code of conduct guidelines - Department of the Environment

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CODE OF CONDUCT GUIDELINES
Purpose
These guidelines provide Department of the Environment (the Department) employees with
essential information about the Australian Public Service (APS) Values, Employment
Principles and Code of Conduct and guidance on some of the more common ethical issues
often encountered by APS employees during the course of their APS duties.
These updated guidelines replace the previous 2013 departmental policy document titled
‘DSEWPaC Code of Conduct Guidelines’.
To obtain a full picture of your responsibilities and rights under the Department’s Conduct and
Ethical Behaviour Framework, this policy document should be read in conjunction with relevant
Chief Executive Instructions (CEI’s), Departmental Instructions and departmental policies
available on the Department’s Intranet including:

Procedures for Suspected Breaches of the APS Code of Conduct

Public Interest Disclosure Procedures

Allegations of Fraud & Criminal Behaviour by Departmental Employees

Workplace Respect Policy.
Who does the Code of Conduct Guidelines apply to?
The Code of Conduct Guidelines applies to all individuals who are employed by the
Department under the Public Service Act 1999 including:

ongoing employees

non ongoing employees.
Contractors to the Department, such as Datacom employees, are not automatically covered by
the APS Code of Conduct. However, where a contractor is delivering services on behalf of the
Department, or is working on departmental premises, it is a requirement that all contractors
behave in a way which is consistent with the APS Code of Conduct, regardless whether this
clause has been included in their individual contract or not.
Further assistance
More information on the APS Code of Conduct, APS Employment Principles and the APS
Values is available from the Workplace Behaviour and Conduct Unit located in the John
Gorton Building, Parkes, Canberra ACT and from the Australian Public Service Commission
website www.apsc.gov.au and the Ethics Advisory Service.
Conduct & Ethical Behaviour Framework
The following table describes the major elements of the Department's Conduct and Ethical
Behaviour Framework.
Title
Description
Code of Conduct Guidelines
Provides information about the standards of behaviour
required under the APS Values, Employment Principles
and Code of Conduct as well as guidance on some of
the more common ethical issues often encountered by
APS employees during the course of their APS duties.
Procedures for Suspected Breaches of Provides information about the process and procedures
the APS Code of Conduct
for investigating alleged and/or suspected breaches of
the APS Code of Conduct, including:
• how alleged breaches of the Code are handled
• the sanctions that can be applied
• employee’s rights if they are alleged to have
breached the Code.
Allegations of Fraud & Criminal
Behaviour by Departmental Employees
Provides information, processes and procedures for
investigating allegations of Fraud and/or suspected
criminal behaviour by departmental employees in the
course of their APS duties.
Public Interest Disclosure Procedures
Provides information on:
• what is a ‘public interest disclosure’
• who is covered by the Public Interest Disclosure
Procedures
• the types of conduct that can be disclosed under the
Department's Public Interest Disclosure Procedures
• protection for disclosers
Workplace Respect Policy
Provides information on appropriate workplace
behaviours and the Department’s commitment to a
workplace free of bullying and harassment.
Public Service Act 1999
Legislation governing the establishment, operation of
and employment in the APS including the APS Values,
Employment Principles and the APS Code of Conduct.
Public Service Regulations 1999
Australian Public Service
Commissioner’s Directions 2013
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APS Values
The five APS Values and their corresponding Employment principles are found at sections 10
and 10A of the Public Service Act 1999 and are legally enforceable under the APS Code of
Conduct found at section 13. At their core, the APS Values are about relationships and
behaviours. In the APS we are responsible for the way we work with the Government and the
Parliament, with the public and each other. We are also required to maintain the highest
ethical standards.
We are different from other employees providing services in the market-place, in that we
exercise authority on behalf of the Government and the Parliament, acting for the public. The
public rightly expects high performance and standards of personal behaviour. The APS Values
are not simply aspiration statements of intent. All APS employees are required to uphold the
APS Values and failure to do so may attract sanctions.
Each of the APS Values is supported by a short statement that expands and clarifies its intent.
The Values are as follows:

Impartial: The APS is apolitical and provides the Government with advice that is
frank, honest, timely and based on the best available evidence

Committed to service: The APS is professional, objective, innovative and efficient,
and works collaboratively to achieve the best results for the Australian community and
the Government

Accountable: The APS is open and accountable to the Australian community under
the law and within the framework of Ministerial responsibility

Respectful: The APS respects all people, including their rights and their heritage

Ethical: The APS demonstrates leadership, is trustworthy, and acts with integrity, in
all that it does
The importance of the APS Values
The APS aspires to be among the best in the world—a Service that is recognised and valued
because its people:

take the extra steps necessary to ensure that the needs of the Australian community
are identified and met

