Part 4: A strong core

A strong core requires the practices, systems, and policies that influence an organisation’s culture to be aligned to the organisation’s purpose and values. When they work in unison, they can directly contribute to the integrity of an organisation and the ethical behaviour of its people.

Tika, pono, and aroha are fundamental in te ao Māori – they bind everything together by providing a way in which everything is upheld and accomplished. The koru on the pou represent the people in the company coming together, working together, with tika, pono, and aroha to uphold the organisation’s integrity.

Leading with integrity

Why it matters: When leaders set a high bar for integrity and ethical behaviour, it sets a positive culture throughout the whole organisation

For integrity to be at the heart of an organisation, there must be a strong commitment to it from senior leaders. This commitment must be genuine and consistent, regardless of the pressures that leaders are facing. If ethical leadership is not demonstrated at the top, it is unlikely to be found in the organisation.

"Integrity is a leadership issue, and leaders need to close the integrity gap to ensure no one else falls through it.” 

Ferguson Values, “5-Step Model to Close the Integrity Gap”

When leaders behave ethically, staff are more likely to be motivated, committed, and willing to report problems. Workplaces where leaders demonstrate ethical behaviour are associated with lower rates of sick leave, high work satisfaction, and higher productivity.²⁴

"It’s the 21st century … and ethical and authentic leadership really matter. We have the public expecting us to improve our behaviour and relationships.” 

NSW Public Service Commission, Behaving Ethically: A guide for NSW government sector employees

What it looks like: Leaders are committed to creating a safe and ethical workplace

Setting the tone

Leading with integrity and being accountable is reciprocal – people give what they feel they are receiving. If leaders want staff to commit to their organisation’s purpose and values then leaders must also commit to those purpose and values, and their behaviours and decision-making need to reflect this.

Leaders must hold themselves to the same standards as is expected from everyone else in the organisation. For example, management override of policies should only be used in exceptional circumstances and the reasons should be documented.

Leading with integrity requires persistence to “do the right thing” even in challenging situations. It is important that leaders are transparent about their decision-making and remain open to feedback and being challenged. Transparency about the thinking and challenges at the top also helps others to see decisions in context.

Senior leaders need to address problematic behaviour at its earliest signs, whether it’s an inappropriate joke, a dismissive comment, or subtle exclusionary practices, and prevent these behaviours from escalating. This proactive approach not only curbs the development of a toxic work environment but also sends a clear message that such behaviours will not be tolerated.

People leaders and middle managers also play an important role when it comes to shaping the behaviour of staff and setting a positive organisational culture. Staff may not have strong working relationships with senior leaders, especially in larger organisations. It is important to pay attention to how an organisation’s people leaders, from frontline supervisors to the senior executive team, lead with integrity.²⁵

Leadership and building psychological safety

Psychological safety means staff know that they will not be punished or humiliated for speaking up with ideas, questions, concerns, or mistakes. High psychological safety improves team collaboration, innovation, performance, job satisfaction, and staff retention. It also contributes to reduced stress and improved well-being.²⁶

Leadership styles that share a common thread of supporting and caring for people are linked to encouraging a culture of integrity.²⁷ This includes styles of leadership that support a culture where:

• staff are encouraged to achieve goals and produce high-quality work;
• collaboration is highly valued;
• staff are respected and cared for;
• there is positive change and innovation; and
• staff have a sense of agency and feel empowered.

These leadership styles align with the concept of aroha (to care for people with compassion and empathy).²⁸

Māori models of leadership provide insight into qualities and behaviours that support the well-being of groups and individuals and contribute to the overall psychological safety of an organisation.²⁹ These qualities and behaviours include the ability to weave people together to focus on collective goals and the demonstration of tika, pono, and aroha in daily interactions.³⁰

A key part of effective leadership is being able to influence other people. To do this, leaders need to build meaningful relationships that are based on mutual trust, empathy, respect, support, and care.

Without these relationships, the ability to influence the behaviour of others will be limited. Showing staff that they are valued and that their contributions are important helps to build strong positive relationships.

Leading with integrity is a skill

Leaders tend to overestimate their own ethical judgement and leadership abilities, compared to how staff view them.³¹ Leaders need support to develop effective leadership styles. Performance assessment and promotions processes for leaders need to be designed to ensure that only those leaders who demonstrate the values and skills in this type of leadership progress.

"When I began this work, I tended to think of integrity as an innate quality – you had it or you didn’t.… But there are serious limitations in framing integrity as the stuff of saints. I now think of integrity as a skill and a habit. A kind of behavioural dance that we can move in and out of all day, depending on how self-aware we are in the moment.”

