Sector profile

• Clear COI policy framework that identifies perceived, potential or actual conflicts of interest, and how it is to be managed by staff and managers, including in relation to private interests that could be impacted by decisions being made by the agency
• Ensure staff are informed and familiar with how to declare COI, and make a declaration easy, fast and accessible
• Conduct mandatory and regular training and awareness raising for employees and contractors, including training private sector employees in the public service’s integrity frameworks
• Require all employees and contractors to provide written acknowledgement that they understand their organisation’s COI policy, potentially through contracts for service and service agreements
• Clear gifts, benefits and hospitality policies and procedures that contain case studies and examples to improve understanding of risks, including raising awareness of private sector employees of the risks of offering or accepting offers
• Discourage any gifts, benefits and hospitality from current and prospective suppliers
• Take proactive measures (for eg, audits and surveys) to ensure staff are aware of, and understand, relevant policies
• Strengthen recruitment and promotion processes and policies to more effectively identify and manage COI
• Increase awareness and compliance around declaring COI in procurement
• Effective probity frameworks (for example, managing the conflicts of interest that can arise from use of consultants, management of incumbent providers, and conflicts arising from senior executives being employed directly from or resigning for employment opportunities with the private sector).

• Conduct regular and random audits to ensure compliance with procurement policies and procedures, and ensure any conflicts of interest are reported and then managed
• Electronic procurement systems with internal controls preventing the processing of invoices until details regarding quotes are entered into the system.

• Monitor variations in contracts and ensure variations are approved by the appropriate financial delegate
• Purchase orders to be raised before receipt of an invoice, unless exceptional circumstances apply, and monitor that this practice is occurring
• Invoices must contain sufficient information before being paid, and goods and services must be received before being paid
• Undertake regular and random audits to ensure the veracity of invoices and identify unusual transactions
• Segregate duties at various stages of the procurement process (For eg, different people initiate procurement, approve, and receive goods/services)
• Ensure compliance with segregation to ensure it has not lapsed into an administrative process
• Undertake audits to ensure goods and services have been ordered, delivered and invoiced appropriately
• Use of effective contractual provisions to manage fraud and corruption risks to the Victorian Government. For example, should contracts require the service provider to have reasonable fraud detection & prevention measures; effective responses to when fraud incident occurs; mechanisms for service provider to notify the Department or other parts of the public sector in the event of a fraud incident; indemnity provisions; rights to audit; back-to-back provisions in their subcontracting arrangements.
• Due diligence over third parties, service providers and key subcontractors. Public sector agencies can go further than examining financial and operational capability of providers and contractors to provider services for the Victorian community, and can examine the practices and processes that contractors have in place for governance, risk management, ethics and compliance reporting, employee hiring practices. 
• Ways to effectively communicate the public sector’s integrity expectations with service providers including, but not limited to, compliance with the Supplier Code of Conduct. 
   

• Increased training and awareness of information security risks, including a focus on how information can be misused and for what illegitimate purposes
• Review procedures for preventing and detecting information misuse
• Regular and proactive audits of employees’ access of information systems
• System users must record a reason for accessing (or altering) sensitive information
• Ensure maintenance of appropriate information security controls, and that staff do not share log-on and password details
• Use of data analytics to provide intelligence as a fraud prevention measure as well as for fraud detection.

Integrity Governance 

• Key principles
  • Fraud and Corruption and Integrity Frameworks report to a governing body
  • Specialist fraud and corruption resources including information and data security
  • Structure and policy elements of an integrity culture
  • Raising awareness of integrity issues
  • Setting guidelines for learning and sharing feedback internally and externally 
• Key actions
  • Integrity oversight by Audit, Risk and Integrity Committee and DTP Senior Leadership Team
  • Fraud and Corruption Control Framework Assessment
  • Data analytics projects
  • Integrity maturity Assessment survey

Culture

• Key principles
  • Leaders are expected to personally act with integrity
  • Leaders take an active role in promoting a positive tone at the top through words and actions
  • DTP’s values and standards are communicated effectively through many channels
• Key actions
  • Integrity Framework (released March 2021)
  • Integrity Framework Governance Toolkit released
  • Fraud and corruption control framework
  • Data and Security Management Framework
  • eProcurement Source to Contract tool

Policy and Program Management

• Key principles
  • Post-investigation reviews
  • Analysis of management actions
  • Identifying of early warning signs
  • Data analytics functionality
  • Leveraging relationships with internal business leaders and external parties
• Key actions
  • New Declaration of Private Interests (released October 2022)
  • Conflict of Interest Policy
  • Gifts, Benefits and Hospitality Policy
  • Official Business Events Policy
  • New Outside Employment Policy (released March 2021).

Intelligence and outputs

• Key principles
  • Leaders are held accountable for compliance with integrity frameworks
  • Leaders participate in action planning to respond to risks, trends and key cases
  • Appropriate disclosures are made to regulatory and integrity agencies 
• Key actions
  • Integrity Masterclass for newly appointed Executive Officers
  • Mandatory Information Management, Professional Conduct and Integrity eLearning modules
  • Compliance and Mandatory Reporting obligations

Accountability

• Key principles
  • Immediate action in response to discovery of fraud and corruption
  • Promotion of integrity reporting channels internal and external to DTP
  • DTP creates a speak-up culture that measured and managed
  • Leaders respond to issues raised and employee feedback is welcomed
• Key actions
  • Dedicated ‘Speak Up’ intranet page
  • Integrity Matters staff newsletter
  • Transport Sector – Community of Practice
  • People Matters Survey