Misconduct Resistance Framework - Corruption and Crime ...

An Integrated Governance Approach to Protecting Agency Integrity

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Misconduct is not a question of ‘bad apples’ – it’s a management problem . ”
Australian Public Sector Anti-Corruption Conference 2007 – Corruption Prevention for Managers Workshop
A NEW APPROACH TO MANAGING MISCONDUCT
Misconduct generally occurs when a public officer abuses authority for personal gain or to cause
detriment to another person, or acts contrary to the public interest.
In the past, managing misconduct was seen in the same way many other corporate social responsibilities were
viewed – as an expensive burden that contributed little or nothing to business outcomes.
Misconduct was generally only considered in situations where doing ‘good’ or acting in the public interest was
more important than doing ‘well’ and producing results. Experience has proven that these goals are not mutually
exclusive: the integrity of an agency and management of misconduct are essential to improve business and
service delivery outcomes. Integrity and performance are complementary goals of public administration, therefore
one should not be seen as more important than the other.
This framework has been developed to help our public sector agencies better manage misconduct. To build
misconduct resistance, agencies should adopt strategies that prevent, treat, detect and respond to misconduct.
Simply introducing more controls, policies and systems is not enough to build a misconduct resistant agency.
In fact, without careful planning, they can produce administrative inefficiency and reduce performance.
This approach to misconduct resistance has two purposes:
– To encourage and increase the factors which actively work to inhibit misconduct.
– To eliminate and restrict the factors which allow misconduct to occur.
This framework aims to enhance agency strategies in both areas to create a more efficient and effective
approach, integrating misconduct resistance strategies with existing integrity systems, risk management
processes, compliance and audit activities, and fraud control strategies.
Misconduct resistance should not be treated as a ‘bolt on’ set of accountability and compliance requirements
that have nothing to do with the rest of an agency’s business activities.
To be effective, deliver sustainable benefits for the agency, and reduce the risk and incidence of misconduct,
misconduct resistance must be fully integrated with wider corporate systems.
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“[Misconduct management is] essential in our form of public administration [...], and there
have been enough examples of abuse of power to make this clear. The question, therefore,
is not whether [misconduct management] is needed, but how much of such protection is
required and how it can be brought to bear without impairing effectiveness. ”
Anechiarico, F & Jacobs JB 1996, The Pursuit of Absolute Integrity – how corruption control makes government ineffective
WHY IS MISCONDUCT RESISTANCE IMPORTANT?
All Western Australian (WA) public sector agencies have a responsibility to ensure that the
services that they provide to the WA community are efficient, effective and reflect public interest
standards and principles.
Public interest standards and principles are commonly understood to be the intended outcomes of public
sector performance, behaviour and accountability, such as:
– Exercising power and authority for the common
good;
– Acting lawfully and impartially;
– Exercising equity and fairness;
– Acting with honesty and transparency;
– Making fair and balanced decisions;
– Using and caring for State resources in a
responsible manner; and
– Respecting and protecting confidential information.
Misconduct by public officials is against the public interest and:
– Hampers agency performance;
– Undermines the value and effectiveness of
government services by costing time, money and
resources;
– Diverts management focus;
– Undermines staff morale;
– Damages the reputation and competitiveness of
the agency; and
– Erodes public confidence and trust.
A 2006 survey of fraud in Australian public and private sectors has found the incidence of fraud to be
rising, with nearly half of agencies reporting incidents and internal fraud representing the biggest risk.
The average cost to an agency was estimated in excess of $700,000. KPMG Forensics’ Fraud Survey 2006
To maintain a valued and respected public sector and produce effective business outcomes, agency integrity
must be the primary concern of public officials.
Integrating misconduct resistance as a part of core business will protect and strengthen the credibility,
competitiveness, efficiency and long term sustainability of all agencies. It will also give agencies the confidence
that their relevant legislative reporting and compliance obligations are being met.
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Successful misconduct management is needs-based and cost-effective.
Agencies should tailor their approach to suit their internal and external
environments, and the level and nature of risk they face.
MISCONDUCT RESISTANCE IS ABOUT ACHIEVING THE RIGHT OUTCOMES
Successful misconduct resistance relies on creating and sustaining the right agency culture, the right operational
strategies and the right management environment. These three areas are the outcomes that agencies should work
towards in building effective misconduct resistance approaches.
Underpinning each outcome are key elements that highlight the specific areas that should be addressed in order to
achieve each outcome.
The outcomes and their key elements operate interdependently, each supporting and contributing to the success
and maintenance of the others. The Commission’s experience and State and international best practice models
show that all three outcomes must be considered in building a misconduct resistant agency.
In 2006/2007 the Corruption and Crime Commission received 2,150 reports
of misconduct by public sector officials. The top five most reported types
of misconduct were physical assault, breach of agency policies/codes,
inappropriate behaviour, fraud and corrupt conduct.
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OUTCOME: THE RIGHT AGENCY CULTURE
Agency culture values integrity and is intolerant of misconduct
Systems to resist misconduct will only ever be as effective as the commitment of the staff members who implement
them. While official policies may specify what management would like to happen, it is agency culture that determines
what happens in practice. 1 Engaging staff in the development of the agency integrity and misconduct resistance
initiatives through consultation, feedback and education can help build commitment.
Collectively, we need to look beyond traditional strategies used to prevent, detect and respond to misconduct. We
need to focus on creating agency cultures that generate their own high standards, norms and internalised controls.
Key elements of a misconduct resistant culture include:
– The right values – Your agency’s communication, actions and decisions reflect its values and public interest
principles.
– The right leadership – Leaders within your agency set an example of integrity with their own behaviour, their
communication and their responses to misconduct by others.
– The right workplace behaviour – Your workplace culture encourages staff to accept personal responsibility for
behaving according to agency values and in the public interest.
OUTCOME: THE RIGHT AGENCY OPERATIONAL STRATEGIES
Agency policies and systems support the effective treatment of misconduct risks
Misconduct resistant agencies ensure that the factors that may encourage or allow misconduct to occur are
restricted and treated.
Key elements of a comprehensive treatment programme include:
– The right policies – Your policy platform provides a solid foundation for establishing the agency’s treatment
environment and communicates your commitment, values and business practices for misconduct resistance.
– The right risks – Misconduct risk identification and assessment are part of the wider corporate risk management
planning process and include all of your agency’s functions and operational areas.
– The right treatment – Your misconduct treatment programme is commensurate with the level and nature of risk
your agency faces, comprehensive and adequately resourced, and is subject to ongoing monitoring and review.
– The right understanding – Your staff and managers have a common understanding of what misconduct is. They
embrace your agency’s stand on misconduct, as stated in the agency policy and treatment programme, and
know how to respond should they become aware of misconduct.
OUTCOME: THE RIGHT AGENCY MANAGEMENT ENVIRONMENT
Misconduct resistance is an integrated and established component of agency life
Misconduct resistance strategies need to have agency wide reach – embedded into all business activities and
integrated across all areas of core business in order to be truly effective.
To ensure this happens senior management need to provide ownership and demonstrate their commitment to
misconduct resistance by making it a top agency priority.
Key elements of the right management environment include:
– The right priority – Misconduct resistance is given high level ownership and central oversight.
– The right business practices – Misconduct resistance is a fundamental part of your agency’s strategic, tactical
and operational business activities – it’s the way you do business.
– The right mindset – Misconduct consciousness is a fundamental part of work practices for everyone in your
agency, with responsibilities structured from the top down – it’s a way of thinking.
– The right review – Review and evaluation processes ensure your agency’s misconduct resistance approach
remains relevant and effective in achieving stated objectives.
– The right communication – Your agency misconduct resistance strategies are consolidated into a documented
approach that is widely communicated.
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1. Committee of Sponsoring Organisations for the Treadway Commission 1992

