Part 4: Approaches for monitoring organisational integrity

Monitoring integrity in public organisations.

There is no single right or wrong process for monitoring organisational integrity. Because each organisation is different, what works best for one organisation might not be effective for another.

As you gather more data and deepen your understanding of integrity in your organisation, your integrity monitoring programme is likely to evolve. Over time, you might find that you need different approaches to monitoring as your organisation’s integrity practices mature. It is important to be flexible and remain open to continuous improvement through feedback and iteration.

Start simple and build over time

Monitoring organisational integrity isn’t all or nothing – it can be built up over time. It might feel unfamiliar or different from other governance activities, but what is important is to begin.

All public organisations are unique in their context and operating environment, so different public organisations might approach monitoring in different ways. Integrity indicators that provide rich data for one organisation might not provide relevant insights for another.

Over time, you might find that some indicators are less effective than you expected. You might also find that new areas of focus emerge and that you need to adjust your data collection and monitoring practices.

Additionally, all public organisations are at different stages in their maturity in monitoring integrity. The goal should be managing integrity over the long term rather than implementing a comprehensive programme immediately.

The approaches we set out and the examples we include in this Part are not designed to be followed to the letter. Rather, we present them to encourage thinking and discussion. You should tailor them, combine elements, or use alternative approaches based on your organisation’s unique circumstances.

Carry out a data review

A place to start is to review the data that is already available within your organisation. This involves taking stock of existing data sources to build an understanding of what aspects of integrity you are already monitoring and where gaps might exist. Many organisations already collect useful data for operational or compliance purposes that could serve as integrity indicators (for example, incident reports, audit results, and employee feedback).

Understanding what data is available in your organisation means you can compare it against the integrity risks that have already been identified for your organisation. This process can help create a matrix of information to identify where you might need to monitor additional integrity indicators and where data gaps could present integrity risks.

Reviewing these data sets can help to identify which areas of integrity you are already tracking, where you might need additional indicators, and how different parts of your organisation contribute to your overall monitoring of integrity. Different teams might collect data that is relevant but is not centrally shared or analysed, so this process could also involve bringing together different parts of your organisation to share information.

A data review could include commonly available information, such as:

  • the number and type of complaints raised through whistleblowing mechanisms;
  • themes from exit interviews relating to organisational culture and behaviours;
  • internal audit findings on compliance with policies or procedures;
  • patterns in staff turnover, particularly in high-risk areas;
  • results from employee engagement surveys focused on workplace culture and behaviour; and
  • investigations into conflicts of interest or procurement practices.

For example, data collected from staff exit interviews and employee engagement surveys might give an indication of:

  • common themes relating to staff satisfaction or dissatisfaction with organisational culture, such as issues with leadership transparency or workplace fairness; and
  • patterns of turnover in specific teams or departments, which might point to areas where integrity-related challenges are present.

Alternatively, a review of audit findings and complaints raised through whistleblowing mechanisms could indicate:

  • areas of non-compliance with internal procedures, which might reflect broader cultural issues within your organisation; and
  • the frequency and nature of reported incidents, providing a snapshot of how effectively certain integrity mechanisms, such as reporting systems, are functioning.

Through this review, you might identify gaps – for example, that you lack qualitative data on the reasons behind staff turnover, or that you do not monitor certain highrisk areas enough. These gaps could inform your selection of additional integrity.

Over time, you might look to refine your integrity indicators to adapt to new risks or emerging trends so that your monitoring programme evolves as your organisation’s integrity practices mature.

Carry out a ‘deep dive’ into an existing process

Carrying out a ‘deep dive’ into an existing process involves thoroughly examining a familiar procedure to uncover existing data that you could use for integrity indicators. The approach can provide valuable insights into a process without the need to develop extensive new systems for collecting data.

What might initially appear as a single data set – such as code of conduct compliance records – can actually be a rich source of information when examined more closely. Patterns and trends might emerge from a deep dive into the data available from code of conduct reports that you can use to identify areas of concern or track changes in organisational integrity.

For example, data collected from code of conduct compliance reports will often give an indication of:

  • the total number of reports over a period – tracking the number of reports about code of conduct breaches might indicate how engaged with, and aware of, conduct issues employees are and how closely they follow the code of conduct; and
  • the types and seriousness of reports – categorising reports by type (for example, harassment and fraud) and severity might help you identify prevalent issues and high-risk areas in your organisation.

However, analysing the available data more deeply could provide additional insights into:

  • the culture of reporting – tracking the number of reports by business area might indicate a strong reporting culture in some areas of the organisation and areas where conduct breaches are not being reported as effectively;
  • the number and types of investigations – monitoring the number and nature of investigations you launch can provide insights into the prevalence of particular issues and where you might need to focus attention;
  • the appropriateness of investigation outcomes – evaluating the results of investigations can indicate the effectiveness of your organisation’s investigative processes and whether they lead to appropriate resolutions;
  • the timeliness and efficiency of investigations – tracking how long investigations take can indicate procedural efficiency and responsiveness, which are important for maintaining trust; and
  • the suitability of investigation resource – analysing whether investigations are adequately staffed and resourced might provide insights into the efficacy of investigations and the workloads of team members.

The data from a deep dive into a process might highlight issues that require further exploration. For instance, if you discover that investigations into code of conduct breaches are taking longer than expected, you might need to turn to other integrity indicators to understand why this is happening. This could involve adding a new integrity indictor to your monitoring programme to gather data to help you understand the factors that impact the process, such as staff training or procedural bottlenecks.

Focus on key organisational values

Another approach to monitoring integrity is to focus on a visible demonstration of integrity within your organisation, such as being transparent, accountable, and fair. Many organisations prioritise these values, and they can provide a useful starting point for identifying integrity indicators.

