Cultivating an anti-corruption culture in the public service takes time and effort

By Melissa Coade

March 25, 2022

The swastika ban is the first law of its kind to be proposed in an Australian state or territory. (Stephane Debove/Adobe)

Two public sector leaders have shared their strategies on improving integrity culture within an organisation both to expose and prevent corruption.

According to Emily Howie, the general counsel and director of dispute resolution at the Victorian Equal Opportunity and Human Rights Commission (VEOHRC), leaders of all levels modelling respectful behaviour in an organisation is crucial. Being an example of this behaviour and reiterating cultural values should be both ad hoc and structured but always consistent about what expectations there were for integrity, she said. 

“This is about setting the tone in your treatment of others and being intentional about that as a standard that you want to set,” Howie said.

“This is the email before the work Christmas party that sets out what the expectations are of behaviour there, and those kinds of expectations should be communicated and very transparent throughout all your policies and processes, induction training codes of conduct performance plans, this communication needs to be ongoing.”

Addressing a virtual panel hosted by the Independent Broad-based Anti-corruption Commission on Thursday, Howie said the commission was concerned about the barriers preventing victim-survivors from speaking up and reporting what has happened to them. As a regulator, she said the VEOHRC was also cognisant that many people who have been harmed in the workplace did not have the wherewithal to lodge a complaint. Therefore, greater focus was needed to empower and support more victim-survivors or bystanders to report their grievances. 

“For the person affected by the unlawful behaviour, the barriers [to speaking up can] often be overwhelming. 

“And in fact, Kate Jenkins, in her Respect@Work report really highlighted the need to move away from relying on people who’ve been affected by the unlawful behaviour to actually raise the report and make the change or get the address that’s needed,” she said.

Howie said the commission’s education team offered comprehensive bystander training, which went some way to overcoming myriad barriers to more people speaking up.

“We benefit in our reviews and investigations work from the people who share with us their experience in the workplace of inappropriate or unlawful conduct.

“And we issue guidelines on the Equal Opportunity Act that address things such as how to prevent sexual harassment in the workplace, a key plank of which is building a speak up culture,” Howie said. 

It was important for organisations to be transparent about the outcomes of incidents that have been reported and resolved, and also reporting back to staff on people matters surveys. Procedural fairness in complaints was another key component to ensure workplace structures upheld values of integrity, and took grievances seriously, the lawyer said. 

“It’s absolutely vital that leaders support complainants from victimisation through a fair and confidential reporting and complaints procedure.

“This is about prioritising the wellbeing of the victim-survivor in the process,” Howie said.

“It is also important for leaders to call out inappropriate conduct when you see it. This protects the target of the behaviour, it communicates that the behaviour isn’t okay, and it discourages that behaviour from happening again,” she said. 

Corporate services deputy secretary, Dr Graeme Emonson, from the Victorian Department of Environment, Land, Water and Planning (DELWP) said his organisation of approximately 5,500 staff reported a 7% increase in perceptions of overall workplace integrity since a formal strategy was launched to address the issue three years ago.

“That’s up from 73% to 80%, which, whilst they’re small gains, they are really positive gains,” Emonson said. 

“We attribute a lot of that to the fact that we actually set out a very clear framework in the head strategy.”

DELWP’s integrity strategy is now in its second iteration, which has highlighted five key priority areas – one of those areas is to build up a strong speak-up environment. Emon said there were challenges, such as being a ‘diverse and dispersed’ organisation across 80 different worksites across Victoria.

“The whole aspect of having a safe speak up environment is a really central piece of our strategy to build an overall integrity culture,” he said. 

“A strong culture of integrity just doesn’t occur in its own right, it really does take a very deliberate and coordinated effort on behalf of the entire organisation: it is leaders, and it is a responsibility of all staff.”

Emonson said that his department set up a dedicated integrity unit in 2019, whose first task was to review existing frameworks and policies and make improvements where it was lacking. Formalising a strategy that relied on principles to build integrity understanding and better integrity management were the underpinning goals of the refreshed policy document. 

“We wanted to make sure that it was going to be leading-edge and, most importantly, that it was going to make a difference.

“We also developed a new strategy to complement that framework and that was all about re-orientating our efforts to build an integrity culture to one of promoting a shift to a more principles-based approach,” he said. 

“Having that broader strategic framework and strategy has really positioned us to drive a number of key initiatives across the department.”

At DEWLP, Dr Emonson said the approach was taken to send a clear message that could be repeated and would ‘cut through’ in an environment that was often ‘crowded’ with other important operational topics: ‘If something doesn’t look right, or you’re not sure, speak up.’

“That’s a bit of a catch line that we’re trying to utilise as a bit of a brand. It’s a really simple message and our experience is that it actually does cut through,” Emonson said.

Another important limb on the strategy was to build staff confidence in grievance processes, and promote a ‘no wrong door policy’ which allowed multiple touch-points across the department to link-up and share concerns if and when they arose. 

“We’ve done is we’ve really taken a very strong disclosure focused approach: taking reports seriously, managing the expectations of disclosures and really being really clear about those expectations,” Emonson said. 

“Confidentiality at every turn where we can, and building those foundations for supporting speak-up means that other people pass on word of mouth based on their experiences, and that’s a key initiative that we’re trying to instil.”


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