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The tone set from the top

A consistent and overwhelming message from the ICAC’s investigations and research is that corruption prevention strategies require thought, effort and commitment from the top levels in order to succeed. The authority of senior executives and elected public officials is needed to support and endorse corruption prevention initiatives and to ensure that prevention controls operate effectively; conversely, poor leadership can encourage non-compliance and corruption.

What does good tone at the top look like?

In many ways, good tone at the top derives from a leader’s demeanour, attitude and reputation. So, although we can often spot good or poor tone in our organisation, it is difficult to prescribe how to achieve it or test for it.

It goes without saying that good tone at the top means refraining from corrupt conduct as well as conduct that allows, encourages or causes corrupt conduct. However, any senior leader seeking to demonstrate observable “tone at the top” should:

  • not exempt themselves from policy and procedure requirements to which other staff are expected to adhere

  • personally attend code of conduct, ethics and corruption training, even if they feel they already understand the content

  • disclose their own actual and perceived conflicts of interest and visibly comply with the agency’s gifts policy

  • devote sufficient resources to preventing, detecting and investigating misconduct

  • personally reward or praise subordinates and colleagues that behave ethically

  • refrain from setting perverse incentives, such as formal key performance indicators that could drive unethical behaviour (for example, an unrealistic delivery date or savings target) or informal cues (for example, telling someone to “just get it done, I don’t care how”)

  • get involved in approving and promoting key policies such as the agency’s code of conduct, and look for opportunities to raise ethics and anti-corruption messages outside of formal training

  • not tolerate rationalisations that can contribute to corrupt conduct (for example, “It’s only taxpayers’ money”, “It’s always been done this way” or “Nobody is getting hurt”)

  • ensure the agency’s risk management framework considers the risk of corrupt conduct

  • encourage a “speak up” culture, where staff can voice concerns about unethical conduct and suspected corruption

  • act on red flags such as staff refusing to take annual leave, resisting accountability or living beyond their means

  • encourage compliance with both the spirit and letter of the law, especially in relation to the use of agency funds and resources

  • welcome internal audit and external reviews as an opportunity to demonstrate the proper use of public resources and, where possible, improve existing processes.

In addition, agency heads should have a level of personal involvement in reporting various types of alleged misconduct to the ICAC (s 11 of the Independent Commission Against Corruption Act 1988), NSW Ombudsman (reporting under the Public Interest Disclosures Act 1994), NSW Audit Office and NSW Police Force. They should also ensure the agency’s audit and risk committee (or similar body) has a mandate to oversee the corruption and fraud control program.