Sue Robertson, There but for the grace of God

It can be helpful for leaders to talk through their decisions with a trusted advisor. For example, the chairperson of an audit and risk committee can be a useful sounding board for chief executives, and some public organisations in central government have nominated a member of their senior leadership team to be an integrity champion.

Actions to consider Take responsibility for your decisions and actions and hold yourself publicly accountable for their outcomes. When mistakes occur, apologise and remedy the error, being transparent about any changes made and what was learned. Monitor and report on the use of policy overrides (for example, in procurement or appointments). Invite feedback from staff on whether organisational values underpin leadership practices in the organisation and what improvements could be made. Share ethical dilemmas that your organisation has faced. Use examples to highlight how ethical challenges might be navigated. Challenge decisions or behaviours that appear inconsistent with your organisation’s values and report on these to the organisation.

Raising and responding to concerns

Why it matters: A safe environment to raise concerns helps to protect staff and provides an important source of feedback about the health of the organisation

When people feel safe to raise concerns without fear of negative consequences, risks can be identified and managed appropriately. It also gives an organisation visibility of what is happening, allowing it to respond effectively and make improvements (including steps to prevent and detect wrongdoing).

"We find that when concerns are reported early, inappropriate behaviours can be addressed quickly and before they cause serious harm.

Government department integrity specialist

When done well, people not only feel heard and safe but can see that leaders of the organisation are understanding and responding to concerns. This can improve morale and trust and strengthen relationships.

What it looks like: When someone speaks up, they are heard. They expect and receive an appropriate response and restorative action

A “speak-up” culture has been a priority for integrity and compliance functions for decades, with a focus on encouraging staff to report inappropriate conduct. In recent years, the focus has shifted from “How do I get my staff to speak up?” to “How can I create an environment where staff feel safe, empowered, and encouraged to speak up?”³²

This shift in focus acknowledges that raising concerns takes courage. People who raise concerns can feel lonely and vulnerable. Staff are often reluctant to raise concerns, mainly because they do not believe they will be protected or that anything will be done.³³ Power is also not equally distributed throughout an organisation – hierarchy or unconscious bias can mean that the costs of speaking up are different for different people.

Raising concerns

Organisations need clear and easy-to-follow processes that people can use to raise concerns or complaints. These processes should prioritise staff safety and well-being.

The effectiveness of any process for raising concerns will in part be determined by the wider culture of the organisation. This includes whether staff feel their work environment is a safe place to share their ideas and opinions, voice concerns, ask questions, or make mistakes. It is difficult to expect employees to raise their hand when they see something wrong if they aren’t listened to or invited to share their perspective in the normal course of work.

Have multiple informal and formal channels to raise concerns

Organisations should offer multiple channels for reporting concerns. This helps people to raise concerns in any circumstance and through any channel they feel most comfortable with, even if they are uncertain or don’t have evidence to support their concerns. Channels should be designed to accommodate staff raising issues either as a group or individually.

"In our organisation, we put multiple channels in place to support people with reporting – people can report their concerns to their manager, to our health and safety team, or to our integrity advisor. People can also report concerns confidentially via text, email, an external phone line, or using a web form on our intranet.”

Government department integrity specialist

All channels should be clearly communicated and visibly endorsed by leadership. By doing so, organisations can create a culture of openness and trust, where employees feel empowered to speak up without fear.

At a minimum, the following channels should be available:

• Informal – Staff can ask a question or speak privately to someone trusted in the organisation or raise a question in an open forum, such as a team meeting or talk.
• Through the line – Staff can discuss an issue or make a formal complaint to a manager or supervisor.
• Chief executive – Staff can raise any concerns about possible wrongdoing directly with the chief executive.
• Protected disclosure – Staff can talk confidentially to a designated impartial person in the organisation and/or a range of external authorities in certain circumstances.³⁴

Because people might raise multiple and varying concerns, processes should be designed to accommodate a combination of issues without requiring the individual to follow separate processes.³⁵

"When we added additional ways to raise concerns, we expected to be dealing with a much greater number of serious complaints. We did receive a lot more concerns, but the number of concerns that needed to be escalated to a formal process didn’t change; instead we were able to deal with concerns earlier.”

Government department integrity specialist

When designing different channels for raising concerns, organisations should seek feedback on cultural appropriateness and accessibility. This can help to avoid inadvertently creating barriers for people to raise concerns.

Silence might not merely mean a lack of safety or lack of confidence to speak up for an organisation or for an individual, but might mean the appropriate opportunity or context to raise an idea or matter is not yet clear or sensitively offered.