are forward looking and innovative

work together and with the community to meet community needs

deliver effective programs and excellent service with maximum efficiency, and so
provide great value for money.
Fundamental to the achievement of these goals is the set of attitudes and behaviours that APS
employees bring to their work. The APS Values, together with the APS Employment
Principles, define the APS as an institution, and guide it in its dealings with everyone and in
everything it does. Behaviour consistent with the APS Values strengthens public trust and
confidence in public administration, and provides a secure foundation to guide the APS into
the future.
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The requirements of the law
The responsibilities of APS employees (including SES employees) and Agency Heads are set
out in the Public Service Act 1999 (the Act).
APS employees must at all times behave in a way that upholds the APS Values and APS
Employment Principles (Act, s13(11)).
Members of the SES must also promote the APS Values and APS Employment Principles by
personal example, and other appropriate means (Act, s35(3)(c)).
Agency Heads must uphold and promote the APS Values and APS Employment Principles
(Act, s12).
APS employees and Agency Heads must also comply with all applicable laws, the APS Code
of Conduct and any other requirements prescribed by the Public Service Regulations 1999 or
these Directions (Act, s13(4), s13(13), s14 and s42(2)).
Directions about employment matters relating to APS employees, including the scope and
application of the APS Employment Principles, are dealt with in Chapters 2 to 5 of the
Australian Public Service Commissioner’s Directions 2013 (the Directions).
The application of the APS Values
The APS Values, and the Directions, set out standards and outcomes that are required of APS
employees and Agency Heads, taking account of an individual’s duties and responsibilities. In
this context, Agency Heads have an additional responsibility to take steps to ensure that the
APS Values are promoted in their agency (Direction 1.7).
The APS Values can be applied to the variety of functions undertaken across agencies. For
example, being Committed to Service applies when service is provided to external clients and
the wider community, to other APS agencies, to clients within an agency, or to Ministers and
Government.
The APS Values can overlap, and actions can involve the application of more than one APS
Value. For example, the concept of collaboration is relevant to being Committed to Service as
well as to being Respectful. This overlap is reflected in Direction 1.2, which provides that being
Committed to Service requires supporting collaboration and teamwork, both internally and
externally, and Direction 1.4, which provides that being Respectful requires collaborating and
being open to ideas in policy development and implementation.
Each of the Values is of equal importance. There is no hierarchy of Values. There may be
particular situations where there is tension between the different APS Values that are to be
applied. In such cases, good judgment will need to be exercised to find the appropriate
balance between competing demands.
The Australian Public Service Commissioner issues standards and guidance material for APS
employees and Agency Heads on the practical application of the APS Values, APS
Employment Principles and the Code of Conduct.
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APS Employment Principles
On 1 July 2013 the Public Service Act 1999 was amended to include a new section 10A which
provides for the Employment Principles. The Employment Principles are largely those of the
previous APS Values that relate to employment and workplace relationships.
The Employment Principles are as follows:
The APS is a career-based public service that:
a.
makes fair employment decisions with a fair system of review
b.
recognises that the usual basis for engagement is as an ongoing APS employee
c.
makes decisions relating to engagement and promotion that are based on merit
d.
requires effective performance from each employee
e.
provides flexible, safe and rewarding workplaces where communication, consultation,
cooperation and input from employees on matters that affect their workplaces are
valued
f.
provides workplaces that are free from discrimination, patronage and favouritism
g.
recognises the diversity of the Australian community and fosters diversity in the
workplace.
The APS Code of Conduct
The Australian public expects the highest standards of behaviour from its public servants.
These standards of behaviour are detailed in the APS Code of Conduct in Section 13 of the
Public Service Act 1999.
The APS Code of Conduct forms the legal basis for a Commonwealth Agency taking
disciplinary action against an employee. The APS Code of Conduct is legally enforceable
under the Public Service Act 1999 which at section 15(1) sets out the sanctions that can be
imposed when employees are found to have breached the Code of Conduct.
The following table sets out the 13 subsections of the APS Code of Conduct which all
Departmental employees, including the Agency Head, must comply with.
Subsection Element of the APS Code of Conduct
1
Behaving Honestly and with Integrity
Employees must behave honestly and with integrity in connection with their APS
employment.
2
Acting with Care and Diligence
Employees must act with care and diligence in connection with their APS
employment.
3
Treating Everyone with Respect and Courtesy and without Harassment
When acting in connection with APS employment, employees must treat everyone
with respect and courtesy and without harassment.
5
Subsection Element of the APS Code of Conduct
4
Complying with all applicable Australian Laws
When acting in connection with APS employment, employees must comply with
all applicable Australian laws.
5
Complying with Lawful and Reasonable Directions
Employees must comply with any lawful and reasonable direction given by
someone in the employee’s agency who has authority to give the direction.
6
Maintaining Confidentiality with Ministers or their Staff
Employees must maintain appropriate confidentiality about dealings that the
employee has with any Minister or Minister’s member of staff.
7
Disclosing and Avoiding Conflicts of Interest
Employees must disclose and take reasonable steps to avoid, any conflict of
interest (real or apparent) in connection with APS employment.
8
Use of Commonwealth Resources
Employees must use Commonwealth resources in a proper manner.
9
False or Misleading Information
Employees must not provide false or misleading information in response to a
request for information that is made for official purposes in connection with the
employees APS employment.
10
Improper Use of Inside Information or an Employee’s Duties, Status, Power or
Authority
Employees must not make improper use of:
•
or
inside information
•
the employee’s duties, status, power or authority
in order to gain, or seek to gain, a benefit or advantage for the employee or for
any other person.
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Upholding the APS Values and the Integrity and Good Reputation of the APS
Employees must at all times behave in a way that upholds the APS Values and
APS Employment Principles and the integrity and good reputation of the
employee’s agency and the APS.
12
Upholding the Good Reputation of Australia while on Duty Overseas
While on duty overseas, employees must at all times behave in a way that
upholds the good reputation of Australia.
13
Complying with other Conduct Requirements
APS employees must comply with any other conduct requirement that is
prescribed by the regulations. At present there is only one additional conduct
requirement prescribed in the regulations: Regulation 2.1 – Duty Not to Disclose
Information
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Roles and Responsibilities
Employees
It is a statutory obligation for all departmental employees to ensure that they:

familiarise themselves with the APS Values, Employment Principles and the Code of
Conduct

fully comply with the requirements of the APS Code of Conduct.
Regulation 3.16 of the Public Service Regulations 1999 requires that each APS employee
must inform himself or herself about the Public Service Act 1999, the Public Service
Regulations 1999 and the Australian Public Service Commissioner’s Directions 2013.
Managers
Managers, at all levels, have the responsibility for:

assisting APS employees to comply with the requirements of the APS Code of
Conduct

providing employees with appropriate advice when difficult situations or dilemmas
arise

