Australia’s Commonwealth Integrity Maturity Framework (the Framework) provides accessible information to support Commonwealth agencies to design, implement and review the effectiveness of their integrity frameworks so that they are tailored to their risk profiles, size and contexts.
The Framework has been developed by the National Anti-Corruption Commission (NACC), which seeks to deter, detect and prevent serious corrupt conduct involving Commonwealth public officials.
The Framework is a set of 8 Integrity Principles, that are derived from the key Commonwealth integrity laws, policies and procedures. Each principle is accompanied by a 4-level maturity scale. This article provides a summary of the principles and maturity indicators, and highlights some of the key implications such as how the framework can help government agencies to better tackle fraud and corruption.
Principle 1: Values and Code of Conduct
Values
- Be impartial, professional, accountable, respectful, and inclusive.
- Prioritise safety, ethics, merit-based decisions, and stewardship.
Code of Conduct
- Act with honesty, integrity, care, and diligence.
- Comply with laws and maintain confidentiality.
- Avoid conflicts of interest and misuse of authority.
- Uphold the agency’s integrity and investigate breaches.
Principle 2: Integrity knowledge and performance management
- Ensure employees possess necessary integrity knowledge and skills throughout their careers.
- Assess employee performance based on alignment with agency values.
- Evaluate leadership’s ability to promote institutional integrity.
- Incorporate integrity into annual performance reporting.
Principle 3: Integrity policies, resources, and systems
- Maintain policies covering various areas, including gifts and benefits, outside employment or volunteering, information management, privacy, impartiality, diversity and inclusion.
- Ensure access to integrity advice for all employees.
- Implement systems for reporting and managing conflicts of interest, suspected misconduct, discrimination, fraud, corruption, public interest disclosures, responses to ethical failures, protection of reporting individuals, and tracking gifts, benefits, hospitality, entertainment, and sponsored travel.
Principle 4: Integrity risk management
- Integrating integrity risk management into key business processes.
- Clearly defining responsibilities for managing integrity risks.
- Establishing systems to identify and respond to emerging integrity risks.
- Regularly reviewing the effectiveness of risk controls.
- Cultivating a culture that encourages open discussions about risk and integrity.
- Ensuring timely communication of integrity risks to stakeholders.
- Collaborating with relevant agencies and stakeholders to manage shared integrity risks.
- Allocating resources based on the severity of integrity risks in line with risk appetite.
Principle 5: Prevent, detect, and manage fraud and corruption
- Conduct frequent assessments to identify and understand fraud and corruption risks.
- Develop and implement a control plan specifically tailored to manage the identified fraud and corruption risks.
- Prevent fraud and corruption by educating officials about these issues and incorporating risk considerations into planning and activities.
- Establish mechanisms for detecting fraud and corruption, while providing a confidential reporting process for suspected instances.
- Investigate and address cases of fraud and corruption, including suspected instances, and maintain records while ensuring timely reporting.
Principle 6: Integrity in public resource management
- Ensuring efficient and ethical resource usage.
- Upholding probity, accountability, and transparency in resource management, including grants and procurement.
- Promoting equitable treatment in processes.
- Holding contractors accountable for conflicts of interest and compliance.
- Encouraging ethical behaviour and risk management among officials and suppliers.
- Addressing the risk of unethical supplier practices, such as conflicts of interest, fraud, corruption, tax avoidance, and modern slavery.
Principle 7: Protect people, information, and assets
- Identifying and managing security risks and sharing relevant information.
- Assessing the eligibility and suitability of personnel and contractors, including their integrity and honesty.
- Continuously evaluating and managing personnel’s suitability while sharing relevant concerns.
- Ensuring contractors adhere to security requirements.
- Communicating ongoing security obligations to departing personnel.
- Evaluating the organisation’s security capabilities and risk culture.
Principle 8: Monitor and evaluate organisational integrity
- Evaluating integrity incidents and conducting testing.
- Involving employees in assessments using integrity metrics.
- Identifying and addressing integrity threats and risks.
- Assessing the effectiveness of governance controls.
- Reporting on recommendations to enhance integrity.
Maturity indicators
Each principle is accompanied by a 4-level maturity scale, with each level building on the previous level. For example, with regards to Principle 5: Prevent, Detect, and Manage Fraud and Corruption, Level 1 Maturity refers to where there are no appropriate mechanisms for preventing fraud and corruption, reporting pathways are not widely promoted nor trusted, and countering fraud and corruption is not seen as important.
At the other end of the spectrum, Level 4 refers to where fraud and corruption risk assessments are embedded in activities of the agency and regularly reviewed, and all staff complete mandatory training. Reports are received regularly and reporters are provided timely follow-up, and the agency has a culture that views countering fraud and corruption as a necessary, non-negotiable priority.
Key takeaways
The Commonwealth Integrity Maturity Framework offers a robust blueprint for Commonwealth agencies to fortify their integrity frameworks. The eight Integrity Principles, grounded in Commonwealth laws and policies, underscore the commitment to transparency, ethics, and accountability. Furthermore, the maturity indicators provide a tangible roadmap for agencies to gauge and enhance their progress.