External mechanisms

Organisations should also consider mechanisms for concerns or complaints from the public or people accessing their services. The appropriate mechanism will depend on the public organisation’s role and types of services it provides.

Responding to concerns

Responding to concerns should be done is a way that is timely, fair, and trusted.

"I have confidence in the process. If something is raised, it will be addressed appropriately.”

Government department staff member

Organisations should prioritise finding the best ways to address the harm caused and prevent future harm. Approaches that focus on assessing whether unlawful or poor conduct can be substantiated should be complemented by respect and empathy when considering actions most likely to remedy the impact of the harm.

Any process needs to be culturally safe and agreed on by participants, so the process does not replicate and reinforce harm. Tika and pono can help guide processes of resolution through constructs such as whakatika, which calls for people to correct or put right transgressions against others or things that have been done wrong.³⁶ These processes require skilled facilitation.

Responding to concerns starts with assessing the concern raised. Often a disclosure will involve more than one issue.³⁷ Failure to properly assess a disclosure and manage the full range of issues raised is often the first step towards bad outcomes.³⁸

"Allowing all parties to know what the process is has built trust amongst staff that action is being taken against integrity breaches and that the organisation stands firmly by its values.”

Government department manager

Have a high degree of transparency

Although some issues need to be managed confidentially, it is important to be as transparent as possible, particularly with people who raise concerns or make complaints. This should include communication to keep staff who raise concerns informed about progress, as well as sharing as much information about decisions or outcomes as possible. This builds trust that action is being taken about integrity breaches and that the organisation stands firmly by its values.

A lack of visibility can lead to staff making assumptions about what is happening.

Have tailored support for staff

Staff who raise concerns need to receive tailored support and regular communication. There should be a range of mechanisms in place to ensure that those who raised a concern are getting the care and support they need to feel safe and are reassured there will not be any negative consequences for them. It is also important to provide appropriate support for those who have had concerns raised against them throughout the process, regardless of outcome.

Organisations need to have the capability to provide tailored support for their people. For public service organisations, the Speaking up model sets out minimum expectations to support staff to speak up about wrongdoing.³⁹

Provide training

Organisations should have training available for people who might deal with concerns. Training and support should cover receiving and dealing with concerns and formal complaints. This helps with a consistent and clear approach throughout the organisation.

Following up

After formal processes have concluded, it is important to check on the well-being of those who raised the concern. Even when people do not believe they have been treated badly through the process, most still experience a range of negative consequences.⁴⁰ The most prevalent are informal “collateral” impacts (such as stress, reduced performance, and isolation) over and above deliberate reprisals and employment actions.⁴¹

Where there have been integrity breaches, the impacts can ripple out much wider than those directly affected. Speaking authentically about issues can help rebuild trust.

Monitoring

It is important to monitor whether processes (triage, risk assessment, support, intervention, and remediation), roles, and responsibilities are operating effectively.

Low rates of concerns or complaints raised in an organisation might mean it has no issues. It might also indicate a lack of trust or a belief that speaking up will not result in change or could lead to a worse outcome (for example, reprisal or retaliation against an individual).⁴²

Actions to consider Put a range of reporting channels in place (including informal, formal, and anonymous channels) to resolve concerns as quickly and as close to the event as practical and safe to do so. Communicate regularly with staff who raise concerns about progress in responding to those concerns, and share as much information about decisions or outcomes as possible. Make support available for complainants, and those complained about, through any process. Ensure that relevant concerns and investigation outcomes are considered in decision-making (for example, when considering the suitability of an individual for career progression or promotion). Monitor speaking-up processes (triage, risk assessment, support, intervention, and remediation), to check that they are operating effectively. Actively seek feedback from staff about their understanding of and trust in your organisation’s processes for raising concerns, and any barriers to the flow of information through the organisation. Engage directly with staff to help understand what issues might be occurring in the organisation. Put channels in place that enable staff to raise concerns as a group, rather than only individually. Provide training for people leaders on psychological safety, how to raise and respond to concerns, and managing conflict.

A code of conduct

Why it matters: A code of conduct creates a shared understanding of expected behaviours and fosters responsibility and accountability

A code of conduct is the first opportunity to interact with new staff and clearly communicate to everyone who works at the organisation what is acceptable and unacceptable behaviour. It expands on organisational values and explains “the way we work around here”. A code of conduct requires active agreement, which establishes the behaviours to which people will hold themselves and others to account.

"Introducing our new code of conduct took a lot of work but it has perhaps been the biggest contributor to the improvement in setting out the expectations of behaviour for all staff.”