consulting with the Workplace Behaviour and Conduct Unit where situations or
dilemmas that arise are suspected to be breaches of the APS Code of Conduct by an
employee.
Section 35 of the Public Service Act 1999 prescribes the role and constitution of the Senior
Executive Service (SES). In particular this section requires that the SES promote the APS
Values and compliance with the APS Code of Conduct by personal example and other
appropriate means.
The Workplace Behaviour and Conduct Unit
The Workplace Behaviour and Conduct Unit (WBCU):

provides assistance to managers and employees with concerns raised about the
workplace conduct and behaviour of departmental employees and supports the
Department's legal and ethical standards of conduct

conducts preliminary inquiries and assessments of allegations made about the
conduct and behaviour of departmental employees and makes recommendations
to the Director, Capability and Performance Section (CPS) and the Primary
Delegate about any further action that may be required in the circumstances

closely liaises with all areas of the Department and other Commonwealth agencies
including the Australian Public Service Commission and the Merit Protection
Commissioner, about APS Code of Conduct and ethical behaviour issues

provides education, guidance and advice to departmental employees and
managers on the APS Code of Conduct, Public Interest Disclosures and Fraud
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awareness initiatives to promote integrity in the performance of employees duties,
in departmental processes and procedures and in the use of the Department’s
resources and Information and Communications Technology (ICT) systems

reports on trends and systemic policy, process and/or procedural deficiencies
identified during investigations to positively assist with the Department’s strategic
direction.
Reporting Suspected Misconduct
Australian Public Service Commission (APSC) guidance to Commonwealth Agencies is that
the duty to act with integrity and with the highest ethical standards also imposes a reporting
obligation on all APS employees with regard to suspected misconduct. In some
circumstances, particularly for employees with managerial responsibilities, it may constitute a
breach of the APS Code of Conduct for an employee not to report suspected misconduct by
another APS employee.
Departmental employees should also be mindful of their obligations and procedures to report
misconduct under the Public Interest Disclosure Act 2013 which was introduced on
15 January 2014. More information can be found under the Public Interest Disclosure
Procedures on the Code of Conduct and Ethics intranet page.
Consequently, if a departmental employee becomes aware of behaviour that is or appears to
be inconsistent with the APS Code of Conduct they have a responsibility to act without delay,
by:

reporting the matter to the Workplace Behaviour and Conduct Unit and/or

raising the matter with their Executive Level, or higher, manager and/or

or reporting the matter to an Authorised Officer in accordance with this Department’s
Public Interest Disclosure Procedures
From 1 January 2014, employees can also report bullying to the Fair Work Commission under
the Fair Work Amendment Act. The Fair Work Commission does not investigate incidents but
will speak to each party and if appropriate, make an order. An order is a ruling made by a
Commission Member after he or she has heard and determined a matter. This could include
direction to the person or persons concerned to stop the bullying or to the agency to provide
additional support and training to workers. The Commission Member may also take into
account any procedures available to the employee to resolve the alleged bullying and any
outcomes arising from those procedures.
In the first instance, employees are encouraged to seek advice from the WBCU or a
Workplace Contact Officer as any discussion about potential misconduct reported to your
manager may qualify as a Public Interest Disclosure. In circumstances where the behaviour of
concern is or appears to be either serious or involves their Executive Level, or higher,
manager - employees must report the matter directly to the WBCU or an Authorised Officer
appointed under the Public Interest Disclosure Act 2013.
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The Department’s procedures for investigating suspected misconduct is set out in the policy
document Procedures for Suspected Breaches of the APS Code of Conduct which is available
to all employees and managers on the Code of Conduct and Ethics intranet page.
Employees should also be aware that disciplinary action may be taken against an employee
who makes a frivolous, vexatious, malicious, fabricated and/or false report of suspected
misconduct about another employee.
Subsequent to an investigation under the APS Code of Conduct, if an employee is found to
have breached the APS Code of Conduct, sanctions may be imposed by an Agency Head or
their Delegate. The sanctions are set out in section 15 (1) of the Public Service Act 1999 and
are listed below:
(a) termination of employment
(b) reduction in classification
(c) re-assignment of duties
(d) reduction in salary
(e) deductions from salary, by way of fine
(f) a reprimand.
Not every failure to act consistently with the APS Values, Employment Principles or Code of
Conduct needs to be dealt with by implementing misconduct procedures. Misconduct action is
part of a range of people management practices that agencies have available to support high
quality performance. When deciding whether to start a misconduct investigation, consideration
is given, for example, to whether the matter could be better dealt with under the Agency’s
performance management framework or through other less formal measures such as
counselling and/or training.
The Department's procedures for investigating allegations of suspected fraud and/or other
criminal behaviour are set out in the policy documents Allegations of Fraud & Criminal
Behaviour by Departmental Employees which are available to all employees and managers on
the Code of Conduct and Ethics intranet page.
Common APS ethical dilemmas and situations
There are many situations that can occur during the course of APS employment where
departmental employees need be aware of the potential for the APS Values, Employment
Principles and the APS Code of Conduct to be breached. Some of the more common of these
ethical issues and situations often encountered by APS employees are outlined below.
However, employees should be mindful that the below guidance information is not intended to
be either comprehensive or exhaustive. Employees should seek further guidance and advice
whenever necessary from their Executive Level, or higher, manager or from the WBCU.
The APSC publication APS Values and Code of Conduct in Practice – A guide to official
conduct for APS employees and Agency Heads is an excellent resource and is aimed to assist
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APS employees to understand the practical application of the APS Values and the APS Code
of Conduct in both common and unusual circumstances. Employees and managers are
strongly encouraged to familiarise themselves with this valuable reference and guidance
material.
To further assist employees and managers, the WBCU has developed a range of educational
Fact Sheets which discuss some of the common ethical issues and situations often
encountered by APS employees in the course of their APS employment. The WBCU fact
sheets are available to all employees and managers on the Code of Conduct and Ethics
intranet page.
Further relevant publications, circulars and information are also available from the APSC
website http://www.apsc.gov.au/ and the Ethics Advisory Service.
Respect and Courtesy
The Department is firmly committed to the APS Values, Employment Principles and the APS
Code of Conduct in promoting a positive workplace culture and environment which is free from
all forms of inappropriate workplace behaviours including bullying and harassment. The
Department demonstrates this commitment from the Agency Head and Senior Executive
levels down by articulating and modelling appropriate workplace behaviour and by decisively
addressing and resolving incidents of improper workplace behaviour that occur.
Treating others with a lack of respect and courtesy and bullying and harassing behaviours are
potential breaches of the APS Values, Employment Principles and the APS Code of Conduct
and are not tolerated in the Department. The serious consequences for employees found to
have engaged in any form of inappropriate workplace behaviour during the course of their APS
employment include the likelihood of facing disciplinary action which may also result in the
imposition of sanctions.
All managers and employees have shared obligations for creating a respectful and courteous
workplace. All Department employees must treat everyone with respect and courtesy. This
includes our departmental colleagues, APS employees in other agencies, clients and other
members of the public. It also includes treating everyone with civility and tact even when
others may display behaviour which is critical, hostile or rude towards them. Employees must
uphold these same values during all employment/work related social activities whether outside
of normal work hours, when undertaking business travel or otherwise.
If an employee is a witness to, or subject to inappropriate workplace behaviour, they can
discuss the issue with

