PARLIAMENTARY SERIES REPORT SEVEN

ContaCts
Office location: 12th Floor St Martins Tower 44 St Georges Terrace Perth WA 6000
Postal address: GPO Box 2581 Perth WA 6001
Telephone: (08) 9260 6600 Facsimile: (08) 9260 6611 Toll free: 1800 676 607
Email: [email protected] Internet: www.opssc.wa.gov.au
AvAIlAbIlITy In OThEr FOrmATs
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ISSN 1835-7342
Published by the Office of the Public Sector Standards Commissioner (OPSSC)
November 2009
ThE sPEAKEr lEGIslATIvE AssEmbly
ThE PrEsIDEnT lEGIslATIvE COUnCIl
PArlIAmEnTAry sErIEs rEPOrT sEvEn – mAnAGInG InTErEsTs In ThE WEsTErn AUsTrAlIAn PUblIC sECTOr
I submit to Parliament the seventh report of the Office of the Public Sector Standards Commissioner’s Parliamentary Series pursuant to s.21(1)(h) of the Public Sector Management Act 1994 and Part 4 of the Public Interest Disclosure Act 2003.
This series of reports aims to provide Parliament with timely information about the extent of compliance or non-compliance with the general principles of official conduct and the general principles of human resource management.
I seek permission to publish the report following tabling in Parliament.
Dr ruth shean COmmIssIOnEr FOr PUblIC sECTOr sTAnDArDs
26 November 2009
iii
Contents
5. WhAT DID WE FIND?.................................................................................9 5.1. Policy Intent........................................................................................9 5.2. Management Strategies....................................................................12 5.3. Operational Procedures....................................................................14 5.4. Oversight and Review.......................................................................15
Perception Survey in 2008-09 and response rates............................29 7.5. Appendix 5: Tables and figures..........................................................30
PARLIAMENTARY SERIES REPORT SEVEN
1
COmmIssIOnEr’s FOrEWOrD1.
This report is the seventh in a series for the Office of the Public Sector Standards Commissioner (OPSSC) to Parliament.
under the Public Sector Management Act 1994 (PSM Act), the Commissioner for Public Sector Standards is required to report annually or from time to time to each house of Parliament on compliance or non-compliance with:
some parts of s.8 and all of s.9 of the PSM Act (these detail the general principles of human resource management and official conduct);
the Western Australian Public Sector Code of Ethics;
agencies’ own codes of conduct; and
public sector standards.
under the Public Interest Disclosure Act 2003 (PID Act), the Commissioner for Public Sector Standards is required to report annually or from time to time to each house of Parliament on:
the performance of the Commissioner’s obligations under the PID Act;
compliance or non-compliance with the PID Act; and
compliance or non-compliance with the code established under s.20 of the PID Act.
The Parliamentary Series reporting approach has been introduced for the following reasons.
Reporting to Parliament as and when matters arise is within the intent of the PSM Act and the PID Act.
Where the identity of an informant is known, it may not be unlawful to report to the informant directly. To do so while not reporting to Parliament, however, may not be in the spirit of the Acts.
Some matters are referred to OPSSC anonymously and it is not possible to report back to the informant. If there is any substance to the matter, the Commissioner may need to report to Parliament.
reporting categories1.1.
Concerns about the public sector are reported in the following ways:
compliance inquiries about alleged breaches of standards claims;
general compliance inquiries; and
In the public interest1.2.
Matters deemed to be within the public interest are appropriately reported to Parliament. The release of information is to provide confidence in the public sector. The purpose of such reporting is to identify areas which require action to increase public confidence. Not all compliance inquiries raised with OPSSC will necessarily be reported in these reports. Most matters will be reported in summarised data in the OPSSC State of the Service Report – OPSSC’s annual compliance report.
For the most part, OPSSC reports matters by naming agencies rather than individuals. In this way, those who have lodged concerns will be able to identify the situations, while at the same time the identity of individuals will be protected. OPSSC’s position on the release of information in the public interest is available from the OPSSC website as Information Series 2009- 01: In the Public Interest1.