HOW DOES THE FRAMEWORK APPLY TO YOUR AGENCY?
The Misconduct Resistance Framework outlines the Commission’s view on what a whole of agency approach
to effective misconduct management should involve. It highlights the areas and issues that agencies should
address, and the outcomes they should strive to achieve.
The outcomes, and more specifically the twelve key elements which underpin them, provide the benchmarks
which agencies should use to assess their performance.
The key elements are not prescriptive in terms of how agencies should address them or which strategies they
should adopt. However, the Commission will use these elements as standards in its own review and monitoring
of the whole sector and individual agency performance in managing misconduct.
Agencies are not expected to implement the framework without first considering their needs and required
resources. Each agency should ensure that their approach to addressing the outcomes reflects their core
business and takes into account their risk environment. The size and complexity of misconduct resistance
systems and strategies will depend on the nature and extent of the misconduct risks faced.
The framework is intended to be a practical resource for agencies to assist them in the planning, implementation
and review of their own misconduct resistance efforts. Agencies can use it in a number of different ways,
depending on their needs:
– Those beginning to tackle the issue of misconduct resistance can use the framework to guide where to
start.
– Those with misconduct resistance strategies already in place can use the framework for self assessment and
progress monitoring.
– Any agency can use the framework at any stage to benchmark its performance as a whole (or individual work
areas) over time, and against the performance of similar organisations.
This framework is supported by the Misconduct Resistance Integration Guide and a series of targeted tools.
These provide more detailed and practical guidance on how to integrate misconduct resistance strategies into
existing agency governance and risk management systems. The Integration Guide provides a simple methodology
and a place to start using Focus Questions, Signs of Success and Ideas to Build Capacity.
WHO SHOULD USE THE FRAMEWORK?
The Misconduct Resistance Framework outlines an approach to managing misconduct that can be applied by
all public authorities in WA, including State government departments, boards, public utilities, local government
councils and universities. It has been written for public sector senior executives, councillors, managers and those
with specialist responsibilities for related areas in corporate governance.
Senior Executives: Chief Executive Officers (CEOs) of all agencies and councillors in local government have
primary responsibility for addressing integrity issues and misconduct matters as part of their wider governance
responsibilities. They also have a responsibility under the Corruption and Crime Commission Act 2003 to
report misconduct to the Commission and to ensure that the agency has the internal procedures and
environment that enables reporting to occur.
If you are a CEO or councillor the framework provides you with a model to meet these legal obligations, identifying
the strategic issues that need to be addressed for you to establish an effective misconduct resistance approach
within your agency. It also provides you with a review mechanism for monitoring and benchmarking your agency’s
progress against best practice outcomes.
Managers: If you are a manager or hold a specialist position within an agency, you are responsible for
implementing, integrating and monitoring misconduct resistance strategies within your agency on a day-to-day
basis. You can use the framework to support your accountability role and report to your senior executives, CEO
or council on the implementation and effectiveness of your agency strategies. You can also use the framework to
strengthen, monitor and evaluate your own business unit performance and progress.
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HOW DOES MISCONDUCT RESISTANCE FIT INTO EXISTING PUBLIC
SECTOR INTEGRITY AND ACCOUNTABILITY FRAMEWORKS?
The public sector operates within a complex arrangement of accountability and regulatory requirements. Some of
these, like the criminal justice system, equal opportunity and occupational health and safety provisions, affect all
Western Australians. Others only relate to the public sector, and include a mix of legislation, policies, oversight by
independent bodies and administrative review systems.
The reach of the public sector accountability framework extends to all aspects of agency operations, including its
governance and administration; financial management; reporting requirements; staff conduct and; service delivery.
The general aim of these arrangements is to ensure integrity and accountability in the operation of government
services. They protect and promote public interests by using sector-wide standards and principles, which are
supported by relevant legislation and policy, and regulated through oversight and reporting arrangements.
The Corruption and Crime Commission is one part of the wider public sector accountability framework.
The Commission’s main role is to ensure that allegations of misconduct by public officers are responded to
appropriately by building capacity to prevent misconduct, and helping agencies deal with specific complaints.
There are other important bodies, each with their own areas of responsibility for public sector integrity and accountability.
WA Public Sector Integrity & Accountability Framework
WA WIDE REqUIREMENTS COVERING BOTH PUBLIC AND PRIVATE SECTORS
WorksAfe (DoceP)
OCCUPATIONAL HEALTH & SAFETY STANDARDS
WA Police
CRIMINAL BEHAvIOUR
equAl oPPorTuniTy coMMission
WORKPLACE HARASSMENT & DISCRIMINATION
state records
records
management
PUBLIC SECTOR
SPECIFIC
REqUIREMENTS
state supply
commission
regulates public sector
purchasing
ombudsman
administrative
actions
& decisions
Auditor General
auditing financial
management
& performance
ccc
individual
misconduct
DlGrD
local government
legislation
& regulations
information
commissioner
FOI decisions
DTf
managing public
sector finances
oPssc
HR standards
& codes
of ethics
PSc
Public sector
management
Misconduct is just one of the many integrity risks that agencies need to manage. The outcomes necessary for
effective misconduct resistance do not only impact misconduct – they are also relevant to many other areas of
agency integrity and accountability, which in turn contribute to an agency’s misconduct resistance. Misconduct
resistance cannot and should not operate in isolation.
The Misconduct Resistance Framework seeks to integrate the management of misconduct with other relevant
accountability and regulatory requirements, both conceptually and practically. It also aims to highlight the importance
of recognising misconduct as a significant business risk and addressing it in existing agency governance, staff
conduct and service delivery frameworks and systems.
6

ACKNOWLEDGMENTS
The conceptual foundation for the Misconduct Resistance: An Integrated Governance Approach to Protecting Agency Integrity framework draws on the
Corruption and Crime Commission’s own experience; the work of other integrity bodies across Australia; risk management methodology; as well as
ethics and organisational development literature.
Special acknowledgement is given to the Independent Commission Against Corruption in NSW, the Crime and Misconduct Commission in Qld, and the
NSW Auditor General’s Office, whose work in developing similar integrated corruption and fraud models has been drawn on extensively.
ISBN : 978 0 9805050 3 0
This publication forms part of the Corruption and Crime Commission’s ‘Misconduct Resistance’ series, available from www.ccc.wa.gov.au.
Further information about the Commission can also be found on this website.
DISCLAIMER
This information does not constitute legal advice and the Corruption and Crime Commission accepts no liability for the accuracy of the information; or
for any act or omission done in reliance on the information provided, or for any consequences, whether direct or indirect, of any such act or omission.
© 2008 Copyright in this work is held by the Corruption and Crime Commission. Division 3 of the Copyright Act 1968 (Commonwealth) recognises
that limited further use of this material can occur for the purposes of ‘fair dealing’, for example, study, research or criticism, etc. Should you wish to
make use of this material other than as permitted by the Copyright Act 1968, please write to the postal address below.
Postal Address PO Box 7667
Cloisters Square
PERTH WA 6850
Telephone (08) 9215 4888
1800 809 000 (toll free for callers outside metropolitan Perth)
Facsimile (08) 9215 4884
Email
Office Hours
info@ccc.wa.gov.au
8.30 am to 5.00 pm, Monday to Friday
Public responsibility concerns aside, misconduct is bad for business.

An IntegrAted governAnce ApproAch to protectIng Agency IntegrIty
iNTEGrATiON GUiDE

Introducing MIsconduct ResIstance:
an Integrated Governance approach to Protecting agency Integrity
Why is Misconduct Resistance iMpoRtant?
All Western Australian public sector agencies have a responsibility to deal with misconduct to protect and
promote the integrity of their agency and its services.
The Commission has developed the Misconduct Resistance Framework to help public sector agencies
better manage misconduct by increasing the positive factors that prevent misconduct from occurring, and
eliminating the factors that foster misconduct.
The main objective of the framework is to enhance agency strategies in both of these areas to produce
systems that are effective, and deliver measurable business benefits. This can be achieved by integrating
misconduct resistance with existing agency integrity, risk management, corporate governance and service
delivery systems at the strategic, tactical and operational levels of the agency.
The Misconduct Resistance Framework is available online at www.ccc.wa.gov.au
hoW can you Build Misconduct Resistance in youR agency?
To achieve successful misconduct resistance your agency needs to create and maintain:
The right agency culture
based on
– the right values
– the right leadership
– the right workplace behaviour
The right agency operational strategies
based on
– the right policies
– the right risks
– the right treatment
– the right understanding
The right agency management environment
based on
– the right priority
– the right business practices
– the right mindset
– the right review
– the right communication
Together, these outcomes and key elements provide the benchmark for measuring the adequacy and
effectiveness of agency misconduct resistance approaches.
While there is no order of importance across the outcomes and key elements, they do work interdependently,
and agencies should address them all to manage misconduct effectively.
Misconduct generally occurs when a public officer abuses authority for personal gain or
to cause a detriment to another person, or acts contrary to the public interest.
HOW TO USE THE GUiDE >>

What is the integRation guide?
The Integration Guide is a practical starting point, designed to help you implement the Misconduct Resistance
Framework in your agency. It is targeted at managers and others in specialist positions who have responsibility for
the development, implementation and monitoring of agency misconduct resistance strategies.
The guide contains detailed information about each outcome and provides a methodology for achieving these
outcomes. The key elements underpinning the outcomes each have a set of Focus Questions and Signs of
Success, with supporting Ideas to Build Capacity for each outcome area.
The guide also includes a reference and resource section to help you access more detailed information should
you need to.
FOCUS QUESTiONS identify some of the potentially relevant issues that your agency may need to consider
against the key elements. They are designed to help you evaluate how comprehensive and effective your current
strategies are, and to help identify areas that may need further attention.
SiGNS OF SUCCESS are descriptions of the types of results your agency should be working towards for a particular
key element. They provide examples of what could be seen in agencies that have successfully implemented a key
element.
iDEAS TO BUiLD CApACiTy have been provided for each outcome to help your agency improve management
of a specific issue where a gap or need has been identified. These ideas represent some commonly used
countermeasures, actions and strategies that you can implement.
The questions, signs and ideas are not exhaustive and simply provide a broad-based reference model.
you should customise your use of the guide to capture your agency’s unique business environment and needs.
ReMeMBeR
the guide is not
An audit or compliance checklist that must be strictly
followed.
A prescriptive method for addressing the key
elements.
A sequential list of activities.
A definitive list of all questions and issues to be
addressed.
A one-size-fits-all model for how to integrate
misconduct resistance.
The only way to approach implementation of
misconduct resistance.
Intended to provide all the right questions or answers.
A mandatory document.
the guide is
A place to start when considering how to integrate
misconduct resistance.
An overview of the key elements for your agency to
address.
A prompt of the issues and areas to consider.
A reference from which to select areas needing
attention.
A generic model that can be customised to reflect your
agency’s unique business and risk environments.
A source of ideas for building capacity where a need
is identified.
A guide for obtaining further information and
resources.
Misconduct is a significant business risk for all public sector agencies, and the costs of failing
to manage it effectively can be severe. In a 2006 survey, KPMG found that 47% and 32% of
Australian businesses, including the public sector, respectively reported fraud and unethical
conduct by staff. The most commonly reported conduct risks (after fraud) were misuse of
resources, false sick claims and disclosures of information.
KPMG Forensic Fraud Survey 2006.

hoW to use the guide
You can use the guide in a number of different ways, depending on your agency’s needs and the status of your current
misconduct resistance approach. For example, you can use it as:
— A starting point if you are beginning to tackle misconduct resistance;
— A tool for self assessment and progress monitoring if you already have misconduct resistance strategies in place; or
— A tool to benchmark your agency’s performance as a whole (or individual work areas) over time, and against the
performance of similar organisations.
Using the guide is as easy as following these five simple steps:
STEp 1: Decide which of the outcomes and key elements you need to address first.
(There is no set formula for where to start – your agency’s priorities and needs should form the agenda.)
STEp 2: Try to answer each focus question under the key element you have chosen. This will help
you assess how comprehensive and effective your current strategies are. Not all questions may be
relevant to your agency situation.
After you have addressed each question, you should be able to identify gaps and areas for improvement,
and reach a conclusion about your agency’s overall performance.
Hesitating to readily answer a question may indicate that further review or assessment is required.
(Always consider whether the focus questions adequately cover all the issues relevant to your agency.
Depending on your core business and risk environment, there may be other questions that have not been
included.)
STEp 3: Compare your current agency performance against the corresponding Signs of Success to
benchmark your progress. This will also help you decide whether specific areas of the key element
require further development and what priority they should be given.
(Remember, these signs are indicative only – there may be other indicators that are more relevant to your
agency’s operating environment.)
STEp 4: Use the ideas to Build Capacity together with your own ideas to create an action plan for
dealing with the areas that have been identified as needing improvement.
STEp 5: Use Steps 1 to 3 to review your progress in the areas that were targeted for improvement.
NOTE:
Every agency has a different level of misconduct resistance – one agency’s strategies may be more
comprehensive and effective than another’s.
Your agency may not need to address all of the key elements at this time. However, it is important
that you periodically review your misconduct resistance approach so that you are aware of your
performance against all key elements, and to ensure that you stay on the right track.

