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Corruption prevention plan

What is a Corruption Prevention Plan?

The purpose of a Corruption Prevention Plan is to put your Corruption Prevention Policy into action. It is a living document that shows how the Policy is being implemented over time. It can also be used to monitor corruption prevention activities in the agency.

There is no standard format for a Corruption Prevention Plan. Several models are available [see Resources] and a Sample Corruption Prevention Plan is provided below. It is important to choose an approach that works well in your agency. Whatever the format any Corruption Prevention Plan should address the same elements or topics and clearly show:

the corruption prevention outcomes your agency wants to achieve
what your agency is already doing to achieve those outcomes, and
what else your agency needs to do to achieve them.

Developing a Corruption Prevention Plan

1. Outcomes: what the plan will achieve

In this section, clearly state the intended outcomes of the Plan. Corruption prevention outcomes are usually ongoing goals which may not change very much over time. Many of them overlap with the agency's governance frameworks, legal obligations and operational or professional standards. Others apply specifically to the agency's ability to detect and respond to corruption.

The Sample Corruption Prevention Plan provides examples of outcomes, including:

Corruption prevention is integrated into all other corporate planning activities, e.g. business plan, corporate plan, audit plan
The agency has published standards and values that are appropriate to its role and function
Executive, senior managers and line managers lead by example and model the agency's standards and values
The agency's IT systems are robust, comply with all applicable standards and are used to address corruption risks.

2. Current activities: what is happening in the agency to achieve these outcomes.

Relevant activities will include any of the agency's policies, programs, protocols, training, communication and other mechanisms that support the outcomes identified. Ideally, the Plan should explain briefly how they work to produce the outcome.

3. Planned action: what else needs to be done

In this section of the Plan you can set an agenda for work to be done to fill the gaps between the desired outcomes and the organisation's current activities. Many of these gaps will be identified in your corruption risk assessment. The implementation of new measures can be tracked in the Plan or in a separate implementation plan.

Implementation, monitoring and review

A Corruption Prevention Plan will not succeed without the active support of the head of the agency and senior management, particularly in its implementation and ongoing monitoring. [See Implementation Checklist in Tools].

The Australian Standard on Fraud and Corruption Control (AS 8001-2008) advises reviewing the corruption prevention plan at least every two years. The actual date for review should be synchronised with the review of the Corruption Prevention Policy and other dates in the business planning, risk assessment and internal audit cycles. Include in the review lessons learned by the agency from instances of corrupt conduct and 'near misses' as well as feedback from all management levels about how well prevention initiatives in the Plan are working.

Frequently asked questions

How much detail should appear in a Corruption Prevention Plan?
The size and structure of the Plan should suit the needs of your agency. The most important thing is that it covers all the essential elements needed to manage the agency's corruption risks. The Plan can be relatively brief and refer to other documents such as a corruption risk management plan, internal audit plan or relevant policies and corporate planning documents, as attachments or links. Alternatively, it can incorporate all relevant documents.
Who should be responsible for developing and implementing the Plan?
This depends on the size and structure of your organisation. In small agencies the CEO may develop the Plan personally. In very large ones it could be drafted by the audit manager reporting to the head of the organisation. Some local councils have their Corruption Prevention Plan noted at a full council meeting and agencies with boards usually have the Plan approved by the board and reviewed by the board's audit and risk committee. Regardless of who actually develops the Plan it should always be done under the auspices of the senior management team and launched by the head of the organisation. Implementation can be made the responsibility of a working group or committee made up of managers with relevant skills. Make sure they have the resources and authority they need to be effective.
Why should the Plan be reviewed every two years?
Any agency's corruption risks will change over time and a Corruption Prevention Plan should address the real risks that it faces. Consider setting some triggers for a review that relate to significant events affecting agency operations or structure. Developments in operational best practice, organisational changes such as restructures, major outsourcing of operations and acquiring new functions can all require the Corruption Prevention Plan to be reviewed.
What should be considered in a regular review of the Plan?
Formal instruments for monitoring the plan can be used (see NSW Audit Office Better Practice Guides and LGMA Governance Health Check) and you can build a review mechanism into the Plan. Link the review to corporate planning cycles to make sure that it captures any strategic issues that have implications for corruption prevention. Set up some simple but systematic ways to get feedback from line managers about how the initiatives in the plan are working. Regular events such as quarterly managers meetings, planning retreats, even performance reviews can all be used. Staff perspectives can also be obtained by surveys and from exit interviews.

Resources

Publications

AS 8000 Premium (Set) 2004: Premium Corporate Governance Set
AS 8001-2008 Fraud and Corruption Control, Standards Australia, Sydney, 2008

Better Practice Guide: Fraud Control, Audit Office of NSW, Sydney, 1994
Fraud Control: Current Progress and Future Directions, Audit Office of NSW, Sydney, 2005.