Non-public service department integrity specialist

A code of conduct will be effective only if people understand how to comply with it. A code of conduct should help people by providing standards that they can apply to specific situations.

If someone faces an integrity problem, a code of conduct should help them make a judgement, consider the individual circumstances of the situation, and arrive at a well-founded decision.

What it looks like: A code of conduct translates values into behaviours

Typically, a code of conduct is a written set of norms that outlines desired behaviours and often includes clear guidance on the consequences for breaches and possible sanctions for violations.

When preparing or updating a code of conduct, consult with staff, staff networks, and unions to improve its effectiveness.⁴³ There might also be cultural considerations in preparing and applying a code of conduct.

However, a code of conduct alone is not enough to influence behaviour and ethical decision-making. It needs to be supported through activities in the organisation – for example, making safe channels available for raising specific questions or discussing ethical dilemmas as they arise, as well as channels to raise failures when they occur. It also requires a programme of communication and training supported by leadership that exhibits core values and desired behaviours.

When an integrity issue is resolved, the lessons (such as the circumstance, issue, and resolution) should be shared with staff where possible, to help show what is and is not acceptable through real-life situations.

The Public Service Commissioner has issued a code of conduct and accompanying guidance for public service organisations.⁴⁴ However, any organisation can incorporate it into its own code of conduct or produce supplementary codes to cover specific circumstances. Councils are legally required to adopt a code of conduct for their elected members.⁴⁵

People might also belong to professional bodies that have standards required of them when working as a member of that profession (for example, lawyers and accountants). These further inform and support the integrity of staff when doing their work.

Organisations should consider applying the same expectations of behaviour for contracted or funded third parties. This can be achieved by specifying them in tender documents, contracts, and supplier briefings.⁴⁶

Actions to consider Ensure that your code of conduct reflects the values of the organisation and any legislative obligations for integrity and conduct. Train new staff on the code of conduct so they understand what acceptable and unacceptable behaviour is, and the consequences for non-compliance. Monitor and report on compliance with the code of conduct in all parts of your organisation. Review the code of conduct regularly and involve staff in the review process. Ensure that new staff sign and agree to the code of conduct, and consider a regular requirement for all staff to reaffirm their commitment to the code. Ask staff about how the code of conduct contributes to their day-to-day decision-making and whether it helps them to navigate integrity issues. Talk about situations where you feel the code of conduct is not being followed and encourage staff to raise concerns they see.

Policies and procedures

Why it matters: Policies and procedures help staff know what is expected of them and what they should do in certain situations

Policies and procedures support the practical day-to-day implementation of an organisation’s values and desired behaviours and help to set its internal control environment. When designed in the right way, policies and procedures ensure that activities in the organisation support the organisation to achieves its purpose in ways that demonstrate its values. Policies and procedures also can help organisations maintain consistency and control over their operations.

"In terms of what they’ve done to change the culture, it’s about how you “walk the talk”, for example health and safety is about making sure people know it’s not just done because of a piece of legislation, it’s about a genuine commitment to getting people home safe.”

Local authority manager

Policies that clearly align with an organisation’s values help staff understand why the policies matter. For example, the importance of policies about conflicts of interest can be explained by referring to values such as independence and fairness. Ensuring that policies have a clear link to the organisation’s values can also help to avoid excessive or arbitrary policies.

What it looks like: Values are embedded into day-to-day business activities

An organisation’s policies and procedures should have a clear purpose and make it easy for staff to know what they need to do or consider in different circumstances. Policies and procedures should be tailored to an organisation’s function, capabilities, and risks, including integrity risks. The process for ensuring that staff are complying with policies should be clear.

"How easy processes are is an indication of how much the organisation values people doing the right thing, and they have a responsibility to make things as easy as possible.”

Government department staff member

All policies and procedures should be:

• designed to clearly link to and support the organisation’s values;
• developed and administered through a simple and transparent process;
• prepared and reviewed with staff involvement; and
• easy to understand and follow.

There are some integrity-related policies and procedures that all public organisations should have. These include a code of conduct; declaring and managing conflicts of interest, sensitive expenditure, and gifts and hospitality; and whistle blowing procedures.

"If you are following our values, you will be following our policies.”

Local authority senior leader

There are also policies and processes that are indirectly related to ethics and integrity in an organisation, such as equality and diversity policies, procurement policies, and bullying and harassment procedures.

"The level of maturity in the organisation around the topic of integrity is constantly growing, so current policies and practices need to be regularly reviewed and reframed and all staff need to be engaged in the conversation.”

Local authority manager

It is important that policies and procedures are regularly reviewed. Seeking feedback from staff about what is and isn’t working can help ensure that an organisation’s systems and processes remain easy to navigate, make clear what is expected, and continue to align with the values of the organisation.