1 Available at www.opssc.wa.gov.au/Documents/Official_Conduct/Information_ Series_2009-01_In_the_Public_Interest.pdf
InTrODUCTIOn TO ThIs rEPOrT2.
In public life, overlapping interests are inevitable. Public sector employees are individuals with their own private interests and there will be times when their private interests will conflict with their public duty. Conflicts of interest may be actual, perceived or potential but they are not necessarily unethical or wrong. It is how they are identified and managed that is important.
Management of interest is an issue which is frequently raised with the Office of the Public Sector Standards Commissioner (OPSSC). Parliamentary Series Report One2 examined the issues that arise when interests are not properly identified and managed and how this can threaten the integrity of the public sector. In 2008- 09, 26% of breach of standards claims and 10% of general complaints received by OPSSC alleged improper bias or a conflict of interest. Parliamentary Series Report Six3 identified that from an audit of 96 positions at Level 8 or above filled between January and December 2008, 31% of appointments involved a potential or perceived conflict of interest; 53% of these were not appropriately managed.
Other Western Australian integrity agencies also have identified the management of interests as an issue that requires ongoing commitment from public sector bodies. During 2008-09, the Corruption and Crime Commission assessed 52 (out of 1132 – 4.6%) allegations of misconduct directly relating to matters where the management of interest was in dispute.
The principles of managing interests2.1.
Managing interests is relevant to the compliance of s.8(1)(a)-(c) and s.9 of the Public Sector Management Act 1994 (PSM Act) and the Western Australian Public Sector Code of Ethics4.
The principles that guide and underpin the management of interests in public sector bodies should reflect the values of the Code of Ethics. These principles are:
personal integrity; relationship with others; and accountability.
2 Parliamentary Series Report One, April 2008. Available at www.opssc.wa.gov.au/ Documents/Reporting/Parliamentary_Series_reports/parliamentaryseries1.pdf
3 Parliamentary Series Report Six: Audit of Senior Recruitment Processes in the Western Australian Public Sector, November 2009. Available at www.opssc.wa.gov.au/Documents/ Reporting/Parliamentary_Series_reports/parliamentaryseries6.pdf
4 Western Australian Public Sector Code of Ethics available at www.opssc.wa.gov.au/ Documents/Official_Conduct/Code_of_Ethics_08.pdf
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OPSSC published Managing Interests: A Checklist5 based on four principles that can guide an ethical approach to a public authority’s management of interests. This checklist calls on agencies to:
identify, monitor and manage conflicts of interest in order to maintain the integrity of the agency and support public confidence in government (Policy Intent);
provide, implement and promote management practices and processes that create and sustain a culture of integrity (management strategies);
have systems, policies and procedures in place to facilitate interest management (Operational Procedures); and
monitor and evaluate compliance and outcomes for managing interest (review and Oversight).
Implications for agency heads2.2.
Agencies have polices and strategies in place to manage interests, but there is a clear problem with their effective implementation. The findings from this review indicate that while most public sector bodies have policies in place to manage conflicts of interest, only half of their employees are aware of them. This raises a number of important issues for agency heads to consider and, where relevant to their agency, take action.
Policy Intent
While virtually all agencies (95%) have policies in place to manage interests, implementation of these is compromised with only 59% of employees being aware of them. To create a shared understanding, agency heads must ensure that their agency clearly articulates what a conflict of interest is and how the agency expects the interest to be managed. To put policy into practice, agency heads must set out steps as to how interests must be managed. The agency must specify who is responsible for each step.
Over and above having policies to guide the management of interests, agencies must identify those potential conflict of interests risks specific to their business. Agency heads should ensure that their agency’s “hot spots” have been identified. An understanding of such vulnerabilities is the first step in managing the risk that organisational conflicts of interest can present. For example, employees in an agency which services the mining industry may wish to caution them about the management of personal shareholdings. A human services
5 Provided as Appendix 1. Also available at www.opssc.wa.gov.au/Documents/Official_ Conduct/managing_interest_checklist.doc
5
Managing Interests in the Western Australian Public Sector
agency which grants funds to non-government organisations could specify that employees with a family member receiving services from that agency should play no part in the decision making surrounding grants.
management strategies
Agency heads must lead by example and champion their management of interest policy and codes of conduct to ensure alignment between personal behaviour and the standard of conduct they expect from their employees.
