’s Directions and Classification Rules.

Legislation provides mandatory obligations. Policies may have mandatory elements depending on authority. Guidance helps interpret and explain legislation and policy, as well as provide advice on how obligations should be met.

Tier 1

Public Service Act 1999

Tier 2

Public Service Regulations 2023 

Australian Public Service Commissioner’s Directions 2022 

Public Service Classification Rules 2000 

Directions and determinations made under the Public Service Act 1999 , such as:

• Prime Minister’s directions made in accordance with section 21 of the Act
• Commissioner’s directions made in accordance with section 11, 11A, and 42 of the Act
• Determinations made in accordance with section 72 of the Act

Tier 3

Policies, guidance material and APSC Circulars as published on the APSC’s website.

Legislation

The principal Act governing the operation of the APS is the Public Service Act 1999. The main objectives of the Act are to:

• establish an apolitical public service that is efficient and effective in serving the Government, the Parliament and the Australian public
• provide a legal framework for the effective and fair employment, management and leadership of APS employees
• define the powers, functions and responsibilities of Agency Heads, the Australian Public Service Commissioner and the Merit Protection Commissioner and
• establish the rights and obligations of APS employees.

The Act is supported by subordinate legislation:

Public Service Regulations provide further detail on the operation of the PS Act, including provisions relating to the Code of Conduct; review rights; independent selection advisory committees; the functions of the Commissioner and the MPC; the employer powers of Agency Heads; non-ongoing (temporary) employment arrangements; and the use and disclosure of personal information.

Australian Public Service Commissioner's Directions prescribe standards that Agency Heads and APS employees must uphold to meet their obligations under the Act. It provides details on the scope and application of the APS Values and APS Employment Principles, and provisions relating to recruitment and selection; performance management; handling of suspected breaches of the Code of Conduct; and other employment matters.

Public Service Classification Rules prescribe approved classifications for the APS. The Rules also establish the requirement that the allocation of a classification to a group of duties must be based on work value as described by the APS Work Level Standards issued by the Commissioner.

Mandatory obligations under the legislation

Agency heads and APS employees must comply with their legislative obligations in how they undertake their roles. There are both general duties and specific obligations for agency heads.

The Act and its subordinate legislation also provides that agencies must consult with the APSC on certain employment and integrity matters. Agencies must consult with the APSC:

• before entering into a confidentiality or non-disclosure agreement with an APS employee relating to sexual harassment
• regarding suspected breaches of the Code of Conduct by SES employees
• regarding proposed termination of SES employees
• to seek the Commissioner’s participation in SES selection processes
• to seek the Commissioner’s consent prior to delegating powers or functions under the Act, the Regulations, Directions or Rules to an outsider
• on requests to convert non-ongoing employees to ongoing without a merit-based process
• on requests to extend non-SES non-ongoing engagements beyond 3 years, and
• to give effect to a machinery of government change.

Agencies may also have mandatory obligations under whole-of-APS and government policy. Information on policies currently in effect is available on the APSC’s website.

Advice and guidance

The APSC provides advice on employment and integrity obligations through the Ethics Advisory Service and Employment Policy Advice Service. The scope of these advice services is available via service charters published on the APSC’s website.

Guidance is structured to help agencies understand their employment and integrity obligations under the Act on the following topics:

• APS Values, Employment Principles and Code of Conduct
• recruitment and selection (including movement)
• performance management
• separation – for example, termination, resignation, retirement
• APS classifications
• machinery of government changes
• handling of suspected breaches of the Code of Conduct
• providing integrity training to APS employees
• conflict of interest management, including gifts and benefits reporting

The APSC also publishes complementary guidance products that help agencies meet whole of APS policy and strategy outcomes while operating in accordance with the Act. Guidance is available on the APSC website.