Part 3: Developing an effective integrity monitoring programme
In this Part, we outline five practices that support an effective integrity monitoring programme.
These practices are guiding principles rather than specific measures or metrics. They are designed to help you approach integrity monitoring in a way that is thoughtful, structured, and tailored to your organisation’s unique context.
Five practices for an effective integrity monitoring programme
Each of these practices is explored in detail in the following sections, providing guidance to help you apply them to your organisation’s integrity monitoring programme.
Strengthen organisational connections
Effective monitoring goes beyond simply collecting and analysing data. You need a deep understanding of your organisation’s context, which includes the human elements that shape your organisation’s culture. Engaging with employees, promoting open dialogue, and building trust are essential to this process.
Strong relationships are essential at all levels of an organisation – between peers, across hierarchies, and within teams – to gather the information that effective monitoring practices need. Leaders set the tone for organisational integrity by modelling ethical behaviour and fostering trust. The behaviour of an organisation’s leaders can significantly affect how people in the organisation perceive integrity.
You can read more about the impact of leadership on organisational integrity in Part 4 of Putting integrity at the heart of how public organisations operate.
Similarly, people responsible for monitoring organisational integrity need strong relationships with senior leaders and governors to effectively communicate integrity matters and address them appropriately. They also need to be approachable and trusted by staff – a lack of strong, trust-based relationships will limit your ability to gather the information you need to monitor integrity effectively.
“We use the Hudson Safety Culture Model to understand our health and safety culture.5 We also use the International Organization for Standardisation (ISO) to understand our progress in psychological health and safety. Our People & Culture Team do their best to track and monitor changes in these areas.
“Our ‘speak up’ processes are embedded into our approach to health, safety, and well-being. Psychological safety in particular is being embedded across the organisation, including in the leadership stream. In our view, speaking up isn’t just about speaking up when you become aware of a serious issue, like fraud. We encourage our people to speak up about any concerns they may have, even minor ones.”
Local authority integrity specialist
Use a diverse range of meaningful integrity indicators
Because organisational integrity is an abstract quality that reflects ethical culture and behaviour within an organisation, it cannot be directly quantified. However, it can be inferred by examining aspects of organisational culture, metrics, and behaviours that reflect an organisation’s integrity. These aspects – or “integrity indicators” – can provide insights into how integrity manifests within the organisation.
Using a diverse range of integrity indicators can help you to get a more comprehensive understanding of your organisation’s integrity. This can help you to make sure that your monitoring processes capture data that is directly measurable, as well as data that provides insight into underlying cultural influences.
“We have talked about organisational integrity in our agency for quite some time, but we have only recently started to identify suitable integrity indicators and carry out monitoring activities.
“We wanted to understand how our people felt about the ways we work as an organisation. In particular, we wanted to understand whether there was a difference between how our senior leaders view our ways of working compared to how staff view our ways of working.
“We ran online and in-person workshops to gather data from our people about the way we work. The workshops involved participants rating our organisation against statements about ways of working (for example, how effectively our organisation is aligned with its vision, values, and expected behaviours and how inclusive our workplace culture is). Participants also had the opportunity to provide comments on why they chose a particular rating.
“When we analysed the results, we noticed that there were some differences between how our senior leaders view our ways of working compared to how our staff view our ways of working. We also noticed that the comments made were aligned with the results of our most recent staff survey.
“Something that came up as a theme was that our people felt that raising concerns could be easier. We will be putting training in place for people leaders over the next 12 months, which will include developing skills in building relationships and trust with staff.”
Non-public service department senior leader
Select meaningful integrity indicators
When thinking about the integrity indicators to include in your monitoring processes, it is important to consider what makes an integrity indicator meaningful. You need to have a good understanding of your organisation’s culture and the context that it operates in.
For any integrity indicator you select, there should be a balance between precision and practical measurability. Think about the metrics that can be plausibly measured in your organisation, then consider what insights these metrics can provide about individual, organisational, and professional integrity.6
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What is a meaningful integrity indicator?To select meaningful indicators to monitor organisational integrity, you need to carefully consider what each metric signifies in your organisation’s context.
The following are some points to consider when selecting integrity indicators:
Context
Understanding cultural nuances in your organisation can help you to make sure that the selected indicators provide meaningful insights. Contextual factors inside the organisation and its operating environment can affect the effectiveness of integrity indicators.
Relevance
Integrity indicators should be directly related to the specific areas of integrity you aim to monitor. Indicators should be informed by your organisation’s unique context (for example, compliance with regulations, decision-making, stakeholder relationships, or transparency in operations).
Reliability
Integrity indicators should provide consistent and accurate data over time. Reliable indicators are more likely to provide information that you can depend on to inform decisions and track integrity trends.
Actionability
Select indicators that can inform decision-making and that can give insights that lead to plausible actions. Indicators that do not directly lead to actions should still offer insights that support strategic planning and decision-making, helping to maintain and improve integrity within your organisation.