"There are ways for staff to give feedback on policies which allows them to be constantly updated and developed so they are fit for purpose.”

Local authority staff member

Seeking feedback on policies and practices also helps identify whether any of them are discriminatory or are upholding systems of inequity. Organisations should be open to testing and reviewing their policies and procedures to uncover unexpected outcomes that they may cause.

For example, our multicultural society means people might have different understandings of what constitutes a “close relationship” in terms of an actual or perceived conflict of interest. A lack of understanding of whanaungatanga and Māori relationships can result in conflict-of-interest instruments being applied to Māori staff when not appropriate.

For public service organisations, policies and procedures will need to align with the principles and values of the Public Service Act, the Public Service Commissioner’s code of conduct, and the Public Service Commissioner’s minimum expectations in specific integrity areas (which are set out in model standards).⁴⁷

Public service organisations can encourage integrity practices in third-party contractors by embedding clear expectations into their procurement policies and contractual agreements.

This might include:

• establishing reporting mechanisms for integrity concerns;
• conducting regular audits to ensure compliance with laws and policies, including relevant code of conduct provisions; and
• creating communication channels to address integrity risks throughout the contract period.

Actions to consider Explicitly build your organisation’s values into your policies, processes, and day-to-day activities. Check with staff that policies and procedures are accessible and easy to understand and incorporate feedback into policy and procedure improvements. Review policies on a regular cycle and update them to incorporate good practice and respond to emerging needs. Consult staff early in processes to draft, review, or improve policies and procedures.

People processes

Why it matters: People processes help create coherence and consistency in what values and behaviours are recruited for, rewarded, and encouraged

Emphasising the importance of ethical behaviour and values at each stage of the employee life cycle is critical to embedding integrity into an organisation.⁴⁸ Recruiting people who fit an organisation’s values and culture will make it much more likely staff will be operating with integrity.

"Leaders must be seen to make the hard decisions when their direct reports aren’t displaying the values. Often, we find that, because an individual is ‘delivering’ the work, we are willing to tolerate a greater level of poor behaviour.”

RDC Group Limited, Civil Aviation Authority Organisational Culture Review

When considering an individual’s performance, ensuring that their behaviour aligns with the organisation’s values is just as important as their achievements.⁴⁹

If an individual does not demonstrate the values and behaviours appropriate to their role, the consequences will affect their colleagues and potentially undermine how the organisation is viewed by the public.

What it looks like: Values are factored into and reinforced throughout all parts of the employee life cycle to encourage, reward, and monitor ethical behaviour

Recruitment

Values need to be embedded in all parts of recruitment processes. This starts with clearly highlighting values in any material relating to the job vacancy. Recruitment processes should:

• be transparent that a good match in terms of values is important to the organisation and the role;⁵⁰
• include ways to test an applicant’s alignment with the organisation’s values as well as important job-based skills and core competencies;
• use recruitment techniques and interviewing tools that identify values-based attributes (such as values mapping, pre-employment evaluations, and behavioural and values-based interview questions);
• be wary of textbook answers in interviews and dig a little deeper if needed to find out more; and
• ensure that reference checks also include questions to assess fit to values.

A values-based approach to recruitment goes both ways – all interactions with candidates provide an opportunity to demonstrate the organisation’s values.

Recruiting on values does not mean creating a workforce that thinks and acts the same. Diversity and inclusion remain important. When applying values-based recruitment practices, it is essential to implement recruitment practices fairly.

"In the interview process, I was asked to choose a value and speak to it.”

Government department staff member

Induction and orientation

The induction process for new staff sets the tone for an employee’s entire journey in an organisation. A good induction prioritises discussion about the organisation’s values and how they are applied in day-to-day work.

"Everyone gets the same messaging through the induction process, which builds the affinity to the processes and values that are shared.”

Government department staff member

Induction also provides an opportunity to tell the organisation’s history and context, including from the perspective of te Tiriti. This could include identifying which iwi and hapū are mana whenua where the organisation is located and explaining any agreed tikanga arising from relationships with them.⁵¹

Performance assessment

The culture of an organisation is influenced more by what it chooses to measure and reward than by what it says. When assessing performance, consider how an individual’s behaviour aligns with the organisation’s values. This means assessing both what was done and how it was done.

When performance assessments are simply a compliance exercise, it can send a strong message to staff about whether, and how, they are valued. Regular feedback about both performance and behaviour can help people to develop and improve, as well as reinforce positive behaviours.

