Does the APS have an integrity problem? Depends on who you ask, Sedgwick concludes

By Matthew Elmas

Thursday December 17, 2020


The Australian Public Service Commission will implement a batch of cultural, training and accountability reforms in an effort to strengthen institutional integrity across the government.

Former APSC boss Stephen Sedgwick published his report into institutional integrity within the APS on Wednesday, concluding the current approach does not require ‘radical additional changes’ — instead recommending adopting more common language and a ‘stocktake’ of current integrity training materials.

While several high profile integrity scandals have rocked the federal public service in recent months, Sedgwick found the broader APS is delivering on a ‘pro-integrity’ culture and should pursue ‘no regrets’ reforms to ensure standards remained high.

“Options are available to better ensure that awareness about potential integrity concerns and the skills to address them are continually refreshed as new risks emerge, as individuals assume additional leadership responsibilities, and for each succeeding generation of public servants,” Sedgwick wrote, directly referencing recent (scathing) auditor-general reports.

Stephen Sedgwick

The report — prepared in concert with a recommendation (7) from the Thodey review — makes 10 recommendations, all of which have been accepted by the APSC.

Current APSC boss Peter Woolcott said the report would further inform how the commission implements the Thodey review, with an implementation strategy to be developed as the next step.

“Many of the recommendations in the report align with the current priorities of the commission, including the development of mandatory integrity training and a refresh of guidance materials on integrity issues. The commission will now focus on the implementation of these recommendations,” he said in a statement.

Does the APS have an integrity problem?

The report also came to 10 ‘key findings’ (listed in full below), identifying a lack of consistency across agencies and departments on integrity, as well as potential improvements in cultural and training practices.

Significantly, Sedgwick found there isn’t agreement about whether the APS currently has an integrity problem — though it was agreed vigilance is the right approach in maintaining public trust.

‘Some’, Sedgwick said, argue the APS Census and other data don’t suggest systemic fraud or corruption within the federal public service; while ‘others’ — including integrity agency heads — say the APS just isn’t looking hard enough.

“They say that when agencies look ‘under a rock’ they typically find an issue or a potential issue and that it is unrealistic to expect that the APS will be any different to the community at large, which exhibits a background level of integrity concerns amongst a small proportion of the population,” Sedgwick said.

The recommendations

  • (1) The Secretaries Board adopt a common language when discussing integrity matters with employees, namely the pursuit of ‘high standards of APS professionalism’ which in turn means ‘doing the right thing at the right time to deliver the best outcomes for Australia sought by the professionally advised government of the day;
  • (2,3,6,7) The APSC, in collaboration with departments and agencies, examine current practices across the APS with a view to develop and promulgate (through enhanced guidance or commissioner’s directions, as necessary) clear and common expectations regarding:
  • (2) The knowledge required by APS employees soon after entry and at key stages of their subsequent career to ensure they achieve a level of awareness of the APS’s integrity frameworks and policies, appropriate to their role and responsibilities; and
  • (3) The capabilities required by APS employees soon after entry and at key stages of their subsequent career to ensure they can effectively implement the APS’s integrity frameworks and policies, as appropriate to their roles and responsibilities.
  • (6) How the ‘how’ is best addressed when assessing an employee’s performance in respect of the ‘what’ is required of them, given their role and responsibilities; and
  • (7) The principles and practices that agencies apply to determine when to commence a formal investigation of an integrity-related complaint with the aim to ensure greater consistency in how such decisions are made between agencies and between classifications.
  • (4) Informed by the commissioner’s guidance, the Talent Council(s) include consideration of the capability to model, champion and advance institutional integrity when assessing staff as part of SES talent and capability assessment processes, and identify development options for staff believed to be the future leaders of the APS that build their capacity to provide leadership for a pro-integrity culture;
  • (5) The APSC, in collaboration with departments and agencies, undertake a stocktake of the metrics that agencies monitor to assess how well individuals and their institution overall operate at high integrity / high professional standards;
  • (8) That, in future, any Code of Conduct allegations against SES officers be progressed in consultation with the APSC, both in respect of whether and how to investigate an allegation and, if applicable, what sanction(s) to apply(achieved through enhanced guidance or commissioner’s directions, as necessary);
  • (9) The APS commissioner and the secretary of the Department of the Prime Minister and Cabinet ensure that explicit attention is paid in each secretary’s annual performance assessment of the framework they have in place and their success in achieving high professional standards of conduct and delivery (and stewardship) in the department they lead; and
  • (10) As part of the future capability reviews the government has agreed should be undertaken by the APSC from 2021, an explicit assessment be made of how effectively each agency is securing an appropriate workplace culture having regard to the need to strengthen institutional integrity and consistently exhibit integrity / high professional standards of conduct and delivery in line with any commissioner’s guidance. This aspect of each review should be informed by the perspectives of at least one reviewer with extensive appropriate experience outside the APS who also understands the role of the APS in the Westminster tradition.

The key findings

  • There isn’t agreement about how broadly the APS’ ‘integrity’ agenda should be cast, although the differences may reflect nomenclature rather than a fundamental disagreement about preferred behaviours;
  • There isn’t agreement about whether the APS currently has an integrity ‘problem’, though most agree that vigilance and proactive messaging is desirable to maintain public trust over time;
  • There are different emphases about the most effective framework in which to address integrity issues (summarised in shorthand as ‘compliance and/or culture’), although the differences can be overstated in practice;
  • Opinions vary about what language resonates most effectively with staff: ‘integrity’ or concepts like ‘professionalism’;
  • Central agencies can usefully provide guidance and act as an accessible source of ‘truth’, but local leaders must provide context, relevant examples and incentives. It is well accepted (at all levels) that local leadership and effective communication are key. Feedback during consultations, though, suggests that performance (whether actual performance or perceived performance is irrelevant for this point) can be patchy;
  • Effective delivery is generally seen as the key to securing / retaining the trust of ministers and the public. Frequently identified issues include: the desired balance between the ‘what’ and the ’how’ of delivery; whether practice and theory about the desirable balance are adequately aligned; and whether managers have the requisite skills and aptitudes. Some argued that poor skills or aptitudes can become a source of future integrity risk, which may be difficult to reverse once embedded in workplace culture. The increased use of contractors rather than APS employees is said to pose particular challenges;
  • Trust is built within teams when leaders create a safe space in which issues of concern can be raised without fear of adverse consequences, provided also that those concerns are then considered and properly and transparently addressed. Addressing ‘little things’ as they emerge matters. The payoff from creating such a space and addressing emerging concerns extends well beyond integrity issues into delivery effectiveness, employee productivity and innovation;
  • Accountability of senior leaders, secretaries, and agency heads for delivery (the ‘what’) is generally clear. Among other things, ministers make their feelings known, if only indirectly. Accountability for the ‘how’ is less clear and arguably is left ‘up to us’, aided by oversight of integrity agencies, including ANAO and the Ombudsman. Accountability is even less clear in respect of the longer-term stewardship of the APS as an enduring institution that needs to be ‘fit-for-purpose’ as needs change over time;
  • Departments and agencies monitor a range of indicators that bear on integrity issues. Work is in hand in some cases to extend existing measures beyond standard ‘hygiene’ metrics into more sophisticated indicators of organisational culture. The latter is seen as one area that would benefit from collaborative work between agencies with a similar agenda; and
  • There is palpable pride about how the APS reinvented itself to deal with COVID and demonstrated the benefits of acting as ‘One APS’. This may provide momentum for further productive change (a positive COVID dividend!)

The full report is available here.

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