THE RIGHT AGENCY CULTURE
AGENCY CULTURE VALUES INTEGRITY
AND IS INTOLERANT OF MISCONDUCT
It is not enough to rely on legislation, codes of conduct and control systems to build
a misconduct resistant agency. While it’s important to express agency values in
official communications, staff need to understand the real meaning of these values
and see them applied in their workplace and in their leaders’ behaviour.
Agency values, the behaviour of the leaders of an agency and workplace culture have
great influence on misconduct resistance. Failing to effectively manage any one of these
elements can have severe consequences, such as damage to your agency’s reputation,
and a decrease in efficiency and long-term sustainability.
Actions speak louder than words. Your agency culture can greatly influence how your
staff will behave – it has the potential to make an ethical person act unethically and vice
versa. While official policies may specify what management would like to happen, it is
your agency culture that determines what happens in practice.
The RIGHT AGENCY Culture

If you are a leader, you play a key role in shaping your agency culture as other staff look
to you for guidance. If your behaviour doesn’t reflect the stated values, it’s likely that
your staff will place less importance on these values.
A misconduct resistant workplace promotes individual responsibility and accountability
by working with its people and involving them in the development of integrity strategies.
It also encourages staff to embrace agency values and codes of conduct, and use them
to develop their own high standards, norms and controls. Given the constant change in
the operating environment within the public sector, maintaining a misconduct resistant
culture as a visible and important part of your everyday working life will pose an ongoing
challenge.
Making sure that your staff, customers and others who interact with
your agency are aware of your agency’s commitment to integrity and
misconduct resistance can lead to higher standards across all of your
business activities – it can improve decision making, increase customer
confidence, and increase staff morale and productivity.

the right values
Your agency’s communication, actions and decisions reflect its values and
public interest principles.
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Focus Questions
Does your agency understand the importance of integrity and misconduct resistance to
business outcomes, and do your values and policies reflect this?
Does your agency have a clear set of values that are consistent with public duty principles?
Do your agency’s Human Resource processes (e.g. recruitment, promotion and performance
management etc.) use the agency values as benchmarks to assess suitability?
Does your agency’s code of conduct include both high level aspirational statements and
statements about behavioural expectations that provide a benchmark for dealing with
misconduct?
Does your agency’s code of conduct/values state what it means to act in the public interest in
the agency workplace?
Has your agency involved staff and key stakeholders in the development and review of agency
values and policies to ensure their continued relevance?
Does your agency have a process for ensuring that all official communication (e.g. policies,
guidelines, statements, publications etc.) is in line with your agency’s values?
How does your agency ensure that all of its decisions and actions align with its values?
Does your agency support and encourage managers to act in the public interest when
resolving integrity issues and prioritising issues?
Do your agency’s policies and practices include standards that reflect your agency’s values
and encourage your staff to act in the public interest?
Has there been an evaluation of how well your agency’s values have been promoted,
understood and integrated into agency operations and decision making?
How does your agency ensure that values are communicated to your staff, customers and
suppliers regularly; and does your agency monitor whether the communication is received,
understood and accepted?
Does your agency have an induction for new staff at all levels which addresses the importance
of acting with integrity and in the public interest?
Do your agency’s other training programmes address the importance of acting with integrity
and in the public interest?
Does your agency measure the impact of your agency’s values on staff morale and productivity,
customer satisfaction, and agency reputation?
SignS of SucceSS
Your agency operates using a clear set of values which are consistent with public interest
principles. These values are reflected in your agency’s code of conduct, which is periodically
reviewed with staff involvement.
The code of conduct is actively promoted both inside and outside your agency. It is featured
in your agency’s publications; and it is recognised by staff in everyday practices and
documentation, such as contracts with suppliers.
Human Resource policies and practices within your agency reflect a commitment to recruiting
people who share agency values, and to providing staff development which helps staff carry
out their duties with integrity and in the public interest.
Your agency has a strategy to ensure that all official written communication, policies,
programmes, work practices and decision making processes are in line with agency values,
reflect misconduct resistance objectives, and link to business outcomes. The effectiveness
of this strategy is closely monitored and reviewed.
Your agency ensures that staff, customers and others who interact with your agency know
about your agency’s values, commitment to integrity and misconduct resistance. Your
agency’s training and induction programmes, and other forms of agency communication are
used to promote higher standards across all your business activities.

the right leadership
Leaders within your agency set an example of integrity with their own behaviour,
their communication and their responses to misconduct by others.
Focus Questions
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Does your agency assess a candidate’s commitment to integrity before appointing them to a
senior management role?
Do leaders understand that they play a key role in promoting misconduct resistance?
Do leaders set the tone for integrity by way of example, and do they promote your agency
values to others?
Do leaders reinforce the effects of proper conduct on business outcomes, and the risks
associated with misconduct?
As integrity issues arise, are they addressed in your staff and business unit meetings?
Are agency values promoted in your staff and business unit meetings?
Do management performance agreements and remuneration strategies refer to responsibility
for promoting your agency’s values within the workplace?
Does your agency provide an internal or external leadership programme which addresses
integrity issues and is compulsory for all managers and optional for aspiring leaders?
What systems exist for supporting those staff who act with integrity and for dealing with
those who breach your agency’s code of conduct?
Are your staff members confident in the integrity of their leaders?
Does your agency include in its measurement of individual work unit performance efficiency
indicators, such as customer satisfaction, complaints about staff conduct, turnover levels
etc.?
SignS of SucceSS
Your agency appoints managers who demonstrate a high level of understanding of integrity
issues and their impact on agency performance. Performance reviews monitor your
managers’ ability to promote integrity in the workplace and their ongoing commitment to it.
Your staff are confident that managers abide by the same integrity standards and that they
promote the importance of acting with integrity.
Your staff have the skills and ability necessary to lead with integrity within their business
units.
Your leaders and managers understand the relationship between agency culture, misconduct
resistance and business outcomes, and communicate it to their staff. They act with integrity
and clearly communicate the expected standards, and intervene when misconduct occurs.
Your agency uses efficiency indicators, such as staff morale and productivity, customer
satisfaction, and integrity related complaints, to monitor individual and work unit
performance.

The RIGhT woRkplACe behAvIouR
Your workplace culture encourages staff to accept personal responsibility for
behaving according to agency values and in the public interest.
FoCus QuesTIoNs
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Do supervision, performance reviews, promotion and recognition processes take into account
staff behaviour concerning your agency values and standards of conduct?
Does your agency consistently and fairly deal with misconduct issues across all agency
employee groups and contractors?
Are your staff, contractors and senior executives required to formally acknowledge the code
of conduct in any way?
Does the behaviour of your staff show that they take full responsibility for behaving according
to agency values?
Does your agency culture support the practice of reporting misconduct by staff and
inappropriate behaviour of suppliers and customers?
Does your agency support those who report misconduct in good faith?
Does your agency raise integrity awareness through integrity training for staff, customer
service charters, and other publicity on the rights and responsibilities of customers and
contractors?
Does your agency have programmes that encourage staff to value integrity, transparency and
responsible reporting?
Does your agency use performance indicators in monitoring and evaluating its culture?
Are your staff members aware of the negative impact on business outcomes and specific
business risks associated with misconduct?
Does your agency monitor costs associated with reported incidents of misconduct
(e.g. material losses; resources invested in investigation; service and customer losses;
damage to reputation, etc.) and measure this against changes in your agency culture?
SIgnS of SucceSS
Your agency actively encourages personal commitment to its integrity framework through
staff participation during the development, implementation and review of the framework;
and then throughout each person’s appointment through ongoing awareness and staff
development initiatives.
Agency staff understand the behavioural standards expected of them and the impact of
misconduct on your agency’s performance, and are aware that breaches of agency code will
be dealt with accordingly.
Your agency widely communicates to external stakeholders that it is committed to integrity,
that it will not tolerate dishonest dealings and that it expects stakeholders to report
misconduct.
Your agency has a programme for benchmarking agency culture and uses this information
to evaluate agency performance; assess the costs and benefits of agency integrity systems;
and identify areas for improvement.

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IdeAs To buIld CApACITY
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Adopt and promote ethical decision making processes within your agency.
Include integrity issues in your agency induction, education and awareness
programmes.
Continually reinforce agency values and public interest principles – not just
during training programmes.
Include integrity issues in your agency discussions.
Establish leadership, management counselling or mentoring programmes
which focus on integrity issues.
Establish clear and reasonable behavioural expectations through codes of
conduct, performance measures and business processes.
Communicate your agency values and their importance to the performance of
your agency to key stakeholders through a targeted communication plan.
Consider public interest and misconduct resistance objectives when reviewing
your agency policies and procedures.
Assess whether your staff understand, accept and apply agency values to their
day-to-day work.
Implement a rolling integrity awareness programme through your agency
publications such as newsletters, websites, policy statements on misconduct
risk areas.
Publicise misconduct resistance and integrity themes using promotional
strategies such as campaigns, slogans, screen savers, online materials,
posters, etc.
Involve all employees in the development of your agency values.
Employ values and public interest principles in your recruitment, selection, and
performance management processes and criteria.
Set up an in-house process to decide on integrity issues and ethical dilemmas.
Develop a recognition and rewards programme for high integrity standards.
Use case studies and real life examples to promote the business benefits of
proper staff conduct and the costs of staff misconduct.
Use structured questionnaires to evaluate the current culture in your agency.
Measure the impact of culture on your agency performance indicators such
as productivity levels, staff morale, customer satisfaction, agency reputation,
appeals against agency decisions, complaints data, etc.
Establish a system for screening your potential employees, suppliers and
customers.
When required, provide copies of agency values, code of conduct, complaints
and disciplinary policies to your customers and/or contractors.