Use indicators that provide a mix of quantitative and qualitative data
Using a combination of quantitative and qualitative indicators provides a more complete view of integrity within your organisation.7
Quantitative data provides measurable and objective insights, while qualitative data offers context and depth, helping to understand the nuances behind the numbers.
Quantitative data can be used to assess trends in compliance metrics, such as the number of reported incidents, audit results, staff turnover, and survey scores. These data points can help measure changes in compliance over time and provide a partial picture of your organisation’s integrity performance.
It can be easy to equate high levels of organisational compliance with high levels of integrity. However, quantitative data alone might not reveal the underlying causes of integrity issues or the cultural factors influencing behaviour. To see the full picture of organisational integrity effectively, you need to go beyond compliance and look at qualitative data to understand behaviours.
Qualitative data includes employee feedback, interviews, focus groups, and case studies. This type of data helps you to uncover the reasons behind certain behaviours and attitudes. It provides a richer understanding of your organisational culture and the reasons for changes in organisational integrity.
By combining integrity indicators that provide quantitative and qualitative data, you will be better able to:
- understand changes in organisational integrity over time;
- pinpoint areas for improvement; and
- develop plans for improvement.
“Our agency uses a combination of quantitative and qualitative indicators for integrity monitoring. We gather quite a lot of data through our quarterly reports. This includes investigations, exit interview data, results from staff surveys, and speak-up notifications. We also gather anonymised information from employee support services to understand the underlying factors affecting workplace relationships.”
Government department integrity specialist
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Ensure clear accountabilities for your integrity monitoring programme
Effective monitoring needs clearly defined roles and responsibilities. Assign specific duties to individuals and teams so that everyone understands their part in the process.
Assign clear roles and responsibilities
The people you select to carry out monitoring should have strong analytical skills, cultural awareness, and the ability to engage with all employees. Effective communication and interpersonal skills are essential for gathering accurate and honest feedback.8
The people responsible for monitoring organisational integrity should also have strong connections with those in leadership and governance positions. These connections help to make sure that conversations about organisational integrity are sustained and that integrity-related insights inform decision-making.
Each group or individual should have clearly outlined responsibilities, whether it’s collecting data, analysing trends, or implementing corrective actions. This helps to ensure that all aspects of monitoring are systematically addressed, preventing gaps and overlaps.
You can read more about the importance of clear roles and responsibilities for organisational integrity in Part 4 of Putting integrity at the heart of how public organisations operate.
Dedicate resources to your integrity monitoring programme
Creating a formal structure to monitor organisational integrity – such as a committee, working group, or an integrity team – can also help co-ordinate efforts and give monitoring the appropriate priority. Any groups tasked with monitoring integrity should include representatives from different parts of the organisation to provide diverse perspectives and comprehensive oversight.
“In our agency, there are a lot of integrity matters to think about. These include internal workplace matters, integrity risks with the services and regulatory functions we are responsible for, and ongoing relationships with third party vendors.
“Integrity practices were present in our agency, but our integrity and compliance monitoring activities were quite fragmented. This was partly because we didn’t have dedicated leadership for organisational integrity. “An important starting point for our organisational integrity work was creating a centralised integrity team. This ensured that we had dedicated resource to focus on integrity in our organisation.
“One of the first things our integrity team was tasked with was carrying out thorough risk assessments. This involved breaking down siloed approaches to risk management and focusing on top risks (for example, procurement processes, conflicts of interest, and the handling of sensitive information). Having a centralised integrity function made it much easier to identify key integrity risks in these areas.
“Having a centralised integrity function in place allowed us to prioritise and allocate resource more effectively, informed by our knowledge of risks and incidents. This approach increased the risk and assurance maturity of the organisation and helped inform changes to make our processes more integrated and user-friendly.”
Crown entity integrity specialist
Communicate the value of monitoring organisational integrity
Integrity issues should be recognised as critical to your organisation’s success and given attention at the highest levels of leadership. This is important because it integrates ethical considerations into strategic decision-making, enhances public trust, and ensures that integrity initiatives can be sustained.
However, elevating the status of monitoring can be challenging. Securing buy-in from leaders and decision-makers might need a shift in organisational culture.
Leaders should actively engage in and support integrity efforts, and everyone in the organisation has a role in reinforcing this commitment. Effectively communicating your monitoring activities can help to reinforce the importance of improving organisational integrity. Effective communication includes:
presenting data and insights in a way that resonates with the recipient – for example, by linking integrity risks and trends to possible impacts on operational effectiveness;
emphasising how monitoring aligns with your organisation’s strategic objectives and long-term goals;
sharing examples of where integrity initiatives have led to significant improvements from within your organisation or from other organisations; and
framing integrity reporting in the context of your organisation’s purpose and values to highlight the intrinsic value of integrity beyond compliance and risk management.
