Corruption prevention policy

A Corruption Prevention Policy is used to communicate how an organisation will manage the issues of corrupt conduct and corruption prevention.  There is no standard model for a Corruption Prevention Policy but it would normally include the following elements:

Administrative information

  • Implementation date
  • Proposed review date: (we recommend every two years)
  • Contact officer: (the person to whom questions about the Policy and procedures should be directed)
  • Responsible division: (name of division responsible for managing and reviewing the policy)
  • Relevant legislation: where applicable
  • Related policies/documents: e.g. code of conduct, risk management plan, corporate plan, audit policy, information management policy, financial management policy. 
  • Date of last review

Introduction

  • Relationship of the Corruption Prevention Policy to other overarching plans:
    Explain how the Policy fits into the organisation's governance structure e.g. corporate plan, business plan, risk management plan, audit plan
  • Application of the Policy:
    Explain to whom the Policy applies, e.g. to all levels of staff, contractors, clients, stakeholders (such as sponsors, grant recipients, ...), consultants, volunteers and boards.

Definition of corruption

Corrupt conduct by a public official commonly involves the dishonest or preferential use of power or position, a breach of public trust or the misuse of information or material acquired in the course of official functions. (For a full definition of corruption as it applies to the NSW public sector context, refer to sections 8 and 9 of the ICAC Act.)

Statement of policy principles

A statement about the agency's policy regarding corruption and its intention to prosecute offenders. For example:

  • (Name of agency) will not tolerate corrupt conduct by employees of the organisation or by any stakeholder, client, consultant or volunteer.
  • (Name of agency) is committed to: ( for example)
    • minimising the opportunities for corrupt conduct by employees, members of the public, contractors and clients. 
    • detecting, investigating and disciplining/prosecuting corrupt conduct
    • reporting corrupt conduct to ICAC and where appropriate to NSW Police
    • taking a risk management approach to the identification and management of corruption risks.

Responsibilities

The Policy should state the responsibilities of all staff in relation to corruption prevention, for example:

  • The CEO has ultimate responsibility for managing corruption risks in the agency.
  • The executive and senior management is responsible for ensuring that the agency's Corruption Prevention Plan is fully and effectively implemented.
  • Line management is responsible for understanding and implementing the code of conduct and relevant agency policies.
  • Staff are responsible for reporting corrupt conduct through the internal reporting framework or directly to the ICAC.
  • The CEO is obliged, under section 11 of the ICAC Act, to report any matter that he or she reasonably suspects involves or may involve corrupt conduct to the ICAC.
  • Staff are responsible for behaving according to the code of conduct and agency policy.

Communication

How the Policy will be communicated and made available to staff and relevant others, e.g. contractors / volunteers / clients / stakeholders etc.

Corruption Prevention Plan

The Policy should state that the agency will develop and resource a Corruption Prevention Plan to implement the Policy.

Review date

The Policy should be reviewed regularly and should clearly state the date for scheduled review and the senior management position responsible for conducting the review.

Examples

Many agencies publish their corruption prevention policy online. These can easily be identified in an online search.

Resources

AS 8000 Premium (Set) 2004: Premium Corporate Governance Set, Standards Australia, Sydney, March 2004.