THE RIGHT AGENCY OPERATIONAL STRATEGIES
AGENCY POLICIES AND SYSTEMS SUPPORT
THE EFFECTIVE TREATMENT OF MISCONDUCT RISKS
Misconduct represents a significant business risk for agencies, and if unmanaged,
it can damage your agency reputation, destroy public trust and sabotage business
efficiency and effectiveness. Managing misconduct risks is a key part of your
agency’s overall misconduct resistance approach and is essential to good corporate
governance.
Agency policies give direction to strategies for dealing with misconduct and are important
in effective risk management. They should be comprehensive, covering the full range
of potential misconduct; and they should communicate your agency’s commitment to
integrity and its firm position on dealing with misconduct.
To ensure the success of risk management programmes within your agency, all staff and
management must understand and commit to your agency’s risk management approach.
They should be fully aware of how they are expected to behave should they become
aware or suspicious of misconduct.
THE RIGHT AGENCY OPERATIONAL STRATEGIES

An effective treatment programme for dealing with misconduct should be based on a
comprehensive risk management system that:
w Identifies and analyses current and emerging risks across all discrete agency functions
and operations;
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Embeds misconduct risks in your agency’s overall risk management plan;
Includes proactive measures for increasing integrity and preventing misconduct; detection
measures for identifying misconduct; and reactive measures for investigating and
responding to misconduct; and
Closely monitors your agency’s risk exposure, and reviews and improves programmes for
dealing with misconduct.
Each stage of the risk management process will require adequate resources.
Experience has shown that one of the most common misconduct detection
methods is internal reporting by staff. This means that the effectiveness of
treatment programmes greatly depends on the integrity of the people who
create, administer and monitor them.

THE RIGHT POLICIES
Your policy platform provides a solid foundation for establishing your agency’s
treatment environment and communicates your commitment, values and business
practices for misconduct resistance.
FOCuS QuESTIONS
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Did your agency consult with staff and key stakeholders (e.g. internal corporate governance, risk
management committees, customer groups) during the policy development stage?
Does policy clearly communicate your agency’s misconduct resistance approach (e.g. your
agency’s values, misconduct resistance objectives and no tolerance position)?
Does policy address all the misconduct risks that are specific to your agency?
Is policy based on an integrated risk management approach and implemented with the support of
appropriate guidelines and procedures?
Has your agency identified and linked all policies that relate to misconduct risk, ensuring they
reflect consistent principles and objectives, and eliminated any duplicate or redundant policies?
Is there a routine review and policy amendment process to reflect changes in your agency’s
operating environment?
Does your agency monitor and assess the implementation and effectiveness of policy
(e.g. levels of compliance, whether set objectives are achieved, work practice standards)?
Does your agency monitor policy breaches and assess their impact on business outcomes
(e.g. standards of service delivery, customer satisfaction)?
Is policy easily accessible to staff?
SignS of SuccESS
Your agency has documented policy that clearly states its objectives and your agency’s approach
to misconduct and building misconduct resistance.
All integrity and misconduct related policies, guidelines and supporting procedures reflect the
same underlying approach and position on misconduct, without contradicting each other.
Policy is continuously reviewed and updated to reflect changing conditions, and is a point of
reference for staff in effectively dealing with misconduct issues.
Your agency closely monitors policy implementation, assesses whether the work practice
standards it sets have been met, and measures its effectiveness against stated objectives and its
impact on business outcomes.

THE RIGHT RISkS
Misconduct risk identification and assessment are part of the wider corporate risk
management planning process and include all of your agency’s functions and
operational areas.
FOCuS QuESTIONS
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Does your agency understand what misconduct is and what it might look like in your agency?
Is your agency aware of all misconduct risks, including those which are unique to the core business
of your agency, and those that are prevalent across the public sector?
Have specific misconduct risks been linked to specific types of behaviours?
Has your agency implemented a comprehensive risk identification process that involves
consultation with all stakeholders, and identifies potential misconduct risks from internal and
external sources in all areas?
Does your agency use the information obtained from misconduct and complaint reports and from
reviews of systems and procedures to update its risk identification and assessment processes?
Does your agency use a customised risk identification approach and language to identify
misconduct risks within your particular agency?
Does your agency understand the impact of specific misconduct risks on business outcomes, and
can this impact be measured?
Have your agency misconduct risks been evaluated against corporate risk criteria and prioritised
for treatment as part of the corporate risk management plan?
Does your agency use tailored criteria which reflect its business environment to ensure that the
priority assessment is accurate in terms of the impact of misconduct risks on business outcomes
(e.g. the dollar value may not be the best criterion for determining the damage caused by loss of
public trust)?
Is there a designated person, group or committee responsible for coordinating the assessment of
misconduct risks and integrating it with corporate risk management planning processes?
SignS of SuccESS
Your agency has drawn on all stakeholder viewpoints to develop a comprehensive understanding
of its misconduct risks, both those inherent to core business and those common across the
sector. Your agency periodically reappraises its current misconduct risks and emerging threats in
all work areas and across all operational and administrative functions.
All identified risks are analysed, evaluated against your agency risk criteria and their impact on
business outcomes quantified using relevant measures. You have included a prioritised list of
misconduct risks requiring further treatment in the corporate risk management plan.
Responsibility for the implementation and monitoring of misconduct risk assessment and planning
processes has been allocated to a person or group who are also represented on the corporate
risk management committee (or equivalent body).
Your agency’s methodology for misconduct risk management meets recognised best practice
standards and uses a customised process and language to address misconduct.
10

THE RIGHT TREATmENT
Your misconduct treatment programme is commensurate with the level and nature
of risk you face, comprehensive and adequately resourced, and is subject to
ongoing monitoring and review.
FOCuS QuESTIONS
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Has your agency evaluated and developed treatment plans for those misconduct risks that have
been identified as high priority?
Do your misconduct treatment plans cover all aspects of business activities, service delivery and
‘corporate health’, not just financial operations?
Does your agency misconduct treatment programme have a dual focus? That is, does it both
eliminate and restrict factors which increase the likelihood of misconduct; and encourage and
increase factors which inhibit misconduct?
Do your misconduct treatment strategies cover the areas of prevention, detection and
response?
Does each misconduct treatment strategy clearly allocate responsibilities, resources and
timeframes for implementing and monitoring mechanisms?
Does your agency have an ongoing process for detecting misconduct, and if so, how does it
do this (e.g. external audits, analysis of business data for indicators of misconduct or reporting
systems)?
Is there a regular audit programme that independently reviews the adequacy of your misconduct
treatment strategies and assesses compliance with the misconduct treatment programme
throughout your agency?
Does your agency have a management information system that captures and tracks all reportable
incidents of misconduct from the initial complaint, throughout the notification and investigation
process, and through to collation for analysis purposes, and for performance and external
reporting?
Is there an internal misconduct reporting system available to your staff and stakeholders that
extends beyond normal communication channels and provides anonymity?
Do your staff and other stakeholders use the internal reporting system; and is the system
evaluated to determine its effectiveness and the protection it affords complainants?
Does your agency have a policy and procedure for responding to misconduct, supported by a
complaint and notification handling system?
Does your agency have an effective internal investigation process with a clear accountability
structure for response to and escalation of misconduct investigations?
Are there established protocols and procedures for reporting matters to external authorities; and
are they followed and measured?
Does your agency review the results of misconduct investigations to identify systems issues and
underlying causes, and does it amend misconduct controls accordingly (e.g. emerging threats,
policy and procedural gaps and areas for improvement)?
Has the treatment programme been reviewed following updated risk reassessments and changes
in your agency’s operational systems to determine whether the strategies are still relevant and
address your agency’s day-to-day issues at this point in time?
Does your agency use available performance data such as complaints information, customer
surveys, compliance audits, etc. to monitor and evaluate the effectiveness of the misconduct
treatment programme?
Does your agency ‘cost’ or quantify the impact of reported misconduct (e.g. resources allocated
to the investigation and management of misconduct incidents, loss of resources, impact
on service delivery and productivity, damage to agency reputation and staff morale, etc.)?
Is this information used for the cost-benefit analysis of your agency’s misconduct treatment
programme?
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noTES
SignS of SuccESS
Your agency has a comprehensive misconduct risk treatment programme that addresses:
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All high risk agency functions and activities;
The recommended measures for eliminating and minimising the impact of these risks;
Assigned roles and responsibilities; and
An ongoing improvement system that includes regular monitoring and review, updated risk
assessments and performance data.
Your agency policies and procedures provide comprehensive coverage of identified high priority
misconduct risk areas/issues, and give clear guidance to staff on how to deal with them effectively.
These are periodically reviewed to ensure they remain current and relevant in addressing the
day-to-day misconduct risks facing staff.
Your agency has a centralised management system for reported misconduct incidents that:
w Identifies and records information about matters across different complaint and Human
Resource systems;
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Manages internal and external reporting; analyses trends and practice issues; and
Ensures an appropriate and consistent response.
Your CEO can go to one point within the agency to learn about the extent of misconduct matters
across the entire agency, how these matters are being dealt with and whether external reporting
obligations are being met.
The responsibilities for implementing and monitoring the treatment programme, and the dayto-day
responsibilities for implementing and monitoring individual treatment strategies are
clearly defined and shared among managers and staff. Adequate resources in terms of training
(investigators, auditors, etc.), funding and time have been allocated to the programme.
Your agency collects information about the costs of reported misconduct, which includes response
costs and costs to business outcomes, and uses this information in its cost-benefit analysis of
individual misconduct resistance strategies and its overall approach.
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THE RIGHT uNdERSTANdING
Your staff and managers have a common understanding of what misconduct is. They
embrace your agency’s stand on misconduct, as stated in the agency policy and treatment
programme, and know how to respond should they become aware of misconduct.
FOCuS QuESTIONS
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Do staff understand what types of behaviour constitute misconduct and which of your agency
functions and activities have been identified as high risk?
Are staff informed of emerging misconduct risks and issues?
Does your agency encourage staff at all levels to get actively involved in all stages of the
misconduct risk identification, assessment and treatment planning process; and to contribute to
managing risk by developing and adopting better controls?
Do staff know about the misconduct treatment programme and can they access your documented
treatment plan?
Is there an ongoing communication strategy to ensure misconduct related policies and procedures
and other treatment strategies are widely distributed and understood; has the effectiveness of
these strategies been assessed?
Do the corporate induction programme and other staff training programmes include information
about your agency’s misconduct resistance policies and treatment programme?
Do staff clearly understand and accept their responsibility to report suspected misconduct, and
does your agency culture support this?
Does your agency map its internal reporting data over time and by work unit to identify trends,
and does it analyse the data against performance data and inherent risk profiles?
Has your agency assessed the level of staff understanding about misconduct and your agency’s
approach to its management?
SignS of SuccESS
Your induction, education, and awareness raising programmes provide staff with enough
information to enable them to identify, prevent and report suspected misconduct.
Your agency’s internal reporting system is well publicised and easily accessible. It encourages staff
to report misconduct and reassures them that supporting arrangements will protect individuals
and their confidentiality as far as possible.
Your staff know that misconduct will not be tolerated and, depending on their level of responsibility,
they are given information about the prevention, detection and response measures that are in
place.
Your agency encourages all staff to contribute to agency risk management strategies, to develop
and adopt better controls in their work units, and to alert management to potential systemic
risks.
Your agency keeps staff constantly aware of misconduct issues through regular communication
e.g. provides updates on changes to misconduct related policies and procedures, and publicises
information about emerging risks and integrity issues.
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!
IdEAS TO BuILd CAPACITY
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Undertake a misconduct risk identification process within your agency.
Use different methodologies such as independent assessments, internal
misconduct risk surveys or facilitated workshops, customer interviews, analysis
of audit outcomes, or use available misconduct risk checklists.
Allocate misconduct risk coordination responsibility to a person or a committee.
Introduce misconduct awareness training according to staff’s level of
responsibility, with specialist and specific training for high risk functions and
different staff groups.
Establish a misconduct incident register.
Establish internal reporting systems such as anonymous hotlines and
Whistleblower (PID) Programmes.
Survey your staff, clients, suppliers and other stakeholders to assess their
willingness to use available reporting mechanisms.
Establish protocols and procedures for external reporting.
Introduce standardised investigation practices based on established best
practice models.
Review your current agency policies and procedures to identify any gaps where
additional guidance may be needed.
Develop policies and procedures to address specific high risk functions/activities
where gaps exist.
Conduct staff surveys to assess awareness levels, attitudes to and perceptions
about misconduct and/or aspects of your agency’s treatment programme.
Develop customer, supplier and contractor information guides outlining best
practice in business dealings with your agency.
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THE RIGHT AGENCY MANAGEMENT ENVIRONMENT
MISCONDUCT RESISTANCE IS AN INTEGRATED
AND ESTABLISHED COMPONENT OF AGENCY LIFE
Having the right agency culture and operational strategies will not by themselves achieve
effective misconduct resistance. To be effective, misconduct resistance must be driven from
the top, embedded in your agency management environment and integrated into all agency
business activities. This requires high level commitment and ownership, with accountability for
implementation of the misconduct resistance approach being allocated at the senior executive
level, where there is sufficient authority to ensure it is given effect.
Your management environment provides the foundation for how the agency operates. It incorporates
your agency business ethos, systems and structures, and the assignment of authority and
responsibility. The right management environment will:
w Instil your agency with an attitude of integrity and misconduct consciousness;
w Promote misconduct resistance as integral to your agency’s performance;
w Reinforce the benefits to your general business efficiency and effectiveness; and
w Integrate misconduct resistance so completely into the strategic, tactical and operational
business activities of your agency that it becomes a fundamental part of business for everyone.
While agency management systems and structures can provide an environment conducive to
building misconduct resistance, the actions of the people charged with relevant responsibilities
will determine whether misconduct resistance objectives are actually achieved.
THE RIGHT AGENCY MANAGEMENT ENVIRONMENT