“We put in place ongoing monthly conversations at the senior leadership level to reinforce ethical practices, especially after the disruptions caused by the Covid-19 pandemic. In our organisation, discussing integrity issues regularly is valued highly. We incorporate these discussions into our quarterly meetings as well.”
Government department integrity specialist
Commit to continuous monitoring
Monitoring organisational integrity is not a one-time activity but an ongoing cycle that enhances your understanding of organisational integrity over time. The more frequently and effectively you monitor, the better you can understand how integrity in your organisation changes.
Understanding the impact of interventions to improve integrity is essential – you should plan integrity interventions with evaluation and monitoring in mind.
Determine a suitable time frame for monitoring
Regularly collecting data allows you to monitor trends in integrity performance over time. This supports benchmarking and evaluation of integrity performance against previous levels. It also helps to make sure that monitoring remains an ongoing priority and that any issues are promptly identified and addressed.
More frequent monitoring might be needed for high-risk areas or critical indicators. This allows you to rapidly detect and respond to integrity breaches. For other areas, quarterly or biannual reviews might be enough to track progress and identify trends.
A balanced approach to monitoring includes both short-term and long-term perspectives. Combining short-term and long-term monitoring gives you a holistic understanding of integrity within the organisation.
“Our agency wanted to move away from a compliance-based approach towards a culture that integrated integrity into everyday practices.
“We developed a communication plan, leveraging the support of our senior leader to reinforce the importance of integrity. We also held competitions and provided recognition for teams excelling in integrity practices and used external examples to illustrate the importance of integrity and the consequences of lapses.
“In our agency, it is important that we can recruit people with experience in the public sector as well as hands-on experience in the industry. Having people who understand the industry, with experience working for industry contractors, is a strength. However, it gives rise to integrity risks from conflicts of interest. We have to protect our people from this risk – not just our Board and executives but everyone.
“Continuous monitoring and awareness of organisational integrity has been key for us in this area. As part of our monitoring, we talked to a lot of our people about conflicts of interest, and many would say that they don’t have any. This prompted us to change the language of our policy from a Declaration of Conflicts Policy to a Declaration of Interests Policy. Our priority is that our people disclose everything so that we can protect them. We have been clear that the obligation is to declare all interests – including relationships.”
Crown entity integrity specialist
Collect and use data responsibly
Public sector organisations must handle data with the utmost care to protect security and privacy, maintain trust, and uphold ethical standards.
By protecting the mana and integrity of data, organisations can foster a deeper level of trust and engagement with their stakeholders.
Use data with care
Public sector organisations must comply with all relevant data protection and privacy laws. Ensuring legal compliance not only protects the organisation from legal repercussions but also demonstrates a commitment to ethical standards.
Using data responsibly involves protecting data – but also making sure that you use it ethically and effectively to inform decision-making and promote integrity.
In many cultures, data is not just information. It carries significant cultural and personal importance. In Māori culture, data can be considered taonga, and its protection is paramount.
To respect and protect the mana of data, you should:
- recognise and respect the cultural significance of the data and engage with cultural advisors to align your data practices with cultural values where appropriate;
- collect, store, and use data in ways that honour your legal obligations and the trust that individuals and communities have placed in your organisation; and
- act as ethical stewards of the data, recognising its importance and handling it with the highest level of integrity and respect.
Maintain staff trust and confidence
Maintaining staff trust and confidence is essential for monitoring to be effective. Staff are more likely to engage with integrity processes when they trust that their data will be used responsibly and not punitively.
In an organisation where employees feel safe to report issues, the data collected to monitor organisational integrity is more likely to be accurate andcomprehensive. Having processes that are trustworthy and supportive can help make sure that employees provide honest and detailed feedback. High levels of staff engagement can also lead to richer data and more insights, improving the quality of monitoring.
Organisations with high levels of integrity take the feedback they receive seriously and act on it in a way that is visible to employees, leading to continuous improvement. When employees see that their feedback leads to meaningful changes, they are more likely to continue participating in integrity initiatives.
Use the data you collect to identify areas for improvement and support a positive organisational culture. Provide clear assurances that individual data will be kept confidential and used solely for integrity purposes. This can encourage more open and honest reporting from staff.
“We consider all data as taonga and some data tapu. Our staff are passionate about their work, and we have focused on translating this passion into better data practices. We make sure that data is handled responsibly and ethically, including securing data and maintaining privacy. This approach has enhanced trust and integrity within the organisation.”
Public sector trust senior leader
5: The Hudson Safety Culture Model (or Hudson Ladder) plots the development of an organisation’s safety culture.
6: See David-Barrett, E and Zinnbauer, D (2022), “Measuring integrity for better understanding and tracking corruption”, at iaca.int.
7: Van Dooren, W (2009), “Integrity in government: Towards output and outcome measurement”, Organisation for Economic Co-operation and Development.
8: See Fréchette, P and Warah, A (2020), Auditing organisational culture in the public sector, Canadian Audit & Accountability Foundation, at caaf-fcar.ca.