Learning and professional development

Ongoing training about ethics and integrity should also be provided. Ethics training enables staff to identify and deal with ethical problems that might arise. Building in everyday discussion about ethics and talking through ethical dilemmas in teams also helps people learn how to apply an organisation’s purpose and values to decision-making.

Career progression

The process of identifying an individual for progression should be as thorough as any external recruitment because, among other matters, the organisation has more opportunity for getting it right. The organisation has the individual’s past performance and behaviour to inform its decision.

When someone is promoted, there will be an implicit assumption that the organisation approves of the individual’s behaviour and how well they model the organisation’s values.

Exiting

When someone leaves an organisation, exit interviews are a source of information about how values and desired behaviours are perceived and practiced. Exit interviews also provide an opportunity for staff to feel heard, and can help staff feel proud of their contributions.⁵²

Actions to consider Monitor and assess recruitment and contracting processes to ensure fairness and minimise the risk of bias. Design your organisation’s induction processes so they are grounded in your organisational values and set clear expectations about acceptable behaviour. Explicitly consider values alignment in all recruitment, promotion, and remuneration decisions. Incorporate a dedicated section into your formal performance assessment procedure for assessing how well staff have integrated your organisation’s values into their work. Provide all staff with the opportunity to participate in exit interviews when leaving your organisation to provide feedback for improvement. Ensure that the feedback is passed on to an appropriate person or function to be actioned.

Integrity roles and responsibilities

Why it matters: Improving organisational integrity requires ongoing commitment, focus, accountability, and resources

Building integrity at an organisational level doesn’t just happen. It is an ongoing commitment that requires sufficient time, dedicated resourcing, and clear roles and responsibilities.

Clear roles and responsibilities help create a structured, organised, and systematic approach to embedding values into strategy, business structures, and processes across an organisation.

Clear roles also help each individual and team know what they are accountable for. This accountability fosters a sense of ownership and encourages everyone to perform their tasks to the best of their abilities. It also makes it easier to identify and address any issues or gaps that may arise.

What it looks like: Roles and responsibilities for managing integrity are assigned across the organisation

Organisations will likely have several integrity-related functions for the different tasks associated with preventing, detecting, and responding to integrity matters. These functions might include people and capability, finance, legal, risk and compliance, privacy officer, and internal/external audit teams.

The allocation of integrity roles and responsibilities needs to reflect the size, scale, and complexity of an organisation’s operations and the type of integrity risks it faces. It is important that each of the elements of this framework are well described and are clearly assigned to staff.

It should also be someone’s role to bring together all the different parts of an integrity system (or framework) to monitor and measure progress at an organisational level.

Some organisations have a dedicated integrity advisor or unit to deal with integrity matters.⁵³ However, they still need to work with other functions to ensure that integrity issues are managed across the organisation.⁵⁴ It is also important to ensure that there is governance oversight of all integrity functions, with responsibility for balancing prevention, detection, and response efforts.

"Responsibility for integrity doesn’t just sit at the top table. However, it does start there.”

Government department senior leader

Those in governance should regularly monitor how well the organisation’s values, the design and operation of its internal controls, and its staff behaviour are aligned. It is also important that these discussions at the governance level include incidents or examples of behaviour that do not reinforce its values (and what changes are required as a result).

An organisation’s internal audit function helps provide governors with independent assurance about the internal integrity system. Internal audit has a critical role to play by understanding risks and monitoring whether the organisation is adequately responding to them.

"Conversations at the senior leadership level are ongoing, monthly. There has been a need to get back into ethics practices after the covid years. We need to talk about this every day and have the discipline of talking about it regularly such as in quarterly meetings.”

Non-public service department integrity specialist

It is also important to recognise and support informal leaders and their role in creating a positive culture. Informal leaders are those who “live the values”, model and champion desired behaviours, connect with people throughout the organisation, and demonstrate integrity in their everyday actions.

Actions to consider Develop an integrity strategy and work programme specific to your organisation. Establish clear roles and responsibilities for monitoring and improving organisational integrity, including who sees integrity information and how it is used. Ensure that people who manage and oversee integrity in your organisation are clear about their role and responsibilities and how their roles fit alongside other related functions. Designate a senior leadership team member as an integrity leader so they can champion integrity at an organisational level. Support and train staff to uphold and enhance their position as role models and early responders to integrity issues.

Continuous learning and improvement

Why it matters: Integrity is not a destination; it is an ongoing process where an organisation continually looks for ways to improve

Monitoring integrity is not an exact science, but any organisation committed to a culture of integrity will focus on continuous improvement. This means being willing to learn and adapt. Organisations that effectively monitor and report on their integrity performance are better positioned to:

• identify risks;
• action and remedy integrity issues; and
• embed integrity into all aspects of organisational culture and practice.⁵⁵

"Integrity is not a once-a-year wonder. It needs to continue to be delivered over the course of the year. Don’t only deliver messaging on integrity because there is a problem. It needs to become a routine of the organisation.”