When staff have internalised your agency’s misconduct resistance approach and become involved in
and committed to its achievement, the approach will become an established part of the way things
are done, and something everyone knows so well that they no longer have to think about it.
It is important to review and evaluate your agency’s misconduct resistance approach to maintain
its effectiveness and relevance. Regular review is also a way to monitor the integration and
performance of your approach.
To document and communicate your agency’s misconduct resistance approach, your agency
needs to articulate:
w Why is the approach needed (e.g. legislative requirements, expected benefits to agency
performance and business outcomes)?
w How will the agency build misconduct resistance? This entails drawing together all relevant
policies, systems, management practices etc.
w Who is responsible for implementing your agency’s approach?
w What measures and performance indicators will be used in assessing performance and
business benefits?
Informing staff, customer and contractor groups about your agency’s stand on
misconduct can improve your agency’s reputation and community confidence.
Having informed stakeholders can also help prevent practices and dealings contrary
to your agency standards; and they are more likely to uncover other situations that
could impact negatively on the integrity and effectiveness of your agency.

THE RIGHT pRIORITY
Misconduct resistance is given high level ownership and central oversight.
FOCus QuEsTIONs
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Does senior management understand the business benefits of misconduct resistance and treat the
risk of misconduct seriously (even in the absence of recently detected incidents)?
Has your CEO given a public commitment to misconduct resistance as an agency priority?
Has responsibility for the implementation and monitoring of your agency misconduct resistance
approach been allocated to a position/committee with sufficient authority to ensure it is given effect?
Do those responsible for the agency misconduct resistance approach have access to the appropriate
skills, knowledge, and experience to discharge this responsibility?
Is there regular progress reporting to the executive management team against agreed misconduct
resistance objectives, milestones and performance indicators?
Are all business units and others with delegated responsibilities required to centrally report on their
own progress in implementing the plan?
Does your agency allocate an appropriate level of resources (financial and human) to managing
misconduct successfully?
Is information about your agency misconduct resistance approach included in the annual report or
other performance reports?
SIgnS of SucceSS
Misconduct resistance is treated as a top corporate priority with accountability for its implementation
vested at the senior executive level.
Your agency has a mechanism for central oversight of the misconduct resistance approach which
includes a process for centralised reporting on progress back to the corporate executive.
Senior management has an observably high level of ‘risk consciousness’ regarding misconduct and
has committed the resourcing required to ensure it is effectively managed.
Your agency includes information about the effectiveness of its misconduct resistance approach in
corporate performance reports.
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THE RIGHT busINEss pRACTICEs
Misconduct resistance is a fundamental part of your agency’s strategic, tactical and
operational business activities – it’s the way you do business.
FOCus QuEsTIONs
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Does your agency management philosophy recognise and promote the link between misconduct
resistance and agency performance at all levels and in all areas?
Do misconduct resistance issues form an integral part of corporate, strategic and operational planning
process and objectives, both annually and long term?
Are misconduct resistance principles and objectives used as a filter and applied as part of all project
planning, agency restructure and service review processes?
Are integrity and misconduct resistance objectives integrated into all business processes (e.g.
embedded in policies, operational procedures and guidelines, decision-making criteria and processes,
the assignment of authority and responsibilities)?
Are all of your agency’s misconduct resistance resources (e.g. Human Resource unit, compliance &
audit functions, legal services, records management, regulatory systems, quality assurance processes
etc.) coordinated in working towards achieving the objectives of the misconduct resistance approach?
Do your agency structures and systems support the integration of misconduct resistance activities
across all agency functions?
Have misconduct resistance strategies been implemented in all work areas across your agency?
Is this monitored in any way?
Is performance against misconduct resistance objectives included as part of your business unit
reporting?
SIgnS of SucceSS
All business units are accountable for demonstrating that they are implementing your agency’s
misconduct resistance strategies, with misconduct resistance being incorporated into your agency’s
general business reporting and performance measurement systems at the individual, work unit and
corporate levels.
Your agency has a strategy in place to ensure that the consideration of misconduct resistance
objectives and issues is integral to all core administrative, planning, decision making and service
delivery business activities.
Your agency’s management environment, as reflected in its management philosophy and operating
style, systems and structures, and assignment of authority and responsibility, actively promotes and
supports the integration of the misconduct resistance principles in all business activities and areas.
Staff in all work units view misconduct resistance as a fundamental part of business, something
everyone knows about and considers as part of their normal business activities.
18

the right mindset
Misconduct consciousness is a fundamental part of work practices for everyone in your
agency, with responsibilities structured from the top down – it’s a way of thinking.
Focus Questions
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Do staff in all work areas know about, understand and support your agency’s misconduct resistance
objectives?
Are your staff members encouraged (in a corporate sense and/or at business unit level) to be actively
involved in the development, implementation and review of your agency’s misconduct resistance
strategies?
Have responsibility and accountability for the implementation of your agency’s misconduct resistance
strategies been clearly assigned, included in agency policies and procedures, and reflected in job
descriptions?
Are your staff members aware of their responsibilities for implementing, complying with and promoting
your agency’s misconduct resistance plan, and do they accept these responsibilities?
Are delegations, authorities and the supervisory roles of management clearly defined in your agency’s
misconduct resistance plan, and are these responsibilities addressed as part of regular performance
reviews?
Does your agency monitor and/or assess levels of staff awareness, understanding and compliance
with misconduct resistance responsibilities?
SignS of SucceSS
There is broad based commitment across your agency to the objectives of the agency’s misconduct
resistance plan. Integrity and misconduct consciousness are firmly established as the way everyone in
your agency thinks and operates, acting as a filter applied to day-to-day core business activities and
decision making.
Your agency’s structures provide staff, from the top down, with a clear understanding of the
agency’s misconduct resistance activities, processes and outputs for which they are responsible and
accountable, and to whom they must report.
19