the colleague involved as an initial step

their Executive Level, or higher, manager, bearing in mind the potential for a Public
Interest Disclosure

a Workplace Contact Officer (WCO)

the Workplace Behaviour and Conduct Unit

the department’s Employee Assistance Program (EAP) provider.
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An employee who reasonably believes they are being bullied at work can make an application
to the Fair Work Commission for an order to stop bullying.
Further information
The Workplace Respect Policy is available to all employees and managers on the Code of
Conduct and Ethics intranet page.
The APSC publication APS Values and Code of Conduct in Practice provides detailed
guidance in relation to working with the public (chapter 6), working with the private sector and
other stakeholders (chapter 7), working with lobbyists (chapter 8) and working with APS
colleagues (chapter 9).
The WBCU has developed Fact Sheets about workplace respect and courtesy. The Fact
Sheets are available to all employees and managers on the Code of Conduct and Ethics
intranet page.
Also see APSC publications:

Respect: Promoting a Culture free from Harassment and Bullying in the APS

Guidelines on Workplace Diversity, Working Together
Recordkeeping
Corporate records, often simply called 'records', are information and data in any form. In
essence, corporate records are the Department's memory of what happened, what was done,
what was decided, by whom and when.
Employees must create accurate official records and maintain records in appropriate formats
as they are crucial to the work of the Department. When creating or updating official records
employees must ensure that all necessary and relevant data is recorded accurately and all the
information relevant to the matter forms part of the corporate record. Confidential and/or
security classified records must be kept in appropriate storage conditions. Employees are also
responsible for registering corporate records in the Department’s electronic records
management system and updating the location information when the record is requested by
another staff member.
Further information
The Australian Public Service Commission publication: APS Values and Code of Conduct in
Practice provides detailed guidance in relation to managing official information (chapter 3) and
managing personal information (chapter 4).
Also see Departmental CEI and policies:
 CEI 1.4 – Accounts and Records
 Records Management Policy
 Information Management Framework
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Complying with Lawful and Reasonable Directions
Departmental employees must comply with any lawful and reasonable direction given to them
by someone in the Department with the authority to do so. Generally, supervisors/managers
have the authority to direct an employee to do or not do something in the course of their
duties. In addition, other employees with particular responsibilities, for example, fire wardens
may need to give directions to ensure staff safety. Provided the direction is not unlawful and is
reasonable, then the employee must comply with the direction.
This does not mean that employees are not encouraged to engage in debate/discussion about
issues with their managers. However, when a manager makes a decision and a lawful and
reasonable direction is given, the employee must comply with the direction.
'Lawful and Reasonable Directions' include:

directions given by managers/supervisors with the authority to direct an employee

formal instructions such as Chief Executive Instructions, Departmental Instructions
and other departmental official policy documents

directions given by fire wardens in the event an alarm is triggered

Ministerial directions.
Failure to comply with a lawful and reasonable direction, given by someone in the Department
with the authority to do so, may constitute a breach of the APS Code of Conduct and may lead
to misconduct action being taken including the imposition of sanctions.
Chief Executive Instructions
Chief Executive Instructions (CEI’s) enable the Agency Head and the Chief Financial Officer to
give instructions to departmental staff on all matters relating to compliance with the Financial
Management and Accountability Act 1997 (FMA Act) and the Financial Management and
Accountability Regulations 1997 (FMA Regulations). Employees must comply with all
instructions contained within the CEI’s.
Failure to comply with departmental CEI’s and other official policies may constitute a breach of
the requirement to comply with a lawful and reasonable direction and may lead to disciplinary
action including the imposition of sanctions.
Further information
The APSC publication APS Values and Code of Conduct in Practice provides detailed
guidance in relation to working with APS Colleagues at chapter 9.
The WBCU has developed a Fact Sheet about APS employee’s obligations to comply with
lawful and reasonable directions. The Fact Sheet is available to all employees and managers
on the Code of Conduct and Ethics intranet page.
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Maintaining Confidentiality with Ministers or their Staff
The confidentiality of dealings between Ministers, their staff and public servants is at the heart
of the reputation that the APS has developed over many decades.
Employees must not:

discuss outside the workplace any dealings with Ministers or their staff which includes
discussing the nature or content of individual items of Ministerial correspondence