Agency heads must ensure that training on conflicts of interest is not just a focus during employee induction, but an ongoing strategy throughout the term of employment. Passive or indirect communication on this issue is less likely to be effective than active promotion of the proper management of interest. Agency heads should champion face-to-face approaches, especially for employees who work in areas of high risk, and those in regional areas. This is especially so for employees working with Royalties for Regions funds.
Regardless of the good work done by agencies in managing interests, all action is to no avail if the public is of the view that interests are not being managed appropriately. Agency heads should ensure that external stakeholders are aware that the agency takes this matter seriously and acts accordingly. This can be achieved through promotion through the agency’s website, annual reports and other publications, and also included in contractual information.
Operational Procedures
Agency heads should review the steps that they take to enhance the effectiveness of the implementation of their policies on managing interests. This can include ensuring that their policy on managing interests is referenced in their code of conduct.
Oversight and review
Agency heads must clearly communicate consequences for non-compliance with policies on managing interests to those within the agency and also external stakeholders. Agency heads must also ensure that allegations of non-compliance are responded to appropriately.
The aim of our review was to:
assist Western Australian public sector bodies to identify how well their policy frameworks and systems support the management of conflicts of interest;
assure the Western Australian community and the Parliament of Western Australia that the public sector has a clearly defined set of frameworks and systems to manage conflicts of interest; and
support Western Australian public sector bodies to develop and implement effective management of interest policy and practice that is relevant to their agencies.
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WhAT mEThODs DID WE UsE? 4.
The Office of the Public Sector Standards Commissioner (OPSSC) conducted a four stage review to assist public sector bodies understand how well they manage conflicts of interests and how this might be able to be improved. The stages were as follows.
Circulating 1. Managing Interests: A Checklist to public sector bodies.
Requesting public sector bodies assess their management of interest 2. against the checklist.
Monitoring agency compliance through the sector-wide Western 3. Australian Public Sector Annual Agency Survey (which collects information from public sector chief executive officers).
Monitoring perceptions of public sector employees through the 4. Employee Perception Survey.
OPSSC then conducted comparative analyses on the different data sets.
managing Interests: A Checklist 4.1.
Managing Interests: A Checklist was developed as part of OPSSC’s “no surprise” approach to a public sector review. The checklist was distributed in January 2009 and enabled public sector bodies to assess how well their policies and systems supported their management of interests. A range of online tools, templates and links to other resources complemented the checklist and were made available from OPSSC’s website.
OPSSC hosted a series of sector-wide workshops on how to manage interests. Representatives from 37 public sector bodies attended the workshops and 28 agencies requested follow-up support from OPSSC. In addition, OPSSC provided agencies with 12 awareness raising presentations, 9 peer reviews and 7 specific consultations (see Appendix 2).
self assessment using managing Interests: A Checklist4.2.
A representative sample of public sector bodies was selected by independent statistical consultants Data Analysis Australia. Chief executive officers from the selected agencies were asked to complete the Managing Interests Checklist Survey. The sample was also stratified by agency size and public sector body type.
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The sample consisted of 50 public sector agencies or authorities and 31 boards or committees. Ninety-two percent of the public sector agencies (46) and 55% of the boards or committees (17) responded to the request to assess themselves against the Managing Interests Checklist Survey (see Appendix 3).
Western Australian Public sector Annual Agency 4.3. survey
The Western Australian Public Sector Annual Agency Survey collects information from public sector chief executive officers. The 2009 Annual Agency Survey was conducted in July 2009 and contained specific questions about the management of interest, with a view to monitoring how agencies are managing conflicts of interests. All public sector agencies (103) and all Schedule 1 authorities (21) responded.
Employee Perception survey 4.4.
The Employee Perception Survey has been conducted by OPSSC for over ten years. Two questions in the 2009 Employee Perception Survey measured employee perceptions of their agency’s commitment to managing interests and employee awareness of their agency’s policies and procedures.
