The consistent and overwhelming message from the ICAC's investigations and research is that corruption prevention strategies require thought, effort and commitment from the top of the organisation.

The way that an agency's senior executives, middle managers and supervisors behave can influence the conduct of individual members of staff and helps to form an agency's culture.  Managers can show leadership by modelling appropriate behaviour and ensuring that their direct reports do likewise.

The authority of managers is needed to support and endorse specific corruption prevention initiatives and to ensure that existing systems operate effectively. 

How can managers show leadership in preventing corruption?

Model the behaviour expected of staff

When supervisors and senior executives are seen to encourage and emphasise honest behaviour in the workplace and treat all staff fairly and equally, employees are more likely to perceive the workplace as honest and follow suit. The perception that managers are honest is associated with NSW public sector employees having positive perceptions about colleagues, the job and the workplace as a whole.1

Staff notice the behaviours that managers reward and the behaviours that result in penalties, and this reinforces their learned behaviour. In addition, the behaviour of managers provides an example of the way in which organisational systems should be implemented. For example, if a manager regards record-keeping as a waste of time, his staff will learn that it is not necessary to keep good records in his division. A manager who takes shortcuts and doesn't always comply with agency policy will find that her staff will come to follow her example. 

Managers have a responsibility to comply with organisational policies and procedures themselves, and also to act openly, honestly and consistently with staff. Managers should be seen to act honestly and to practice what they preach, encouraging and emphasising honest behaviour in the workplace, and treating all staff fairly and equally.

Building trust in this way is particularly important for corruption prevention initiatives that could be perceived as an attack on staff, or as an indication that managers do not trust staff.

Strategies for building trust include consistent and clear communication, communication about ethics and corruption prevention that comes from the top of the organisation, consistent management throughout the organisation and managing staff expectations from the time of their employment, and through any organisational changes that follow.

Use organisational systems effectively

It is up to managers to ensure that appropriate policies and procedures exist and that they are adequate, to enforce the policies and procedures, and to monitor their effectiveness. Managers and executives have a responsibility to incorporate corruption prevention into existing governance processes such as strategic planning and risk management and ensure the organisation stays true to its stated values.

Managers need to endorse these processes and allocate appropriate resources to ensure that they are implemented properly. For managers in regional areas this will often involve implementing corruption prevention initiatives that were developed centrally.

Take effective action against corrupt conduct

The ability of an organisation to appropriately penalise corruption is an important prevention tool. Managers should take appropriate action against corruption and should be seen to take such action when wrongdoing is reported and against those who have acted dishonestly.  Lack of action by an agency, or the perception that no action has been taken, can send a message to staff that nothing will be done when corrupt behaviour occurs.

Taking effective action includes:

  • Following correct procedure: Following proper procedures and having a regard for principles such as natural justice is vitally important when investigating or taking action against someone regarding corrupt behaviour. This will minimise the possibility of an incorrect action being taken, or of a decision being challenged.
  • Publicising action and outcomes: Being seen to punish perpetrators is important for setting the tone of what is acceptable behaviour in organisations. In addition, making staff aware of the repercussions of corrupt conduct is a useful part of the education process.
  • Communicating with staff: Managers have a role in communicating information about policies, procedures and organisational systems. However they have an equally, or possibly even more important, role in communicating the values and culture of the organisation. This can be done in formal ways such as through induction programs, or it can be informally through general discussions or the provision of advice. Managers need to ensure that this communication is clear and consistent.

Case studies

 Case study 1: Supporting staff

The ICAC received a report of an unsolicited gift to an employee of a state infrastructure agency who provided advice on a complex matter while on a site visit to a rural location.  The advice was given within his official capacity and without favouritism to the property owner. 

On returning home the employee found the property owner had left an envelope containing a sum of money and some bottles of beer and wine. The employee notified his supervisor and asked for assistance.  He then rang the giver to explain why he could not accept the gift. As the landowner was to be away for some time the gift was held for safe-keeping by the agency and senior management was notified. 

In addition to reporting to the ICAC , as required under section 11 of the ICAC Act, the agency proposed taking the following action: 

  • the CEO would write to the employee commending his action
  • the employee and a third person would return the gift to the giver
  • the incident would be written up by the CEO in the staff newsletter as an example of good practice and used by the Compliance and Risk Manager in training on fraud and corruption awareness.