Supervision of staff
Today many public sector employees work with less direct supervision and more autonomy, which means supervisors have critical roles to play in minimising the risks of corruption in their workplaces.
Employees are strongly influenced in their own behaviour by the way their immediate supervisors behave1. Consequently, supervisors are in a position to either encourage or minimise corrupt conduct.
Their role also means supervisors are well-placed to detect and report instances of misconduct or corruption of which they become aware.
The improper supervision of employees can constitute corrupt conduct as defined by the Independent Commission Against Corruption Act 1988.
A risk assessment of the supervision of staff in a public sector agency is likely to identify some or all of the following corruption risks:
- Failing to check work records such as employee timesheets, leave applications and travel approvals.
- Improperly promoting, engaging or advantaging employees for personal reasons.
- Unfairly disadvantaging, bullying or discriminating against employees for personal reasons.
- Taking detrimental action against employees who report corruption or misconduct.
- Concealing the corrupt conduct of subordinate employees.
Managing corruption risks
As a minimum your agency should:
- Ensure its organisational structure and reporting lines make it clear who employees report to, and are supervised by, and do not leave any employee unsupervised.
- Introduce policy and procedures for the supervision of employees that contain elements listed in the Policy Development Model.
- Include in the policy sanctions for any breach of the policy and procedures.
- Review the policy every two years.
- Train and support all new supervisors in the supervisory responsibilities of their roles, especially in relation to policies on anti-discrimination, employee grievances, bullying and managing performance.
- Ensure that supervisors have clear direction on reporting corruption and dealing with corruption risks.
- Give employees access to processes for reporting misconduct that provide alternatives to reporting through their supervisor, who may be involved in corrupt activity.
- Make sure position descriptions for supervisors set out the supervisory responsibilities of the role.
- Assess the performance of supervisory responsibilities in performance reviews.
Risk management strategies
Following your risk assessment of employee supervision, you should consider these risk management strategies:
- Ensuring the workload of supervisors is not so great that they cannot properly monitor the work being done.
- Locating supervisors so that they are physically able to have sufficient contact with employees to know how work is being done.
- Giving supervisors enough access to the work of employees to enable adequate monitoring of work being done.
- Ensuring enough supervisors have skills and knowledge of the work required to be done to avoid the agency becoming dependent on any individual employee.
- Rotating staff to ensure that supervisory relationships do not become too close or interdependent.
- Conducting additional supervision for employees in roles that are exposed to greater corruption risks.
- Conducting anonymous staff surveys from time to time to assess workplace satisfaction and culture.
|Case study 1|
In 1999 the ICAC reported on an investigation that found the executive officer of a regional development board had engaged in corrupt conduct. He had illegally obtained public funds and used them for the benefit of himself and his family.
The man was a long-term middle-ranking public official on a modest salary, working in a location away from the head office of his organisation. Reporting lines were ambiguous, or not properly understood or applied by the relevant managers. He reported to a regional office but on an ad hoc, mostly verbal basis, which was not adequately recorded on files. This lack of supervision meant that he was able to exercise a high level of discretion.
Another risk factor identified in the investigation was the apparent lack of direction by senior management and the lack of performance management. Remote officials were expected to define, create and manage their own work program with minimal reference to head office and little or no supervision.
|Case study 2|
In 2003 the ICAC found that an employee had taken without permission more than 2,000 zoological specimens, many of significant rarity and scientific value, from a major natural history museum.
The employee had been appointed in a temporary capacity to a position that largely involved controlling insect pests in the collections. At the time he was operating a commercial venture involving taxidermy and osteology reproduction. He also had his own, quite extensive, collection of zoological specimens.
In the course of his pest control duties, he was given unrestricted and unsupervised access to the collections on display and in storage, as well as to museum vehicles which he used to take many of the specimens home without authority.
He was nominally supervised in this work by a manager who did not monitor his day-to-day activities. At the same time he did other work, such as taxidermy and specimen preparation for other museum employees, as well as contract pest control work for external agencies for which the museum was paid. He described the situation as, '….one person is supervising, another signs my daily sheets, another signs my car sheets'.
The confusion in his reporting arrangements was exacerbated by museum employees or groups outside the museum who approached him directly with work requests, rather than through a supervisor who could manage and keep track of the workflow.
Confused reporting responsibility can provide opportunities for corrupt behaviour and makes it more difficult to detect such behaviour when it occurs.
The ICAC recommended the museum ensure that all employees have a direct supervisor who is responsible for functions such as assigning and monitoring work, approving leave and performance management.
Frequently asked questions
What is the proper response for an employee who is directed by a supervisor to do something that is prohibited by the Code of Conduct?
|This can be a very difficult situation for employees, especially if they feel loyal to a supervisor. Organisations can provide avenues for employees to find out whether something is improper, or not, such as an advice line, an easily accessible written policy or procedure, or confidential human resources support. There should also be a confidential way for reporting suspected misconduct or asking for advice about how to proceed.|
What if the agency doesn't have enough supervisors to check work closely or employees are working in remote locations?
This situation means working smarter and designing work arrangements to reduce opportunities for misconduct. External advice that brings fresh eyes to the problem may be needed in such a situation.
Regular and random checks, instead of constant oversight, can be effective in many work functions. It may also mean reorienting the way the agency's corruption prevention strategy is targeted. For example, making sure all employees understand the consequences of acting corruptly may provide more of a deterrent to corrupt conduct than close watching by supervisors. Electronic systems or document management systems with audit trails and access restrictions can take on some aspects of supervision. Ensuring that all employees are in the habit of recording decisions and knowing that these decisions will be checked at some point, even if not every day, can also be useful in this situation.
Regular contact by telephone, email and routine – or random - visits may substitute for aspects of supervision in some situations. However, if activities that have been assessed as highly vulnerable to corruption are not being adequately supervised it is important for senior management to be made aware so that alternative work monitoring arrangements can be made or resources prioritised.
How can employees whose work requires exercising discretion be effectively supervised?
|Many public sector roles are required to exercise considerable discretion, often with minimal supervision. Regulatory and law enforcement roles are the most obvious examples. If direct supervision is not possible, other accountability mechanisms can be used. The most fundamental is the need for accurate recordkeeping. Systems that automatically generate a record of decisions or approvals – such as electronic sign-offs or dated video records – can be used in these situations. Regular reviews of the decisions made by individuals can also indicate whether they have been made properly. Other performance data may be available such as complaints about the work of employees or appeals from their decisions.|
- Identifying and managing conflicts of interest in the public sector (2009 brochure), ICAC, Sydney, 2009
- Tips from the top: Senior NSW public sector managers discuss the challenges of preventing corruption, ICAC, Sydney, 1999.
- Personnel Handbook, NSW Department of Premier and Cabinet, last updated July 2007
- Operation Bart: Investigation of allegations against Police in relation to the shutter allocation system, The Ombudsman, Victoria, May 1998.
Relevant ICAC investigation reports
- Public Employment Office - evaluation of the position of Director-General, Department of Community Services (November 1996)
Related topics on the ICAC website
1. Seligson, Amber Levanon and Choi, Laurie, Critical Elements of an Organisational Ethical Culture: Research Report, Ethics Resource Center, Washington DC, 2006.