Government department integrity specialist

Integrity requires a sustained commitment to making necessary improvements, preventing poor conduct and behaviours over the long term. Regular reviews of progress toward embedding integrity into everyday practice is essential.

What it looks like: Continuous improvement requires doing things better, and sometimes differently

Processes for monitoring organisational integrity

Using an organisation’s accumulated data, information, and knowledge can help make sure that new initiatives build on previous experience and avoid past mistakes.⁵⁶

Organisations might already have a regular review or monitoring process that includes components of this integrity framework. The challenge is to integrate this monitoring with reporting on organisational culture to provide a system perspective.

Monitoring progress means assessing the “direction of travel”, rather than focusing solely on specific outputs and outcomes. This requires attention to both what is done and how it is done.

Consider organisational culture and context

The importance of “soft” and “hard” monitoring of organisational culture should not be underestimated. Formal data collection and feedback needs to be combined with informal feedback from staff.

Regular and genuine engagement by leaders and governors can provide insight into an organisation’s culture and leadership performance. This can help identify issues that might not emerge through formal monitoring or data analysis.

It is also important to seek multiple sources of information and close the feedback loop. This can help to make sure staff know what’s going on and can see leaders continuing to prioritise the improvement of the organisation’s culture.

Use diverse indicators

To monitor progress effectively, organisations will need to use a combination of quantitative and qualitative data collection methods. They could include:

• incident reports and types of incidents;
• outcomes from investigations, complaints, and stakeholder engagement surveys;
• insights from culture and climate surveys (especially any that help understand levels of psychological safety);
• feedback from groups such as kaimahi Māori or the organisation’s staff networks;
• notes from exit interviews;
• trends in the use of employee counselling and support services;
• findings from internal audits; and
• views and experiences of external stakeholders.

It might be necessary to combine current data with new data collection strategies to effectively monitor organisational integrity.

Ensure clear accountabilities

Monitoring and reporting progress is useful only if it informs the planning, reporting, and assurance processes set up to improve and account for an organisation’s activities and risks.

"We share where there are lessons for the organisation. It’s great to be able to use things that have happened to educate.”

Government department manager

Internally, this means regular reporting and discussion at a governance level about the organisation’s integrity system and culture.

Where public organisations are spending public money, collecting and using personal information, or exercising coercive powers, it is essential to assure the public that integrity is safeguarded. An external account, such as describing the types and outcomes of integrity investigations in an annual report, provides insight into the design and operation of the integrity system.

"Reporting the outcomes of your monitoring to stakeholders can build trust and enhance the credibility of your monitoring. This should include being transparent and open about things that didn’t go well and reporting this information clearly. The New Zealand Customs Service includes indicators about its ongoing programme to safeguard integrity and prevent corruption in its annual report. The information includes data on the outcomes of investigations into allegations of unacceptable behaviour and what type of corrective action was needed.”

Controller and Auditor-General, The problems, progress, and potential of performance reporting

Commit to continuous monitoring

Frequent and effective monitoring will reveal any changes in an organisation that affect organisational integrity.

Effective monitoring requires committing to regularly reviewing and updating practices to keep pace with changes and challenges. Understanding the effects of the interventions in place to improve integrity is essential – integrity interventions need to be planned with evaluation and monitoring in mind.

Careful use of monitoring data

Data collected for monitoring integrity needs to be used thoughtfully and carefully. It is important to handle this information in a way that upholds the organisation’s integrity and respects the trust of those who provided it. Misusing data can erode trust and undermine the very integrity that the monitoring aims to protect.⁵⁷

Actions to consider Make integrity a regular item on the agenda for governance and/or senior leadership team meetings. Identify the mechanisms your organisation uses to collect and share information about organisational integrity. Use diverse types of data and information to monitor integrity (for example, a mix of qualitative and quantitative data). Work with other public organisations to support and learn from each other. Ask stakeholders for their perspectives on integrity in your organisation. Implement feedback mechanisms to record learning and improvement opportunities from staff and stakeholders. Recognise commitments to continuous improvement by rewarding team members who contribute to integrity initiatives.

---

24: NSW Public Service Commission (2014), Behaving Ethically: A guide for NSW government sector employees, at psc.nsw.gov.au.

25: The Leadership Development Centre has resources and core leadership development programmes that provide additional support and development.