During 2008-09 OPSSC distributed 17,731 Employee Perception Surveys across 13 public sector agencies and received 5,746 completed returns (32.4%). See Appendix 4 for a list of agencies surveyed.
9
WhAT DID WE FInD?5.
The Office of the Public Sector Standards Commissioner (OPSSC) collected data through three different data sources. The data from these sources were then compared to better understand the strategies used for the management of interests in the public sector. This section outlines key findings. Full data sets, sample sizes and confidence intervals are provided in Appendix 5.
The results from this review are reported using the four principles of Managing Interests: A Checklist. That is:
identify, monitor and manage conflicts of interest in order to maintain the integrity of the agency and support public confidence in government (Policy Intent);
provide, implement and promote management practices and processes that create and sustain a culture of integrity (management strategies);
have systems, policies and procedures in place to facilitate interest management (Operational Procedures); and
monitor and evaluate compliance and outcomes for managing interest (review and Oversight).
Policy Intent5.1.
The challenge facing the public sector is to develop policies on managing interest that strike a balance between the public duty and private interests of public officers. To get the balance right, agencies need to customise their policies to their specific needs and conflict vulnerabilities. The intent of the policy is to help public officers identify, manage and monitor conflicts of interest as they arise.
managing personal and organisational interests5.1.1.
All public sector agencies completing the self-assessment (100%) stated that they recognised the importance of being able to identify personal conflicts of interests. Ninety-four percent of the boards and committees surveyed responded the same. Slightly fewer agencies have strategies in place for this purpose.
95% of public sector agencies reported having put strategies in place to identify personal conflicts of interests.
82% boards and committees reported having strategies in place.
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While virtually all agencies have policies in place to manage interests, implementation of these is compromised with only 59% of employees being aware of them. To create a shared understanding, agency heads must ensure that their agency clearly articulates what a conflict of interest is and how the agency expects the interest to be managed.
An important step in developing an effective system to manage interests is to identify the areas of risk and the kinds of conflicts that are likely to occur within the business of the agency.
89% of public sector agencies and 82% of boards and committees recognised the importance of identifying organisational risks.
86% of public sector agencies and 71% of boards and committees reported they had strategies in place to identify organisational risks.
Small or medium agencies (80%) were less likely to report having strategies in place than larger agencies (95%). This is consistent with OPSSC’s State of the Service Report 2008 in which we observed that larger agencies were more likely to take a systemic approach to issues such as this.
Over and above having policies to guide the management of interests, agencies must identify those potential conflict of interests risks specific to their business. Agency heads should ensure that their agency’s “hot spots” have been identified. An understanding of such vulnerabilities is the first step in managing the risk that organisational conflicts of interest can present. For example, employees in an agency which services the mining industry may wish to caution them about the management of personal shareholdings. A human services agency which grants funds to non-government organisations could specify that employees with a family member receiving services from that agency should play no part in the decision making surrounding grants.
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Putting policy into practice5.1.2.
There was consistency of data between the Managing Interests Checklist Survey and the Annual Agency Survey. In the Annual Agency Survey, 83% of public sector agency chief executive officers stated that they had a clear policy to assist them to manage interests.
In contrast, just over half of employees (59%) reported via the Employee Perception Survey that agency policies assisted them to manage interests.
The discrepancy between what chief executive officers report and what employees perceive is of concern.
The policies themselves would benefit from revision.
77% of agencies indicated their policies reflected the ethical codes and standards of the public sector.
66% stated their policies reflected the enabling legislative framework of the public sector.
The method of implementation of policies also requires strengthening.
57% reported their policies on management of interest were implemented by a nominated person within the public authority.
48% indicated their policies were clear about the accountabilities, including those which fell to external stakeholders, such as contractors.
The findings from this review indicate that while most public sector bodies (95%) have policies in place to manage conflicts of interest, only half (59%) of their employees are aware of them. To put policy into practice, agency heads must set out steps as to how interests must be managed. The agency must specify who is responsible for each step.
management strategies5.2.