By selecting a key value, you can tailor your integrity monitoring practice to focus on behaviours and practices that demonstrate how your organisation is upholding that value.

Engage staff in your approach to monitoring organisational integrity

Focusing on organisational values provides an opportunity to engage
staff in your integrity monitoring programme.

Staff often have direct insights into how they experience organisational values in their day-to-day work. Gathering input through surveys, focus groups, or informal discussions can help to identify relevant integrity indicators that leadership might not have initially considered.

For example, if accountability is a central value for your organisation, you could monitor integrity indicators that focus on how decisions are made, communicated, and owned by these responsible. For example:

  • The quality of accountability mechanisms: Feedback on how frequently and thoroughly decision-makers communicate the rationale behind their decisions can provide insight into how transparent and accountable leadership is in practice.
  • The impact of restorative actions: Monitoring whether corrective actions are taken in response to performance issues or concerns raised (and the efficacy of these actions) might help to indicate changes in perceptions of accountability over time.
  • Follow-through on commitments: Tracking the percentage of formal commitments made that are delivered on time and as expected might indicate the level of collective accountability within the organisation.
  • Perceptions of leadership accountability: Monitoring results from surveys or interviews that ask staff and stakeholders how they feel about accountability in decision-making can provide insights into how accountability in leadership is viewed.

Alternatively, if your organisation focuses on investing in relationships, it might be valuable to look at integrity indicators that monitor how well relationships are built and maintained. For example:

  • Frequency of engagement opportunities: Evaluating the number of formal and informal engagement opportunities between leadership, staff, and external stakeholders can provide insights into how effectively your organisation is nurturing relationships.
  • Frequency and effectiveness of collaboration: Monitoring the frequency, progress, and success of cross-departmental and cross-agency projects or initiatives can reveal the extent that different areas of your organisation are building and maintaining strong working relationships.
  • Investment in relationship-building resources: Tracking organisational investment in resources for relationship-building activities (for example, team building, community engagement, or staff well-being programmes) might provide an indication of your organisation’s long-term commitment to maintaining strong relationships.
  • Uptake of development and support initiatives: Monitoring the usage of mentorship programmes or membership of employee-led networks can provide some understanding of how effectively your organisation builds and maintains staff relationships.

Report what you do and what you find

Transparency in monitoring processes builds trust within the organisation and with external stakeholders. It is important to communicate your organisation’s commitment to integrity and the measures you are taking to monitor and uphold ethical standards.9

Regularly reporting on monitoring activities and findings is important to maintaining transparency. This can include internal reports to senior leadership and staff, as well as external reports to stakeholders and the public. Reports should highlight key findings, trends, and any actions that you have taken in response to integrity issues.

“We implemented a system for collective integrity reporting across
the organisation. Quarterly reports are prepared by our Professional Standards Team. We include information about incidents, including details about what type of incidents are being investigated and the stage each investigation is at.

“We present all the data we gather as a dashboard using a data visualisation tool. Teams across the organisation then analyse the data – the teams involved in the analysis are our Professional Standards, Security, HR, and Integrity teams. They work together to collate the information and provide a report to senior leadership about what has been happening over the last quarter. The report consists of the dashboard along with an accompanying paper that expands on the data in the dashboard.

“The data allows us to make informed decisions about integrity activities to focus on for the next quarter. We have been gathering data like this for about five years, so it also allows us to go back and look at changes in our integrity performance over time.”

Government department integrity specialist

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.

Engaging stakeholders can help ensure that your monitoring practices are transparent and that they respond to the community’s needs and concerns.10 Consider forming advisory panels with representatives from key stakeholder groups or holding public forums to discuss integrity initiatives and gather feedback.

Review and revise your monitoring programme

Regularly reviewing and revising your monitoring practices is essential for them to remain effective and relevant. This involves:

  • assessing the effectiveness of your current monitoring activities;
  • identifying areas for improvement; and
  • updating your practices to reflect new insights, emerging risks, and changes in organisational priorities.

A proactive approach to reviewing and revising your monitoring programme helps maintain the responsiveness of your monitoring efforts.

The Australian National Audit Office (ANAO) Integrity Framework and Report 2022-23 is a good example of effectively reporting and communicating organisational integrity outcomes.11 The report does more than just list achievements. It provides context for how these outcomes were reached and offers a clear view of what it has accomplished and what still needs attention. This balanced approach helps to make sure that readers get a comprehensive picture of both successes and ongoing challenges.

The report also integrates performance metrics with strategic plans. By showing how the results of monitoring activities inform future actions, the ANAO demonstrates that it has a dynamic approach to performance management. This alignment between data and planning helps to provide assurance that integrity activities respond to new challenges.

The report also emphasises accountability and details who is responsible for implementing the next steps. This not only enhances the report’s credibility but also clearly demonstrates that the ANAO follows through on the commitments it has made.

Finally, the report highlights a strong commitment to engaging with stakeholders. By explaining how the ANAO will involve different parties in its future steps, the report fosters a sense of shared responsibility and openness. This inclusive approach not only strengthens the ANAO’s integrity practice but also builds broader support for its initiatives, making everyone feel part of the journey.

9: Lamboo, T and Hoekstra, A (2015), “The Netherlands: Developments in Monitoring Integrity in Public Administration”, in Netherlands Ministry of the Interior and Kingdom Relations (2015), Prime witnesses? Case studies of staff assessments for monitoring integrity in the European Union, page 65.

10: United Nations Development Programme (2023), Integrity and Ethics Agency Improvement Framework, at undp.org.

11: Australian National Audit Office (2023), “ANAO Integrity Framework and Report 2022–23”, at anao.gov.au.