the right review
Review and evaluation processes ensure your agency’s misconduct resistance
approach remains relevant and effective in achieving stated objectives.
Focus Questions
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Is there a plan and mechanism in place for reviewing and assessing the effectiveness of your agency’s
misconduct resistance strategies against key milestones, stated objectives and expected outcomes
using standardised performance measures and indicators?
Do review and evaluation processes make use of internal and external feedback, and information
from misconduct complaints and investigations to improve business practices?
Do your agency’s review and evaluation processes attempt to measure the extent to which your
misconduct resistance approach has been integrated across different business activities?
Has your agency assessed whether the individual components of the misconduct resistance approach
(i.e. values, leadership, culture, treatment program, structures etc.) have increased or decreased the
incidence of misconduct and its concealment?
Has your agency assessed the impact of its misconduct resistance approach against general business
efficiency and effectiveness indicators, such as numbers of complaints/customer satisfaction levels,
staff turnover and morale, productivity figures, financial loss through theft and misuse of resources
etc.?
Have your agency’s misconduct resistance objectives been reviewed and confirmed or amended in
light of organisational, environmental, business condition or government policy changes, including the
results from updated risk assessments?
Is business unit and corporate performance data consistently collected and analysed to inform the
review and evaluation processes?
Does your agency use benchmarking as a means of evaluating performance across work units and
against wider sector and industry norms?
SignS of SucceSS
Your agency has an established and appropriately resourced review and evaluation mechanism to
assess whether misconduct resistance strategies are effective in achieving objectives. The review
and evaluation mechanism also ensures that the strategies remain relevant and appropriate to your
agency’s operations, and accommodate changes in the external operating environment.
The review mechanism has specified timelines, incorporates both internal and external review
processes, outlines key milestones and objectives to be achieved, and details the resources
required.
The results from review and evaluation processes are used to benchmark your agency’s performance
(over time and across business units) and to support continual improvement in your agency’s
misconduct resistance, business practices and service delivery, and general business efficiency and
effectiveness.
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THE RIGHT COMMuNICATION
Your agency misconduct resistance strategies are consolidated into a documented
approach that is widely communicated.
FOCus QuEsTIONs
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Has your agency approach to misconduct resistance, with all its component parts and initiatives, been
consolidated and documented as an integrated, whole of agency strategy or plan?
Does your documented agency approach clearly articulate the strategies and initiatives adopted to
build integrity and misconduct resistance; how these will work together; the expected benefits to
performance; and the measures of success?
Does your agency have a strategy for ensuring that your misconduct resistance approach, its principles
and objectives are well known to all staff? Is the effectiveness of this strategy evaluated?
Does your agency have a customer and community awareness strategy that broadcasts your agency’s
no tolerance stand on misconduct, and the measures you have adopted to detect misconduct and
encourage suspected misconduct to be reported?
Do your agency’s annual report and other publications include reference to your misconduct resistance
approach?
Has the effectiveness of communication and awareness strategies been evaluated in terms of
the impact on the behaviour of your different stakeholder groups (e.g. the reporting of suspected
misconduct by your staff and customers, the incidence of externally instigated misconduct etc.)?
Is your agency’s documented misconduct resistance approach available to staff and do they know
how to access it?
Are contractors and suppliers given relevant information about your agency misconduct resistance
approach?
Does your agency survey or in any other way measure customer and/or contractor perceptions in
respect to its services and business practices/performance? Do these mechanisms include questions
about misconduct resistance issues?
Is performance data such as complaints statistics used in the evaluation of your agency’s
communication strategy?
SIgnS of SucceSS
Your agency’s misconduct resistance approach has been holistically planned, considers your agency’s
position against each of the 12 elements in the Misconduct Resistance Framework and has strategies
tailored to meet the needs and resources of your agency.
Your agency’s misconduct resistance approach has been documented, is promoted by management
and widely communicated both internally and externally.
There is widespread understanding and support for your agency’s stand on misconduct amongst your
staff, customers and other stakeholders that has resulted in measurable improvements in areas such
as business practices, customer confidence and misconduct reporting.
21

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IdEAs TO buILd CApACITY
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Establish misconduct resistance as a regular item at meetings of executive and/or
the corporate governance group.
Appoint a misconduct resistance committee, chaired by a senior member of executive,
to implement and monitor your agency’s misconduct resistance approach.
Include briefings on your agency’s misconduct resistance approach and related
issues at senior management meetings.
Use your staff and business unit meetings as a forum to actively promote and raise
awareness about your agency’s misconduct resistance approach and how it relates
to general performance.
Include misconduct objectives and performance measures in your operational and
corporate reporting processes.
Develop a model or template as a guide to the inclusion of misconduct resistance
objectives in your agency policies, processes and procedures etc. Use this guide
when policies and procedures are being reviewed.
Undertake business re-engineering processes aimed at incorporating your misconduct
resistance objectives into current business processes.
Include misconduct resistance responsibilities in job descriptions and performance
management systems.
Monitor the progress of your agency misconduct resistance approach through
data collection in respect of programme activities and outputs e.g. statistics on
complaints, investigations, referrals and outcomes.
Undertake comparative evaluations of performance between different business units
and over time etc.
Perform cost-benefit evaluations.
Use surveys and questionnaires to gather information from your staff, customers and
suppliers.
Use exit interviews to evaluate your agency’s approach to misconduct resistance,
and identify any areas for potential improvement.
Benchmark your agency’s approach and performance against other agencies
operating in the same business or industry sector.
Publicise your service standards, performance pledges, code of conduct and
complaints processes by making them readily available at service centres and on
websites.
Develop conditions of business dealings with external parties and include these in
‘requests for tender’ and other contracting processes.
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REFERENCES and RESOURCES
In the following section you will find a comprehensive list of all of the references used to compile
the Misconduct Resistance: An Integrated Governance Approach to Protecting Agency Integrity
series of documents. This list has been expanded to include additional references and resources
that you can use to find more information about any of the three outcome areas.
REFERENCES and RESOURCES

ThE RighT agENCy CUlTURE
Australian Public Service August 2007, APS Values and Code of Conduct in Practice: Guide to official conduct
for APS employees and Agency Heads.
Independent Commission Against Corruption 2000, What is an ethical culture? Key issues to consider in building
an ethical organisation.
Independent Commission Against Corruption April 2001, The First Four Steps.
Office of the Public Sector Standards Commissioner, undated, Ethics Framework.
Office of the Public Sector Standards Commissioner, undated, Revitalising your code of conduct: Guidance
notes for public sector agencies.
Office of the Public Sector Standards Commissioner September 2004, Building & Sustaining Integrity –
Integrating Ethics into Everyday Business.
Office of the Public Sector Standards Commissioner February 2008, Conduct Guide.
Office of the Public Sector Standards Commissioner February 2008, Western Australia Public Sector Code of
Ethics.
Office of the Public Sector Standards Commissioner February 2008, Supporting Information: Conduct Guide.
Sampford, C and Preston, N with Bois, C-A 1998, Public Sector Ethics – Finding and Implementing Values,
Chapter 6 by Stephen D Potts, Ethics in Public Service – An idea whose time has come.
Sampford, C and Preston, N with Bois, C-A 1998, Public Sector Ethics – Finding and Implementing Values,
Chapter 8 by Colin Hicks and Gerald Scanlan, Integrating Ethics.
The Western Australian Integrity Coordinating Group 2006, Taking action on integrity issues.
Western Australian Premier’s Circular 2008/01, Requirement for Public Sector Agencies to Develop Codes of
Conduct.
ThE RighT agENCy OpERaTiONal STRaTEgiES
Australian Research Council, undated, ‘Whistling While They Work’: Enhancing the Theory and Practice of
Internal Witness Management in Public Sector Organisations, Australian Research Council Linkage Project -
2005-2008, http://www.griffith.edu.au/centre/slrc/whistleblowing.
Australian Standard 8001:2003, Fraud and Corruption Control.
Australian Standard DR 06651 (Revision of AS 8001-2003), Fraud and Corruption Control.
Australian/New Zealand Standard 4360:2004, Risk Management.
HB 436:2004, Risk Management Guidelines – Companion to AS/NZS 4360:2004.
Australian Standard 4811:2006, Employment Screening.
AS ISO 10002 – 2006, Customer satisfaction – Guidelines for complaint handling in organisations.
Corruption and Crime Commission 2005, Protecting Personal Data in the Public Sector – Report of an Inquiry
into Unauthorised Access and Disclosure of Confidential Personal Information Held on the Electronic Databases
of Public Sector Agencies.
Corruption and Crime Commission May 2006, Disclosure of Misconduct Reports Made to the Corruption and
Crime Commission: Guidelines for Principal Officers of Public Authorities.
Corruption and Crime Commission October 2006, Sexual Contact With Children By Persons in Authority in the
Department of Education and Training of Western Australia.
Corruption and Crime Commission 2007, Dealing With Conflicts of Interest - Practical Guide for the Western
Australian Public Sector.
Corruption and Crime Commission July 2007, Notification Guidelines for Principal Officers of Public Authorities.
Independent Commission Against Corruption, and the Crime and Misconduct Commission 2004, Managing
Conflicts of Interest in the Public Sector: Toolkit.
24

KPMG 2004, Forensic Fraud Survey 2004 Australia.
KPMG 2006, Forensic Fraud Survey 2006.
KPMG 2007, Fraud Risk Management in the Public Sector – What are the trends and effective strategies to
address fraud and misconduct?
KPMG 2007, New trends in identifying and mitigating fraud, Forensic Insight May 2007 Issue 10.
Office of the Public Sector Standards Commissioner 2001, Public Sector Standards in Human Resource
Management.
Office of the Public Sector Standards Commissioner 2006, Public Interest Disclosure Act 2003 – Guidelines for
Internal Procedures in Public Authorities.
Ombudsman Western Australia May 2005, Guidelines for conducting administrative investigations.
Ombudsman Western Australia October 2006, Good Record Keeping.
Ombudsman Western Australia, undated, Guidelines and Information Sheets: for agencies.
RiskCover January 2007, Western Australian Government Risk Management Guidelines.
The Western Australian Integrity Coordinating Group 2006, Conflict of Interest Guidelines.
Western Australian Premier’s Circular 2004/04, Whole of Government Complaints Management Strategy.
ThE RighT agENCy MaNagEMENT ENviRONMENT
Crime and Misconduct Commission March 2005, Fraud and corruption control – guidelines for best practice.
Corruption and Crime Commission February 2007, Misconduct Handling Procedures in the Western Australian
Public Sector: Department for Community Development.
Corruption and Crime Commission March 2007, Misconduct Handling Procedures in the Western Australian
Public Sector: Department of Consumer and Employment Protection.
Independent Commission Against Corruption November 2002, The Do-It-Yourself Corruption Resistance Guide.
New South Wales Auditor-General 2006, Better Practice Guide – Fraud Control Improvement Kit.
The Government of Western Australia, Ministry of the Premier and Cabinet 1999, Better Management: Corporate
Governance Guidelines for the Western Australian Public Sector CEOs.
Western Australian Premier’s Circular 2005/02, Corruption Prevention.
gENERal REFERENCES
Anechiarico, F and Jacobs JB 1996, ‘The Pursuit of Absolute Integrity – how corruption control makes
government ineffective’.
Australian Public Sector Anti-Corruption Conference 2007, Corruption Prevention for Managers Workshop.
Bartos, Stephan 2004, Public Sector Governance Australia, CCH.
Committee of Sponsoring Organisations for the Treadway Commission 1992, Internal Control – integrated
framework, American Institute of Certified Public Accountants, Jersey City.
Corruption and Crime Commission 2007, Corruption, Integrity and the Public Sector, Speech by Commissioner
Kevin Hammond to IPAA 20 March 2007.
Corruption and Crime Commission 2007, Misconduct – Is that all there is! Address by Commissioner the Hon
Len Roberts-Smith RFD QC at Edith Cowan University, 30 October 2007.
Corruption and Crime Commission 2008, What does the Corruption and Crime Commission actually do? Speech
by Commissioner the Hon Len Roberts-Smith RFD QC to Western Australian Local Government Association,
22 February 2008.
25