Public sector bodies must manage conflicts of interests fairly and effectively if they are to build a culture of integrity. Chief executive officers must demonstrate leadership through example. Communication strategies and awareness raising programs must enable employees to identify, disclose and manage conflicts of interest in a way that is transparent and open to scrutiny.
leadership5.2.1.
All employees within an agency have a responsibility to manage interests correctly. Agency heads must therefore demonstrate leadership in ethical management of interests to ensure that others in the agency will follow this lead.
Almost all public sector agencies surveyed in the Managing Interests Checklist Survey recognised the importance of leadership in managing interests.
98% of agencies considered it important for their agency head to lead by example by encouraging disclosures, implementing policies and following procedures.
Agencies reported they had strategies in place to enable agency heads to lead by example in relation to encouraging disclosures (93%), implementing policies (95%) and following procedures (95%).
In contrast, only 65% of employees surveyed through the Employee Perception Survey believed that their agency was committed to managing conflicts of interest.
Agency heads must lead by example and champion their management of interest policy and codes of conduct to ensure alignment between personal behaviour and the standard of conduct they expect from their employees.
Awareness and education5.2.2.
The effective implementation of a policy on managing interest requires the ongoing education of all employees. Employees should be assisted not only to define a conflict of interest, but also to highlight the specific conflict of interest risks relevant to the business of their agency.
13
In responding to the Managing Interests Checklist Survey:
almost all agencies agreed that it was important to have education or awareness strategies in place for staff (98%), managers (95%) and senior managers (95%);
almost all agencies reported that they had education or awareness strategies in place for staff (93%), managers (91%) and senior managers (91%); but
fewer boards and committees had strategies in place for staff (76%), managers (65%) and senior managers (65%).
These results contrast unfavourably with employee perceptions. For example, in responding to Employee Perception Survey, only half of employees (54%) reported that they were aware that their agency had a gift policy.
Agency heads must ensure that training on conflicts of interest is not just a focus during employee induction, but an ongoing strategy throughout the term of employment. Passive or indirect communication on this issue is less likely to be effective than active promotion of the proper management of interest. Agency heads should champion face-to-face approaches, especially for employees who work in areas of high risk, and those in regional areas. This is especially so for employees working with Royalties for Regions funds.
Communication5.2.3.
A public perception that a conflict of interest is not being managed properly can be very damaging. Public sector bodies should communicate their commitment to the proper management of interests to all of their stakeholders – employees, clients, and the general community.
In the Managing Interests Checklist Survey:
95% of agencies indicated they “communicated the organisation’s commitment to managing conflicts of interest to staff”; but
only 59% of agencies communicated their commitment to stakeholders; and
only 52% of agencies communicated their committed to clients.
14
Regardless of the good work done by agencies in managing interests, all action is to no avail if the public is of the view that interests are not being managed appropriately. Agency heads should ensure that external stakeholders are aware that the agency takes this matter seriously and acts accordingly. This can be achieved through promotion through the agency’s website, annual reports and other publications, and also included in contractual information.
Operational Procedures5.3.
Carefully thought out operational procedures are essential for the effective management of interest.
98% of the agencies completing the Managing Interest Checklist Survey stated that it was important for their agency to develop, publish and review these procedures. This compares to 82% for boards and committees.
93% of public sector agencies stated that they had strategies in place to develop, publish and review managing conflict of interest operational procedures. This compares to 71% for boards and committees.
The Annual Agency Survey provides some insight into the steps agencies may have in place to manage interests. Of the public sector agencies responding to the 2008-09 survey:
82% indicated they had operational procedures to oversee and review potential agency conflicts;
70% stated they had procedures for investigations in situations for possible breaches; and
73% reported they had effective procedures in place for dealing with allegations of non-compliance. Large agencies were more likely to report having effective procedures (88%) than were smaller agencies (68%).
OPSSC is pleased to report that about half (46%) of public sector agencies surveyed had the full range of steps in place to monitor and investigate conflicts of interest matters. An agency’s code of conduct is another effective tool to implement policies on managing interest. Codes of conduct are unique to the business of agencies and are customised to reflect specific business risk. A code of conduct sets out the agency’s expectation of how conflicts can be managed.
