Sector profile

Strong conflict of interest (COI) frameworks 

• Clear COI policy framework that identifies perceived, potential or actual conflict of interest, and how it is to be managed by staff and managers
• Ensure staff are informed and familiar with how to declare conflicts of interest, and make a declaration easy, fast and accessible
• Conducting training and awareness raising for employees and contractors
• Requiring all employees and contractors to provide written acknowledgement that they understand their organisation’s conflict of interest policy
• Clear gifts, benefits and hospitality policies and procedures that contain case studies and examples to improve understanding of risks
• Taking proactive measures to ensure staff are aware of, and understand, relevant policies
• Strengthening recruitment and promotion processes and policies
• Increasing awareness and compliance around declaring conflicts of interest

• Clear policies and procedures regarding assessment processes, including processes to be followed to ensure accountability
• Improved training and awareness of organisational records management and general records management standards
• Establish appropriate records management strategies, systems and audits to regularly assess and improve processes and compliance 
• Establish a clear and auditable trail of information
• Risk assessment strategies underpinned by regular training and audits
• Effective systems and audit regimes

Procurement – bidding and supplier selection

• Conducting regular and random audits to ensure compliance with procurement policies and procedures
• Electronic procurement systems with internal controls preventing the processing of invoices until details regarding quotes are entered into the system.

Procurement – contract management stage

• Monitor variations in contracts and ensure variations are approved by the appropriate financial delegate
• Purchase orders to be raised before receipt of an invoice
• Invoices must contain sufficient information and goods and services must be received before being paid
• Undertake regular and random audits to ensure the veracity of invoices and identify unusual transactions
• Segregate duties at various stages of the procurement process and ensure compliance with segregation
• Undertake audits to ensure good/services were ordered, delivered and invoiced appropriately.

• Robust recruitment policies and procedures to ensure integrity in the process
• Ensure that all job vacancies are advertised externally where required by policy and through internal systems.

• Deliver specific integrity training for leaders. For example, leading from the top, complying with conflict of interest requirements, and addressing reports of corruption and misconduct
• Establish Public Interest Disclosure policies and procedures training for employees
• Regular reviews of policies and procedures regarding corruption awareness, to ensure there are clear policies to train employees – particularly managers – about their obligations to report suspected corrupt behaviour

• An integrity risk review and prioritisation is undertaken by the department annually and is reviewed by the Executive Board. The Board considers the department’s strategic and operational integrity risk profile and identifies priority integrity risks to guide integrity activity for the year ahead. 
• Annual integrity performance assessments are a key oversight mechanism used to measure the department’s integrity performance and ‘ethical health’ against qualitative and quantitative indicators. The performance assessment shapes ongoing integrity risk identification and management activities.  
• The annual integrity and risk pulse check survey measures corporate staff perceptions of how the department manages integrity and risk. The results feature in the integrity performance assessment.
• A communications action plan is developed annually to map out integrity communications for the corporate and schools’ audiences. These communications seek to remind employees of their integrity obligations in addition to providing tailored messages for leaders to assist them to ‘set the tone from the top’ and create a positive integrity culture. 
• The department has five Integrity Leadership Groups which play a key consultative role in implementing integrity initiatives across the department and schools and embedding a strong and enduring culture of organisational integrity. The groups include a diverse range of staff including principals, business managers and corporate and regional staff from high-risk integrity areas. 
• The department offers a responsive and best-practice integrity advisory service to support corporate and school-based staff across the department to meet their integrity obligations in accordance with departmental policies, legislation, the Code of Conduct, and the department’s Values.
• An Integrity Capability Tool is available for all corporate staff to effectively identify their expected knowledge, skills and capabilities in relation to various integrity topics (including conflict of interest, procurement, records management and fraud and corruption control) for their given seniority and role type within the department.
• Integrity training and education resources, including eLearn modules and animations on Fraud and Corruption and Conflicts of Interest are available to all staff. Tailored integrity training is provided to address specific integrity risks across schools, corporate and regional staff. 
• The department supports a corporate culture where all staff, regardless of level or seniority, feel safe to speak up and know their concerns will be taken seriously, investigated, and managed discreetly. Staff have a range of channels to raise concerns, including through the 24-hour, external Speak Up service.