Department of the Premier and Cabinet 2008, ‘Training on Accountable and Ethical Decision-Making in the
Western Australian Public Sector’, http://www.dpc.wa.gov.au.
Gillman, Stuart and Stout, Jeffrey 2005, Assessment Strategies and Practices for Integrity and Anti-Corruption
measures: Comparative Overview, OECD.
Johnston, Michael 2005, Syndromes of Corruption: Wealth, Power and Democracy.
Premier’s Circulars, Public Sector Management, Government of Western Australia, http://www.dpc.wa.gov.au/
psmd/pubs/pubs.html#legislation.
Rose – Ackerman, Susan 1999, Corruption in Government: Causes, Consequences and Reform.
Western Australia Department of the Premier and Cabinet, Administrative Instructions, http://www.dpc.wa.gov.
au/psmd/pubs/pubs.html#legislation.
USEFUl WEBSiTES
Australian Public Sector Anti-Corruption Conference 2009 www.apsacc.com.au
Corruption and Crime Commission
www.ccc.wa.gov.au
Crime and Misconduct Commission
www.cmc.qld.gov.au
Department of Local Government and Regional Development www.dlgrd.wa.gov.au
Department of the Premier and Cabinet
www.dpc.wa.gov.au
Equal Opportunity Commission
www.equalopportunity.wa.gov.au
Government of Western Australia
www.wa.gov.au
Independent Commission Against Corruption
www.icac.nsw.gov.au
The Integrity Coordinating Group
www.opssc.wa.gov.au/icg/
Office of the Auditor General for Western Australia
www.audit.wa.gov.au
Office of the Public Sector Standards Commissioner www.opssc.wa.gov.au
Ombudsman Western Australia
www.ombudsman.wa.gov.au
RiskCover - Insurance Commission of Western Australia www.riskcover.wa.gov.au
Standards Australia
www.standards.com.au
State Law Publisher
www.slp.wa.gov.au
State Supply Commission
www.ssc.wa.gov.au
State Records Office of Western Australia
www.sro.wa.gov.au
WESTERN aUSTRaliaN lEgiSlaTiON
Auditor General Act 2006
Corruption and Crime Commission Act 2003
Corporations (Western Australia) Act 1990
Criminal Code
Equal Opportunity Act 1984
Financial Management Act 2006
Freedom of Information Act 1992
Local Government Act 1995
Occupational Safety and Health Act 1984
Public Interest Disclosure Act 2003
Public Interest Disclosure Regulations 2003
Public Sector Management Act 1994
Public Sector Management (Breaches of Public Sector
Standards) Regulations 2005
State Records Act 2000
State Supply Commission Act 1991
26

NOTES
27

“
Integrity means earning and sustaining the public trust by
– Serving the public interest
– Using powers responsibly
– Acting with honesty and transparency
– Preventing and addressing improper conduct. ”
WA Integrity Coordinating Group 2005

ACKNOWLEDGMENTS
The Misconduct Resistance: An Integrated Governance Approach to Protecting Agency Integrity framework draws on the Corruption and Crime
Commission’s own experience; the work of other integrity bodies across Australia; risk management methodology; as well as ethics and
organisational development literature.
Special acknowledgement is given to the Independent Commission Against Corruption in NSW, the Crime and Misconduct Commission in
Qld, and the NSW Auditor General’s Office whose work in developing similar integrated corruption and fraud models has been drawn on
extensively.
ISBN : 978 0 9805050 4 7
This publication forms part of the Corruption and Crime Commission’s ‘Misconduct Resistance’ series, available from www.ccc.wa.gov.au.
Further information about the Commission can also be found on this website.
DiSCLAiMEr
This information does not constitute legal advice and the Corruption and Crime Commission accepts no liability for the accuracy of the
information; or for any act or omission done in reliance on the information provided, or for any consequences, whether direct or indirect, of
any such act or omission.
© 2008 Copyright in this work is held by the Corruption and Crime Commission. Division 3 of the Copyright Act 1968 (Commonwealth)
recognises that limited further use of this material can occur for the purposes of ‘fair dealing’, for example, study, research or criticism, etc.
Should you wish to make use of this material other than as permitted by the Copyright Act 1968, please write to the postal address below.
Postal Address PO Box 7667
Cloisters Square
PERTH WA 6850
Telephone (08) 9215 4888
1800 809 000 (toll free for callers outside metropolitan Perth)
Facsimile (08) 9215 4884
Email
Office Hours
info@ccc.wa.gov.au
8.30 am to 5.00 pm, Monday to Friday
Public responsibility concerns aside, misconduct is bad for business.

An IntegrAted governAnce ApproAch to protectIng Agency IntegrIty
HealtH CHeCk
MisConduCt ResistanCe:
an integRated goveRnanCe appRoaCH to pRoteCting agenCy integRity
The puRpoSe of ThiS healTh CheCk
The Misconduct Resistance Health Check is designed to assist Executive Management 1 to monitor
and review their agency’s misconduct resistance approach. Experience shows that agencies can have
difficulty implementing and maintaining misconduct resistance programmes, so this Health Check aims
to help agencies tackle these problems by examining staff perceptions about misconduct resistance in
their specific work area 2 . The purpose is to identify:
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work areas where elements of an agency’s misconduct resistance approach may need refreshing
or improving; and
elements of the misconduct resistance approach that may need attention across the entire
agency.
The questions used to assess staff perceptions are based on the 12 key elements that underpin the
Corruption and Crime Commission’s Misconduct Resistance: An Integrated Governance Approach to
Protecting Agency Integrity framework. The Health Check can be used as a strategy to support your
agency’s review and evaluation activities under the key element ‘The Right Review’.
Caution:
This Health Check is a quick and easy tool that can be used to measure staff
perceptions about your agency’s misconduct resistance approach. The results
are indicative only, and should not be relied on in isolation when evaluating your
agency’s performance. The Health Check does provide a useful indication of staff
beliefs about how effectively your agency’s misconduct resistance approach has
been implemented, and what action you can take to improve it.
1. Arrangements in agencies will vary. Your agency may delegate a person/committee to be responsible for implementing and monitoring your agency’s
misconduct resistance approach. In small agencies, your Executive Team or CEO may retain this responsibility.
2. Work area could refer to business unit, division etc.

WhaT iS MiSConduCT ReSiSTanCe?
Misconduct resistance refers to an agency’s ability to effectively resist and manage misconduct. It
relies on creating and maintaining the right agency culture, operational strategies and management
environment. These outcomes can be achieved by addressing the key elements which underpin
them. The outcomes and key elements operate interdependently and together they represent
the standards for measuring the adequacy and effectiveness of agency misconduct resistance
approaches.
The RiGhT aGenCy CulTuRe:
Agency culture values integrity and is intolerant of misconduct.
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The right values – Your agency’s communication, actions and decisions reflect its values and
public interest principles.
The right leadership – Leaders within your agency set an example of integrity with their own
behaviour, their communication and their responses to misconduct by others.
The right workplace behaviour – Your workplace culture encourages staff to accept personal
responsibility for behaving according to agency values and in the public interest.
The RiGhT aGenCy opeRaTional STRaTeGieS:
Agency policies and systems support the effective treatment of misconduct risks.
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The right policies – Your policy platform provides a solid foundation for establishing your
agency’s treatment environment and communicates your commitment, values and business
practices for misconduct resistance.
The right risks – Misconduct risk identification and assessment are part of the wider corporate
risk management planning process and include all of your agency’s functions and operational
areas.
The right treatment – Your misconduct treatment programme is commensurate with the level
and nature of risk your agency faces, is comprehensive and adequately resourced, and is
subject to ongoing monitoring and review.
The right understanding – Your staff and managers have a common understanding of what
misconduct is. They embrace your agency’s stand on misconduct, as stated in the agency’s
policy and treatment programme, and know how to respond should they become aware of
misconduct.
The RiGhT aGenCy ManaGeMenT enviRonMenT:
Misconduct resistance is an integrated and established component of agency life.
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The right priority – Misconduct resistance is given high level ownership and central oversight.
The right business practices – Misconduct resistance is a fundamental part of your agency’s
strategic, tactical and operational business activities – it’s the way you do business.
The right mindset – Misconduct consciousness is a fundamental part of work practices for
everyone in your agency, with responsibilities structured from the top down – it’s a way of
thinking.
The right review – Review and evaluation processes ensure your agency’s misconduct
resistance approach remains relevant and effective in achieving stated objectives.
The right communication – Your agency’s misconduct resistance strategies are consolidated
into a documented approach that is widely communicated.
2

hoW To uSe The healTh CheCk
The misconduct resistance questionnaire consists of 12 short and simple questions for staff to answer. It should
take less than five minutes to complete and all responses are entirely anonymous. The questionnaire is located on
page 5.
Depending on the size of your agency, you can survey all or a percentage of your staff. Surveying 10 – 20% of
your total staff is sufficient, but conducting a higher percentage of surveys is likely to lead to richer data.
The Health Check process is quick and easy enough for broad use within your agency, and processing and
analysis are straightforward and inexpensive.
Your project manager (or appointed staff member) is responsible for distributing and collecting the misconduct
resistance questionnaire. Online survey tools could be useful for surveying large, dispersed agencies, but we
discourage using email in this case because it is very important that the responses be kept anonymous.
As responses are received, your project manager will need to enter them into a report generator spreadsheet that
uses colour coding to highlight the work areas and/or misconduct resistance aspects that need attention.
The report generator is available for download from our website at:
www.ccc.wa.gov.au/misconduct _ resistance.php
Please note that:
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You cannot save data to the online version of the generator, so please ensure you save a copy to your
own system.
The report generator uses an underlying formula to generate the dashboard results which cannot be
manually calculated.
hoW To inTeRpReT The RepoRT
The Health Check provides a broad overview of staff perceptions about your agency’s current misconduct
resistance approach. Any problem areas highlighted by the report generator will require further investigation to
determine the exact nature of the concern, and whether action is required.
Work areas or aspects of your agency’s misconduct resistance approach may be highlighted for action by
the report. These could reflect systemic problems within your agency, or areas that could benefit from staff
refreshment or training. Either way, action is needed to ensure that any potential problems are clarified and
appropriate remedial action is taken.
The Commission’s Misconduct Resistance Integration Guide can be used as a reference for a range of possible
actions and ideas to build capacity.
The Health Check should be used as a guide to improve your agency’s misconduct resistance strategies and
approach. In the example on the next page, the report suggests that:
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Staff in Work Area 4 do not perceive the agency as having effective misconduct resistance strategies in most
areas.
Staff in Work Areas 2 and 3 have mixed perceptions about the agency misconduct resistance approach across
a number of areas.
The Right Policies and The Right Priority key elements need to be reviewed across the whole organisation.
The Right Workplace Behaviour, The Right Risks and The Right Treatment key elements show signs of
weakening effectiveness and would benefit from a review.
Your Health Check results should be reported to your Executive Committee/CEO, outlining areas of concern and
any recommendations.
3