15
Agency heads should review the steps that they take to enhance the effectiveness of the implementation of their policies on managing interests. This can include ensuring that their policy on managing interests is referenced in their code of conduct.
Oversight and review5.4.
It is essential for effective management to review regularly all policies. This is especially true for policies on managing interests – a review which includes consideration of compliance.
Public sector bodies should use a range of oversight strategies that include defining the consequences for non-compliance and ensuring that they are proportional to the seriousness of the offence. To complement sanctions for policy breaches, public sector bodies need to state the forms of redress available and review the complaint mechanisms for dealing with allegations of non-compliance.
Of the public sector bodies responding to the Annual Agency Survey:
56% reported they reviewed and updated the managing interests system;
52% stated they defined the consequences for non-compliance;
55% mentioned they implemented sanctions for non- compliance; and
24% indicated they provided redress where conflicts of interest had been demonstrated.
Only 17% of public sector bodies demonstrated good practice in implementing all four of the above.
Agency heads must clearly communicate consequences for non- compliance with policies on managing interests to those within the agency and also external stakeholders. Agency heads must also ensure that allegations of non-compliance are responded to appropriately.
16
As has occurred in previous audits and reviews, OPSSC notes a difference in the capacity between agencies depending on their size. In this review, larger agencies were more likely to define the consequences for non-compliance, implement sanctions for non-compliance and provide redress for conflict of interest breaches, as can be seen in the figure below.
Oversight and review Processes by Agency size
38
49
63
76
33
45
% o
Implements sanctions for non-compliance
17
COnClUsIOn6.
This review enabled public sector bodies to assess the effectiveness of their policies and systems for managing interests. The majority of public sector bodies have policies and systems in place to manage interests. The majority of chief executive officers recognise that they have an important role in driving and leading effective management of interests.
Significant differences between chief executive officer observations and employee perceptions exist, indicating that although most chief executive officers believe they are taking strong action to manage interests in their agencies, employee perceptions do not support the effectiveness of this. This shortfall between presumed and actual practice may place an agency at risk.
Chief executive officers must now focus on effective implementation of these policies. In particular, chief executive officers are advised to identify high risk areas. Finally, they should ensure that all employees understand that should their agency be brought into question for the improper management of interests, their own reputation and that of the government of Western Australia will be needlessly damaged.
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Appendix 2 – managing Interests Workshops: Agencies 7.2. and number of attendees
Agency number of workshop attendees
Department of Planning and Infrastructure 13
Department of Commerce 8
Department of health 5
Department of Water 3
Nurses and Midwives Board of Western Australia 3
Tourism WA 3
Curtin university 2
Department of Fisheries 2
Disabilities Services Commission WA 1
Drug and Alcohol Office 1
Fire and Emergency Services Authority 1
Forest Products Commission 1
Office of the Auditor General 1
Peel Development Commission 1
Rockingham General hospital 1
Swan TAFE 1
WA Treasury Corporation 1
Appendix 3 – list of agencies and authorities 7.3. responding to the managing Interests self Assessment
Albany Port Authority
Animal Resources Centre
Architects Board WA
Curriculum Council
Department of Corrective Services
Department of health - Child and Adolescent health Service
Department of health - North Metro Area health Service
Department of health - South Metro Area health Service
Department of Indigenous Affairs
Department of Racing Gaming and Liquor
Department of the Attorney General
Department of Water
Economic Regulatory Authority
Office of the Director of Public Prosecutions
Office of the Information Commissioner
Potato Marketing Board
Public Transport Authority
Swan TAFE
Appendix 4 – Public sector agencies undertaking 7.4. Employee Perception survey in 2008-09 and response rates
Agency Total surveys Distributed
Dept of Education and Training (Fremantle/Peel Disctrict) 4,945 931 18.8%
Dept of Education and Training (Central Office) 2,352 965 41.0%
Disability Services Commission 1,810 660 36.5% Department of Treasury and Finance 1,717 703 40.9%
Department of Commerce 1,274 385 30.2%
Main Roads WA 1,125 463 41.2%
Landgate 1,082 377 34.8%
Department of housing 1,019 495 48.6%
Department of Water 847 390 46.0% Dept of Education and Training (Narrogin District) 690 109 15.8%
Dept of Education and Training (Pilbara District) 649 147 22.7%
Department of Racing, Gaming, and Liquor 133 57 42.9%
Office of the Public Sector Standards Commissioner 44 33 75.0%
Perth Market Authority 19 11 57.9%
Office of Health Review 16 14 87.5%
Freedom of Information 9 6 66.7%
Total 17,731 5,746 32.4%
Policy Intent
Table 1: Results from the Managing Interests Checklist Survey and the Western Australian Public Sector Annual Agency Survey on managing interests policy in the public sector.