26: See “Integrity and psychological safety for leaders”, Australian Public Service, at apsc.gov.au.

27: See NSW Public Service Commission (2014), Behaving Ethically: A guide for NSW government sector employees, at psc.nsw.gov.au.

28: Hawkins, C (2017), “How does a Māori leadership model fit within current leadership contexts in Early Childhood Education in New Zealand and what are the implications to implementing a rangatiratanga model in mainstream Early Childhood Education?” He Kupu, Vol. 5, No. 2, at hekupu.ac.nz.

29: Haar, J M, Roche, M, Brougham, D (2019), “Indigenous Insights into Ethical Leadership: A Study of Māori Leaders”, Journal of Business Ethics, 160:621–640.

30: Hawkins, C (2017), “How does a Māori leadership model fit within current leadership contexts in Early Childhood Education in New Zealand and what are the implications to implementing a rangatiratanga model in mainstream Early Childhood Education?” He Kupu, Vol. 5, No. 2, at hekupu.ac.nz.

31: Macaulay, M (2020), “Towards a New Public Ethics”, Policy Quarterly, Vol. 16, No. 1, pages 37-42.

32: See LRN Corporation (2024), Benchmark of Ethical Culture 2024: Unveiling the link between company culture, misconduct, and risk, at lrn.com.

33: Brown, A J et al (2019), Clean as a whistle: A five-step guide to better whistleblowing policy and practice in business and government.

34: See Te Kawa Mataaho Public Service Commission (2022), Acting in the spirit of service: Speaking up (the speaking up model standards), at publicservice.govt.nz.

35: For example, bullying or harassment combined with wrongdoing.

36: See Ministry of Social Development (2023), He tūtohu nā Ngā Mātanga Māori: Advice from the Māori Advisory Group, at msd.govt.nz.

37: Brown, A J et al (2019), Clean as a whistle: A five-step guide to better whistleblowing policy and practice in business and government.

38: Brown, A J et al (2019), Clean as a whistle: A five-step guide to better whistleblowing policy and practice in business and government.

39: See Te Kawa Mataaho Public Service Commission (2022), Acting in the spirit of service: Speaking up (the speaking up model standards), at publicservice.govt.nz.

40: Brown, A J et al (2019), Clean as a whistle: A five-step guide to better whistleblowing policy and practice in business and government. This study found that more than 80% of staff who raised concerns about workplace wrongdoing reported that they experienced some negative repercussions.

41: Brown, A J et al (2019), Clean as a whistle: A five-step guide to better whistleblowing policy and practice in business and government.

42: Brown, A J et al (2019), Clean as a whistle: A five-step guide to better whistleblowing policy and practice in business and government.

43: Sometimes it might also be appropriate for organisations to consult with other parties they have important relationships with, who can provide an external perspective of how integrity is being demonstrated.

44: See “Integrity and conduct” at publicservice.govt.nz.

45: See the Local Government Act 2002.

46: National Anti-Corruption Commission (2023), Towards Integrity Maturity – Mapping the Commonwealth integrity landscape: Commonwealth Integrity Maturity Framework, at nacc.gov.au.

47: The Public Service Commissioner has issued model standards on a range of topics, including positive and safe workplaces, workforce assurance, speaking up, conflicts of interest, information gathering and public trust, and chief executive gifts, benefits, and expenses.

48: The employee life cycle is a human resources model that identifies the different stages an individual moves through in an organisation, as well as the role human resources teams plays in that progress.

49: For more information, see Eccles, A, Newton, E, and Shaw, H (2013), Performance with integrity – Linking performance to values: A toolkit, at cityhr.co.uk.

50: See “Get the right fit for your team with values-based recruitment” at recruitit.co.nz.

51: See, for example, the Te Ātiawa publication Ngā Pakiaka o Te Ātiawa Taranaki Whānui, Whitiki Herepū to support adoption of Te Ātiawa kawa (protocol) across the Wellington public service.

52: See, for example, “Creating a Positive Exit Experience” at eqconsultants.co.nz.

53: It is important to clearly identify which issues in your organisation are considered “integrity breaches” and covered by your integrity adviser or unit. Not all employment issues, for example, will be integrity breaches.

54: Taylor, A (2017), The Five Levels of an Ethical Culture: How to build and sustain organizations with integrity (working paper), at bsr.org.

55: Australian Public Service Commission (2022), Integrity Metrics Resource, at apsc.gov.au.

56: Australian Public Service Commission (2022), Integrity Metrics Resource, at apsc.gov.au.

57: This should include consideration of Māori data governance expectations and obligations that might apply. See kahuiraraunga.io.