The healTh CheCk RepoRT
This report identifies areas where staff perceptions or awareness of your agency’s misconduct resistance approach
indicate that there may be a problem. Below is an example of a completed report.
key: Good Performance green Action Required orange Urgent Action Required red
Misconduct Resistance
Key Element
The Right Values
Overall
Results
Results for Individual Work Areas
Work Area 1 Work Area 2 Work Area 3 Work Area 4
green green green green orange
The Right Leadership
green green green green green
The Right Workplace Behaviour
orange green orange green red
The Right Policies
red orange red red red
The Right Risks
orange green green orange red
The Right Treatment
orange green orange green red
The Right Understanding
green orange green green green
The Right Priority
red green red orange red
The Right Business Practices
green green green green orange
The Right Mindset
green green green green green
The Right Review
green green orange orange green
The Right Communication
green orange green orange orange
Overall Work Area Results
green green orange orange red
4

An IntegrAted governAnce ApproAch to protectIng Agency IntegrIty
MiSConduCT ReSiSTanCe QueSTionnaiRe
Misconduct generally occurs when a public officer abuses their authority for personal gain or to cause detriment
to another person, or acts contrary to the public interest. Examples include misuse of computers, bribery,
harassment and fraud.
Please put a tick in the most appropriate box
1. My agency consistently communicates the importance of acting
in the public interest.
Strongly
Disagree
Disagree Agree Strongly
Agree
2. Our senior executives and managers act with integrity.
3. Most staff in my workplace know they should act in accordance
with our agency’s values.
4. My agency’s policies help us to deal with the misconduct issues
that we face.
5. The misconduct risks we face are identified by ongoing
assessment of the activities in my work area.
6. My agency has effective strategies to manage misconduct risks
that arise in the workplace.
7. Most staff in my work area know what misconduct is and
understand their responsibility to report it.
8. My agency treats dealing with misconduct as a top agency
priority.
9. We consider preventing and controlling misconduct in all of our
work activities (e.g. planning, service delivery etc.).
10. Acting with integrity is the way we do things in our agency.
11. My agency reviews the effectiveness of our plans and strategies
for preventing and controlling misconduct.
12. I believe our customers/contractors understand my agency’s no
tolerance approach to dishonest and unethical dealings.
Do you have any general comments you would like to make about the integrity and misconduct resistance
environment in your work area?
......................................................................................................................................................................................................................................................................
......................................................................................................................................................................................................................................................................
Name of your work area (NOT YOUR NAME—your response is anonymous): ................................................................
Thank you for your feedback, please send your completed form to: ..............................................................................
5

Who Should Take ReSponSibiliTy foR The healTh CheCk?
Management is responsible for developing, implementing and maintaining effective misconduct
resistance, but all staff have a role in integrating and monitoring misconduct resistance strategies.
If you are part of your agency’s management team, you need to ensure that your agency’s misconduct
resistance approach is appropriately applied across your entire agency. You should consider tailoring
your use of the Health Check to suit your agency’s specific needs. You should look at:
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the literacy and cultural profile of your staff;
the frequency of using the Health Check;
whether the Health Check is used for your entire agency, or applied in sections over a period of
time;
how you will progress recommendations for improvement, including any further investigation or
assessment of areas identified as a potential concern; and
how you will monitor the implementation of recommended improvements.
You may choose to appoint a project manager to help apply the Health Check within your agency.
When top management fails to send a clear message about the principles and values of
the agency, the default message just might be something like ‘who cares?’.
aCknoWledGMenTS
The Corruption and Crime Commission is grateful for the support of the New South Wales Auditor-General’s Office in allowing the adaptation
of their Better Practice Guide: Fraud Control Improvement Kit in line with the Commission’s misconduct resistance framework.
diSClaiMeR
This information does not constitute legal advice and the Corruption and Crime Commission accepts no liability for the accuracy of the
information, or for any act or omission done in reliance on the information provided, or for any consequences, whether direct or indirect, of
any such act or omission.
CopyRiGhT
© 2008 Copyright in this work is held by the Corruption and Crime Commission. Division 3 of the Copyright Act 1968 (Commonwealth)
recognises that limited further use of this material can occur for the purposes of ‘fair dealing’, for example, study, research or criticism etc.
Should you wish to make use of this material other than as permitted by the Copyright Act 1968, please write to the postal address below.
iSbn : 978 0 9805050 5 4
This publication forms part of the Corruption and Crime Commission’s ‘Misconduct Resistance’ series, available from www.ccc.wa.gov.au.
Further information about the Commission can also be found on this website.
CoRRupTion and CRiMe CoMMiSSion
Postal Address PO Box 7667
Cloisters Square
PERTH WA 6850
Telephone (08) 9215 4888
1800 809 000 (toll free for callers outside metropolitan Perth)
Facsimile (08) 9215 4884
Email
info@ccc.wa.gov.au
Office Hours
8.30 am to 5.00 pm, Monday to Friday
6

An IntegrAted governAnce ApproAch to protectIng Agency IntegrIty
AGENCY IMPLEMENTATION STATUS
the right agency ManageMent environMent
The right
mindset
The right
business
practices
The right
review
The right
communication
10
8
6
4
2
0
The right
values
the right agency culture
The right
leadership
The right
workplace
behaviour
The right
policies
The right
priority
The right
understanding
the right agency operational strategies
The right
treatment
The right
risks
Based on a 1 – 10 scale (10 = Best practice)
explanation: The wheel map has 12 spokes which reflect the key elements of the misconduct resistance framework.
It is a simple tool to visually capture the status of your agency’s approach to integrating misconduct resistance across
the agency. This visual snapshot can help you identify areas needing attention or provide a benchmark to monitor your
agency’s progress over time.
In the example above, the map indicates that the agency is performing well against the key elements relating to values,
leadership and workplace behaviour, scoring between 7 and 8 out of 10. It also shows that the agency’s policies, misconduct
risk assessment and mindset require further attention, with scores between 2 and 4 out of 10.
acknowledgeMent
This tool for mapping the implementation status of an agency’s misconduct resistance approach has been adapted from a model presented at the Australian Public Sector
Anti-Corruption Conference 2007.
disclaiMer
This information does not constitute legal advice and the Corruption and Crime Commission accepts no liability for the accuracy of the information, or for any act or omission
done in reliance on the information provided, or for any consequences, whether direct or indirect, of any such act or omission.
© 2008 Corruption and Crime Commission.
This publication forms part of the Corruption and Crime Commission’s ‘Misconduct Resistance’ series, available from www.ccc.wa.gov.au.
Further information about the Commission can also be found on this website.

An IntegrAted governAnce ApproAch to protectIng Agency IntegrIty
MAPPING YOUr AGENCY’S PrOGrESS
The right
communication
10
The right
values
the right agency culture
the right agency ManageMent environMent
The right
mindset
The right
business
practices
The right
review
8
6
4
2
0
The right
leadership
The right
workplace
behaviour
The right
policies
The right
priority
The right
understanding
The right
treatment
The right
risks
the right agency operational strategies
Based on a 1 – 10 scale (10 = Best practice)
how to use: There is no set method for assessing your performance against the key elements, and you don’t need to
use the same method for each element. For example, you can use a staff survey to measure workplace culture and an
independent audit to review your treatment programme. However, it is helpful to use consistent review methods when you
use the map to benchmark and compare your agency’s performance over time. The Misconduct Resistance Integration
Guide is one of the tools you can use for assessing your agency’s performance.
Evaluate your agency’s performance against all 12 key elements, assigning a score from 1 to 10 to each element.
Mark the scores on the appropriate wheel spokes, joining them with one continuous line, then shade the inside of the
area you have drawn. This shaded area represents the current status of your agency’s progress across the misconduct
resistance framework.
Refer to the completed Agency Implementation Status diagram as an example.

Monitoring, evaluating and benchmarking performance & progress as part of a continuous improvement cycle
‘Agency policies and systems support the effective treatment of misconduct risks’
An IntegrAted governAnce ApproAch to protectIng Agency IntegrIty
objective
To recognise misconduct as a significant business risk and integrate misconduct resistance with your strategic planning,
corporate governance and operational systems in a way that is effective, and produces measurable performance benefits.
The right mindset
The right review
THE RIGHT AGENCY MANAGEMENT ENVIRONMENT
‘Misconduct resistance is an integrated and established component of agency life’
The right business
practices
The right
communication
The right values
Developing ideas to build capacity in areas of need
Using Focus Questions & Signs of Success
IntegratIng
MIsconduct
resIstance
‘Agency culture values integrity and is intolerant of misconduct’
The right leadership
THE RIGHT AGENCY CULTURE
The right workplace
behaviour
The right policies
The right priority
The right
understanding
The right treatment
THE RIGHT AGENCY OPERATIONAL STRATEGIES
The right risks
Misconduct generally occurs when a public officer abuses authority for personal gain or
to cause detriment to another person, or acts contrary to the public interest.
DISCLAIMER: This information does not constitute legal advice and the Corruption and Crime Commission accepts no liability for the accuracy of the information, or for any act or omission done in reliance on the information provided, or for any
consequences, whether direct or indirect, of any such act or omission.
© 2008 Corruption and Crime Commission.
This publication forms part of the Corruption and Crime Commission’s ‘Misconduct Resistance’ series, available from www.ccc.wa.gov.au. Further information about the Commission can also be found on this website.