Organisations develop policies, procedures and administrative systems to support their efficient management and good governance. Policy frameworks express the principles that will govern most aspects of an organisation's work and decisions, while an organisation's procedures and systems give effect to those rules and enable them to be complied with.
Policies, procedures and systems work best when they are applied to events that occur frequently in the work of an organisation. When they work as they should, policies, procedures and systems enable like situations to be treated alike, individuals to be dealt with equitably and decisions to be made in an accountable way and on their merits.
The role of policy frameworks in preventing corruption
Like a code of conduct, a policy framework is an important element in an effective corruption prevention strategy. In a public sector organisation a policy framework can be used to give effect to public sector values and ethics. For example, accountability is implemented through policies and procedures that require record-keeping and reporting. Merit-based decision-making is embodied in policies for recruitment and selection, purchasing and contracting.
Policies also establish minimum standards of conduct and controls to enforce the agency's values, especially in specific corruption risk areas like conflicts of interest or the receipt of gifts and benefits.
Policy quality and effectiveness
To achieve their purpose, policies and procedures must be understood by those affected by them, and workable. That means being clearly expressed, procedurally unambiguous and suitable for the circumstances they are expected to meet. If people are uncertain about how or whether a policy applies to them they are less likely to comply with it.
A common reason for non-compliance with policies is that the agency has not provided an easy way to comply. Many policies need a step-by-step procedure to ensure that staff know exactly what steps they need to take to comply with a policy. A related problem is that policies can become out of date especially when, for example, an agency's structure changes or it acquires new functions. Having too many policies can also be a problem.
|Case study 1: Ambiguous policies|
|In 2008 the ICAC investigated allegations of gifts given to a local council planning official to encourage favourable assessment of planning applications. The gifts comprised $1,000 cash and jewellery with a retail value of more than $800. The council's code of conduct prohibited employees accepting anything from someone who had an application before the council for determination. It also prohibited acceptance of gifts with a retail value over $50. In this instance these provisions created ambiguity because although the official was in the process of assessing an application, she thought the jewellery was worth less than $50. The ICAC recommended changes to the council's gifts and benefits policy that included removing monetary thresholds for accepting gifts, as they can create an impression that the policy permits employees to accept gifts below the threshold regardless of the circumstances.|
|Case study 2: Absence of policies|
|In 1998 the ICAC reported an investigation of corrupt conduct at a number of council tips. It was found that the waste depot staff were in the habit of collecting materials not suited to deposit at the waste depot, such as green waste, and selling it for their own profit. A similar practice arose with items dumped at the tip that were still usable. They were known by staff as "loot" and resold by them. It appeared that, officially, material became the property of the council once it passed over the weighbridge but there was no policy to govern the removal of material from the waste depot. Recycling is a potentially profitable business and revenue from recycling should go to the owner of the material recycled – in this case the council. The ICAC recommended that policies and procedures be introduced to ensure any benefits associated with the retrieval of materials accrue to the ratepayers rather than to staff.|
Frequently asked questions
How can I make sure that all staff understand and accept the policies that apply to them?
|Requiring staff to formally acknowledge that they have read and accepted specific policies is a useful safeguard, but is not in itself sufficient. Managers must take every relevant opportunity to instil awareness and acceptance of the policies and procedures in their staff, including in their own work practices.|
What is the best way to keep policies up to date?
The simple way to keep policies current is to make sure that they are part of a searchable policy library that is retained electronically and that each policy is marked with a date for review. Every two years is a common review period but many policies can be reviewed less frequently as long as they are actively monitored and reviewed. Certain events should also trigger the review of policies, such as the merger of an agency or changes in its functions or legislative framework.
A review should include consultation with managers and other staff about how well the policy has been working as well as updating to take account of agency changes. It is useful to nominate an 'owner' for each policy from senior management and have the process of updating and amending policies overseen by the agency's human resources staff.
I work in a small agency, do we still need a lot of policies?
|Make sure that the agency's policy framework covers all of the risks identified in your corruption risk assessment as well as the agency's legal obligations. Any other policies will depend on the nature and functions of the agency. Over-regulation in an agency can be as much of a corruption risk as inadequate regulation.|
How can we encourage our staff to read long policy documents?
Ideally your policy documents should not be long. Policies should only contain statements of principle. Details about how to comply with the policy really belong in a procedure document and background information about the reasons for the policy should be communicated in a staff meeting or induction session.
All policies should be accessible to all staff (for example on the agency's intranet) however it may be that not all of your staff need to receive full length versions of every policy. As a communication tool, try reducing the policy to a statement that summarises the top five things that everyone should know. Other information about the policy that managers or supervisors may need can be provided to them in other formats.
Providing a training session in the new procedures attached to the policy can be an effective way to ensure the staff read them.
Linking the introduction of a policy to an event such as a change in the organisation's work, a merger or the development of new operating systems can be an opportunity for staff to become familiar with a policy.
If the policy affects people outside the agency, consider producing a version for them that contains the information that they need.
Relevant ICAC investigations
- Standards Australia, www.standards.com.au
Related topics on the ICAC website