Information source Indicator
Managing Interests Checklist Survey
Does your agency identify different types of personal conflicts of interest that typically arise in your organisation:
44*
Does your agency identify different types of organisational conflicts of interest that typically arise in your organisation: relevant to agency? 89% ± 8%
strategy in place? 86% ± 8%
Employee Perception Survey
Your agency has policies and procedures in place that assist employees in managing conflicts of interest.
59% ± 1% 5,746
Annual Agency Survey
Does your agency have a clear policy for managing potential or perceived conflicts of interest arising from conflict between the performance of public duty and private or personal interests?
83% ± 0% 124
Managing interests policy reflects the ethical codes and standards of the public sector
77% ± 0%
Managing interests policy reflects the enabling legislative framework of the public sector
66% ± 0%
Managing interests policy is implemented by a nominated person within the agency/authority
57% ± 0%
48% ± 0%
Notes: * Sample includes public sector agencies only. Boards and committee results are presented in the text of the report. Due to small sample sizes the results for boards and committees should be interpreted as indicative.
31
management strategies: leadership
Table 2: Presents results from the Managing Interests Self Assessment Checklist and the Employee Perception Survey on leadership in the public sector in relation to managing interests.
Does your agency head lead your organisation by example by encouraging disclosure:
44*
relevant to agency? 98% ± 3%
Does your agency head lead your organisation by example by implementing policies: relevant to agency? 98% ± 3%
Does your agency head lead your organisation by example by following procedures: relevant to agency? 98% ± 3%
Your agency is committed to managing conflicts of interest and communicates relevant information to staff
65% ± 1% 5,746
management strategies: Education and awareness
Table 3: Presents results from the Managing Interests Checklist Survey and the Employee Perception Survey on awareness and education in relation to managing interests.
Does your agency have education or awareness strategies in place for general staff:
44*
relevant to agency? 98% ± 3%
Does your agency have education or awareness strategies in place for managers: relevant to agency? 95% ± 5%
Does your agency have education or awareness strategies in place for the senior executive: relevant to agency? 95% ± 5%
Does your agency have a policy or procedure regarding receiving and giving of gifts?
54% ± 1% 5,746
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management strategies: Communication
Table 4: Presents results from the Managing Interests Checklist Survey and the Employee Perception Survey on communication in relation to managing interests.
These results have been discussed below.
Does your agency communicate the organisations commitment to managing conflict of interest to staff:
44*
Does your agency communicate the organisations commitment to managing conflict of interest to stakeholders: relevant to agency? 80% ± 10%
Does your agency communicate the organisations commitment to managing conflict of interest to clients: relevant to agency? 73% ± 11%
Your agency is committed to managing conflicts of interest and communicates relevant information to staff.
65% ± 1% 5,746
Operational Procedures
Table 5: Presents results from the Managing Interests Checklist Survey and the Western Australian Public Sector Annual Agency Survey on operational procedures in relation to managing interests.
Does your agency develop, publish and review managing conflict of interest operational procedures:
44*
Annual Agency Survey
Does your agency/authority have operational procedures in place to oversee and review potential agency conflicts of interest?
82% ± 0% 124
70% ± 0%
73% ± 0%
Oversight and review
Table 6: Presents results from the Western Australian Public Sector Annual Agency Survey on oversight and review processes in relation to managing interests.
Information source
Does your agency review and update the managing interest system?
56% ± 0% 124
52% ± 0%
55% ± 0%
24% ± 0%

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