share any information, even within the workplace, except on a need-to-know basis.
That means that an employee must not pass information to anyone else unless the
information is required for legitimate work related reasons.
Inappropriate disclosures of information may damage the relationship of trust between the
government of the day and its public service advisers. This may reduce the willingness of the
government of the day to seek the advice of the public service. Among other things, this could
reduce the capacity of the public service to have its views and experience taken into account
in the policy development process.
Further information
Further advice on dealing with Ministers, their staff and Members of Parliament is available
from the Communications and Ministerial Services Branch in the Policy and Communication
Division.
The APSC publication APS Values and Code of Conduct in Practice provides detailed
guidance in relation to working with the Government, the Parliament and Ministers at chapter
2.
Conflicts of Interest
A conflict of interest occurs when an employee’s personal circumstances may be in conflict, or
be perceived to be in conflict, with their responsibilities as an employee of the APS.
Employees must:

take reasonable steps to avoid any real or apparent conflict of interest

disclose any real or apparent (perceived) conflict of interest.
Conflicts of interest can arise in a wide variety of circumstances and are not limited to
situations such as where employees accept goods and services from companies who have a
contractual relationship with the Department.
An ‘apparent’ conflict of interest is the perception that a departmental employee is not acting
fairly, appropriately or is acting with bias. Such a perception can be destructive to the
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reputation of the Commonwealth, the APS, the Department and the employee - even if no
actual wrongdoing has occurred.
It is important that employees avoid the perception of conflicts of interest so that an event or
relationship is not misinterpreted. Even if you are confident of the integrity of your actions, you
must always consider how your relationships and actions may appear to others.
Avoiding and Disclosing Conflicts of Interest
Employees must take reasonable steps to avoid real or apparent conflicts of interest. What is
‘reasonable’ will vary from situation to situation. Recognising a possible conflict of interest and
disclosing it to your manager, is an important factor in ensuring that appropriate and
reasonable steps are taken to avoid the conflict.
The action taken to avoid or minimise a conflict of interest situation will vary depending on the
nature of the issue. For example: if you are a member of an environmental organisation but
work in an area of the Department that has no dealings with that particular organisation, simply
declaring your membership to your manager will likely be sufficient in most cases.
Employees with a real conflict of interest or whose conflict of interest situation may be
apparent or perceived must disclose this in writing to their appropriate Executive Level, or
higher, manager. Disclosing a conflict of interest may not always remove the perception of a
conflict of interest but it does allow the Department to manage the situation in a professional
and ethical manner which protects the reputation of the Department, the integrity of the
Department’s processes and decision making as well as the reputation of the employee.
After disclosing the conflict of interest in writing the employee and the manager should discuss
the matter including:

the nature of the conflict of interest

any sensitivities or privacy issues it raises and how these can be managed

any management action necessary to manage the conflict of interest

any action to be taken by the employee to avoid or minimise the conflict of interest.
Once a conflict of interest has been disclosed it may be necessary for management to take
action to remove the conflict of interest or to limit the extent of any potentially damaging
perceptions of a conflict of interest.
Employees must also advise their manager if the circumstances giving rise to the conflict of
interest change. If an employee changes position/manager within the Department, the
employee must advise the manager in their new area, in writing, of any existing conflict of
interest situations.
Greater onus on SES officers
SES employees, given their higher level of responsibilities and influence, have a greater onus
to avoid real or perceived conflicts of interest. SES employees must notify the Agency Head of
any interests which they have that may impact on the Department’s business operations. They
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must also declare any private interests or relationships of their immediate family which could
be perceived as a potential conflict of interest.
This declaration is made by completing forms circulated annually by the Assistant Secretary,
Business Services Branch, and includes an obligation to notify the Agency Head of any
substantial out-of-cycle changes in SES interests.
The relevant forms can be obtained from the Assistant Secretary, Business Services Branch.
Persons acting in an SES position for six months or more are also required to complete the
declaration form.
Freedom to join organisations
APS employees are entitled to become an active member of community organisations. If the
organisation you propose to participate in relates to an area of interest covered by the
Department you must declare the conflict of interest to your manager in the first instance who
may need to seek advice on whether it is necessary for you to complete an application for
outside employment to ensure that there is no actual or perceived conflict of interest. You
must seek approval again if your status within the organisation changes, such as, becoming
an office bearer.
Further information
The APSC publication: APS Values and Code of Conduct in Practice provides detailed
guidance in relation to conflicts of interest in the course of APS employment at chapter 11.
The WBCU has developed Fact Sheets about APS employee’s obligations and responsibilities
regarding conflicts of interest. The Fact Sheets are available to all employees and managers
on the Code of Conduct and Ethics intranet page.
ALSO SEE APSC PUBLICATION:
 IN WHOSE INTERESTS? PREVENTING AND MANAGING CONFLICTS OF
INTEREST IN THE APS
Gifts
Gifts include:
 goods
 hospitality
 sponsored travel and accommodation
 special offers
 gifts received by mail or left at the Department for an employee
 frequent flyer points.
Risks in accepting gifts
The perception that departmental staff are not acting fairly, appropriately or may be acting with
bias can be destructive to the reputation of the Commonwealth, the APS, the Department and
the employee. In the course of their duties, employees may be offered gifts from clients or
15
other stakeholders. These include goods, services, hospitality or any other type of benefit that
is provided to an employee either for free or at a discounted rate.
Clients are the people and their representatives who access our programs or services or who
are subject to our departmentally administered regulations. Stakeholders include contractors
and businesses with which the Department has a relationship (such as a contract or panel
arrangement). During the course of their APS employment employees may be presented with
a gift as a gesture of general appreciation, recognition of a specific service, as a general
courtesy and/or based on custom and practice. Employees may also be offered goods and
services from clients and other persons seeking to transact business with the Department.
There are three key risks in accepting offers of gifts and/or other benefits:

the employee may be compromised, or open to compromise, in the performance of
their duties by the acceptance of a gift or benefit

an observer or the gift giver might perceive that the departmental employee is acting
corruptly or is open to influence

an observer or the gift giver might consider that the acceptance of a gift or benefit
compromises the employee so that they cannot perform their duties impartially and
fairly, creating a conflict of interest.
Rules on gifts
Departmental employees must observe the following rules in relation to gifts, goods and
services:

Never solicit a gift (inclusive of goods, services or benefits as defined above) and
includes entering prize draws at conferences and functions etc

Never accept cash as a gift under any circumstance as it can easily be construed as
a bribe

Never accept a gift if there is a judgement that a third person could reasonably
perceive that you have given or will give favourable treatment as a consequence

Regardless of value, never accept a gift if there is a clear or likely intention on behalf
of the client that you will give favourable treatment in return

Never accept an offer of hospitality, gifts, services or sponsored travel from anyone
involved in a departmental tender or procurement process. All procurement
processes must be undertaken with regard to probity and in a demonstrably fair and
equitable manner. No prospective tenderer should be able to obtain (or be perceived
to have been able to obtain) an unfair advantage

If an employee accepts a gift, the employee must inform the person offering the gift
that the Department has specific procedures which require the declaration of gifts and
which determine how they are to be disposed. The employee should also advise the
giver that they may not be able to keep the gift

Do not participate in commercial promotions for personal benefit while on official
duty. If an employee receives a benefit such as a lucky door prize, this is considered
to be departmental property and must be dealt with according to the Department
16
instructions for accepting and disposing of gifts as contained within CEI 10.1 –
Acquiring Public Property and the Department’s Finance Practice Manual.
All SES officers hold authorisation to approve the acceptance of gifts, goods and services and
to determine the method of their disposal.
Departmental employees must make every effort to refuse an offer or return the gift
immediately if:

it could be construed as an attempt to influence or pressure you into making a
particular decision or bringing about a particular outcome

acceptance of the gift could give rise to a real or apparent conflict of interest situation

the gift is from a foreign government official. Such gifts must be declared regardless
of their value and is particularly important from a security aspect.
If you are offered hospitality you must discuss the matter with your manager and obtain their
written approval prior to accepting the offer.
Note: These principles also apply to members of your family where the offer of gifts, goods or
services is a result of your Departmental employment.
APS Code of Conduct and Criminal Law
Employees who are found to have behaved corruptly in accepting gifts, goods or services in
exchange for a benefit to any person, may be in contravention of the Criminal Code Act 1995,
in addition to potentially breaching the APS Code of Conduct for which sanctions can be
imposed. Severe penalties, including imprisonment, can apply under the criminal law to
employees found to have behaved corruptly.
All gifts and special offers of goods and services must be discussed with your manager and
must be entered into the Gift Register maintained by each Corporate Support Unit (CSU).
Gifts and/or services received by SES officers, including those in State and Territory offices,
must be reported to the Assistant Secretary - People Strategies Branch who maintains a
separate Gift register for this purpose.
Further information
The APSC publication: APS Values and Code of Conduct in Practice provides detailed
guidance in relation to gifts and benefits at chapter 12.
The WBCU has developed Fact Sheets about gifts and benefits. The Fact Sheets are
available to all employees and managers on the Code of Conduct and Ethics intranet page.
Also see:
 CEI No 10.1 – Acquiring Public Property
 CEI No 2.3 – Official Travel
 CEI No 2.4 - Official Hospitality/Business Catering
 Finance Practice Manual.
17
Outside employment
Outside employment is work employees do for private purposes outside their APS
employment with the Department. It includes paid, unpaid or voluntary work. It also includes
but is not limited to:

operating your own business, whether or not it is run for profit

being the director of a company or incorporated society

working for any person or business engaged in the private practice of any profession,
occupation or trade, whether you earn money from this or not.
Outside employment may also include holding an official position in a community organisation
where that organisation has dealings with the Department.
All employees, including those on any form of leave from the Department, must obtain written
permission from the appropriate Delegate of the Secretary prior to engaging in any
employment outside their official duties. Employees are required to establish that any
employment, whether paid or unpaid, will not create a conflict of interest with their usual official
APS duties consistent with section 13 of the Public Service Act 1999.
If an employee commenced outside employment before joining the Department the employee
must obtain approval to continue the employment immediately upon joining the department.
In all other cases employees must obtain approval before commencing outside employment.
The requirement to have outside employment approved is not intended to hinder employees
from having an additional income. It ensures that:
 there are no occupational health and safety issues which could affect your work for the
Department
 there is no actual conflict of interest and/or apparent (perceived) conflict of interest
whilst performing your outside employment
 the outside employment does not interfere with the performance of the employee’s
APS duties.
Working with volunteer and community organisations
Similarly, the requirement to seek approval for outside employment is not intended to hinder
employees from participating in community life by being active in volunteer and community
organisations. The key issue is whether or not the employee’s participation creates a real or
perceived conflict of interest with the employee’s role as a departmental APS employee
including their particular duties. In most cases voluntary work will not give rise to any conflict of
interests. For example:
 sports coaching
 working in a school canteen
 assisting people with disabilities or the aged
 collecting for charitable organisations
 participating in a school parents and citizens committee.
18
For these types of volunteer work it is not necessary to make a formal application for outside
employment. However employees must advise their manager if any issues arise during their
participation in these types of activities which could give rise to a conflict of interest.
Further information
The APSC publication APS Values and Code of Conduct in Practice provides detailed
guidance in relation to outside employment at chapter 13.
The WBCU has developed a Fact Sheet about Outside Employment. The Fact Sheet is
available to all employees and managers on the Code of Conduct and Ethics intranet page.
Also see Departmental Policy:
 Outside Employment Policy
 Volunteer Activity Policy
Post Separation employment
There are no laws that restrict the type of employment employees can move to in the private
sector if they resign from the APS. In common law, there is a general principle that a person is
not to be restrained from using the skills, knowledge and experience gained in the course of
their employment. However, there are clear provisions under law that protect the disclosure
and use of official information after an employee has left the APS.
The law can also protect other types of sensitive information. The doctrine of 'breach of
confidence' for example restricts a person from disclosing information where an obligation of
confidence is imposed. Also, the Commonwealth would generally own the intellectual property
in work performed by APS employees in the course of their employment, and could protect
infringements through relevant intellectual property laws.
Employees are not able to use or disclose confidential or otherwise non-public information
gained during their employment in the APS during any subsequent employment. Section 70(2)
of the Crimes Act 1914 makes it an offence for a person who has left the APS to publish or
communicate without authority any fact or document which they became aware of or obtained
while employed by the Commonwealth. An offence may attract a two-year maximum prison
term.
Section 142.2 of the Criminal Code Act 1995 (Abuse of Public Office) makes it an offence for a
person who has left the APS to use official information obtained while employed, dishonestly
to obtain a benefit for themselves or another person or to cause detriment to another. An
offence may attract a five-year maximum prison term.
Further information
The APSC publication APS Values and Code of Conduct in Practice provides detailed
guidance in relation to post-separation employment at chapter 14.
19
Also see APSC Circulars:
 2007/3 – Post Separation Employment
 2008/4 – Requirement relating to the Lobbying Code of Conduct and Post Separation
contact with Government
Use of Commonwealth Resources
Using the Department's resources and facilities in a proper manner means using them
efficiently, effectively and ethically. Employees are responsible for avoiding extravagance or
waste in the use of the Department’s financial or physical resources. Employees must always
take care when using departmental property.
Commonwealth resources include but are not limited to:






Commonwealth funds
Commonwealth fleet vehicles
Internet and email
Telephones
Stationery
Printers and photocopiers.
In general, departmental resources may only be used for departmental purposes. However,
there are some instances where limited personal use may be acceptable. Examples are
limited personal use of the department’s Internet access and limited personal use of
telephones.
As well as potentially constituting breaches of the APS Code of Conduct which may attract
sanctions, penalties of up to seven years imprisonment under the Financial Management and
Accountability Act 1997 exist where an employee is found guilty by a court of:

misapplying, improperly using or disposing of public funds

falsifying documents in connection with the collection of public funds.
Intentionally damaging Commonwealth property may also constitute breaches of the APS
Code of Conduct and attract sanctions as well contravening criminal law with penalties of fines
and terms of imprisonment applicable.
E-mail and Internet
It is essential that employees use e-mail and internet accounts appropriately. An email must
not be sent or forwarded to another person, whether inside or outside the Department, if the
sender is not absolutely certain that the email is appropriate. Sending an inappropriate email
may constitute a breach of the APS Code of Conduct and result in the imposition of sanctions.
Employees must familiarise themselves with the department’s CEI’s and policies and
guidelines on appropriate e-mail and Internet usage.
All departmental employees should be mindful that their use of the Internet is monitored.
Inappropriate and/or excessive use of the Department’s IT facilities that is considered
20
inconsistent with the Department’s Information and Communication Technology policy may
constitute breaches of the APS Code of Conduct and may attract sanctions.
Further information
The APSC publication APS Values and Code of Conduct in Practice provides detailed
guidance in relation to the use of Commonwealth resources at Chapter 10.
The WBCU has developed a Fact Sheet about the proper use of Commonwealth resources.
The Fact Sheet is available to all employees and managers on the Code of Conduct and
Ethics intranet page.
Also see related Departmental CEI’s:
 CEI No 7.1 - Receiving Public Money
 CEI No 10.3 – Custody and Use of Public Property
 CEI No 5 – Commonwealth Credit Cards and Credit Vouchers
 CEI No 2.14 – Use of Commonwealth vehicles
Also see related Departmental Instructions:
 Information and Communications Technology
Also see related Departmental Policy:
 Guidelines for the Use of IT facilities
 Email Guidelines & Tips
 ICT Security Policy
 Social Media - Business use Policy
 Guidelines for the use of Social Media
 Social Media - Personal Use Policy
Also see related Legislation:
 Crimes Act 1914: Section 29 – stealing/damaging/destroying Commonwealth property
 Criminal Code Act 1995: Divisions 131 & 145 – falsifying records & returns
 Archives Act 1983: Section 24 – destroying/damaging/disposing Commonwealth
records
Public Interest Disclosure
On 15 January 2014 the Public Interest Disclosure Act 2013 came into effect. This legislation
replaces the previous whistleblower provisions under section 16 of the Public Service Act
1999. The Department of the Environment Public Interest Disclosure Procedures discuss this
legislation in detail.
Further information
The WBCU has detailed information available to all employees and managers regarding Public
Interest Disclosures on the Code of Conduct and Ethics intranet page.
21
More information about the Public Interest Disclosure Act 2013 and the process of making a
disclosure can be found at www.pid.ombudsman.gov.au. You can also view the APSC
Circular 2013/08: APS whistleblowing scheme and public interest disclosures at
www.apsc.gov.au.
Releasing official information
The legal and regulatory framework that governs the use and disclosure of official information
by APS employees and access by the public includes:








Crimes Act 1914
Public Service Act 1999
Criminal Code Act 1995
Freedom of Information Act 1982
Archives Act 1983
Privacy Act 1988 (Privacy Amendment (Enhancing Privacy Protection) Act 2012
comes into effect on 12 March 2014)
Public Service Regulations 1999
Public Interest Disclosure Act 2013
Apart from the above mentioned legislation, provisions in the legislation administered by the
Department may also limit the information that can be disclosed. The APS Code of Conduct
requires that APS employees must comply with all applicable Australian laws and this
therefore includes the above listed Acts.
Regulation 2.1 - Duty not to disclose information - Public Service Regulations 1999
Public access to information is an important part of our democratic system of government.
However, there are some circumstances where there may be an overriding public interest in
maintaining the confidentiality of official information. The purpose of regulation 2.1 is to
ensure that the effective working of government is not compromised by the unauthorised
disclosure of official information.
Regulation 2.1 contains a number of sub clauses which govern the disclosure of different
categories of information including:

information prejudicial to the effective working of government (sub regulation 2.1(3))

information communicated in confidence (sub regulation 2.1(4)).
Sub regulation 2.1(5) makes it clear that sub regulations 2.1(3) and (4) do not prevent the
disclosure of information if an APS employee is required to make disclosures as part of their
duties. Such disclosures should be in accordance with agency protocols or guidance. For
example, employees undertaking regular liaison with members of the media may be required
to disclose certain information routinely.
APS employees may also disclose information in accordance with an authorisation given by an
Agency Head or a Delegate. Information may also be disclosed where disclosure is otherwise
22
authorised by law for example in accordance with the Privacy Act 1988 and the Freedom of
Information Act 1982.
Confidentiality and protection of client information
The Department places the highest priority on maintaining the confidentiality of the information
it collects about its clients. Clients and other people, such as employees, whose personal
information is collected by the department, must have the confidence that the Department will
protect their information from improper disclosure. It follows that any breach of this
requirement may constitute a breach of the APS Code of Conduct and may attract sanctions.
Client information is amongst the most valuable type of information which the Department
holds. Departmental employees have very strict obligations under both the relevant legislation
and the APS Values and Code of Conduct not to access client information for any purpose
other than a reason directly related to their role and responsibilities as a departmental officer.
This is referred to as either a legitimate business reason or a ‘lawful need to know.’
Departmental employees who do not have a legitimate business need to access information
held within any departmental database or record, must not, under any circumstances access
that information for any other reason.
Public Comment
Public comment includes, but is not limited to, comment made on political or social issues at:

public speaking engagements

during radio or television interviews

on the Internet such as social networking sites

in letters to the press or books or notices

in other ways where the comment is intended for the community at large.
Departmental employees as private citizens may make public comment in a private capacity,
so long as they make it clear they are expressing their own personal view. However, it is not
appropriate, and may constitute a breach of the APS Code of Conduct, if departmental
employees make public comment that could be perceived as:

being on behalf of the Department or Government rather than a personal view

compromising the employee’s capacity to fulfil his or her duties in an unbiased
manner

so harsh or extreme in its criticism of the Government or its policies that it raises
concerns about the employee’s capacity to work professionally, efficiently and
impartially

so strong in its criticism of the Department’s administration that it could seriously
disrupt the workplace

a gratuitous personal attack
23

compromising public confidence in the department or the APS.
When making comment outside the Department on matters that fall within the domain of the
Department’s business portfolios, employees must not disclose official information that is not
publicly available without the express authority of the Agency Head or a Delegate.
Sanctions and Criminal Penalties
The unauthorised disclosure of official information may constitute breaches of Regulation 2.1
of the Public Service Regulations 1999 and the APS Code of Conduct and subsequently result
in sanctions being imposed.
Section 70 of the Crimes Act 1914 makes it a criminal offence for a Commonwealth officer, or
a person who has ceased to be a Commonwealth officer, to publish or communicate
information that comes to their knowledge or into their position by virtue of their work and
which they have a duty not to disclose. This includes leaking inside information and/or
classified documents to the media or other organisations.
Section 3 of the Crimes Act 1914 provides an extended definition of a Commonwealth officer,
which has the effect of extending section 70 to persons who perform services for or on behalf
of the Commonwealth.
Further information
The APSC publication APS Values and Code of Conduct in Practice provides detailed
guidance in relation to managing official information (chapter 3), managing personal
information (chapter 4) and APS employees as citizens (chapter 15).
The WBCU has developed Fact Sheets about the use and disclosure of information. The Fact
Sheets are available to all employees and managers on the Code of Conduct and Ethics
intranet page.
Also see Departmental CEI’s and policy:
 CEI 1.4 – Accounts and Records
 ICT Security Policy
 Media Policy
Also see Departmental Instructions:
 Information and Communications Technology
 Privacy
Behaviour outside the workplace
It is a requirement of the APS Code of Conduct that all employees must uphold ‘at all times’
the integrity and good reputation of the Department and the APS. Disciplinary action may be
taken under the APS Code of Conduct where an employee’s inappropriate behaviour is linked
to their employment (such as while undertaking work travel or attending work related social
24
functions) and/or where the inappropriate behaviour could bring the reputation of the
Department or the APS into disrepute.
This APS Code of Conduct requirement may also provide the basis for determining if an
employee who has been found guilty of a criminal offence, even where the behaviour subject
of the criminal offence is not connected to their APS employment, may have also breached the
APS Code of Conduct. For example, serious criminal behaviour, such as dealing in drugs or
theft, may result in disciplinary action being taken under the APS Code of Conduct. This is
because such criminal behaviour by an APS employee undermines the public's expectation of
highly ethical behaviour by APS employees and could therefore also threaten the good
reputation of the APS.
Accordingly, employees must immediately advise their Executive Level, or higher, manager in
writing, if they are required to appear in a court of law as a result of being charged with a
criminal offence in their private capacity as a result of any non work related issues. The
employee’s manager must then advise the WBCU of the employee’s criminal charges and
appearance in a court of law without delay.
Further information
The WBCU has developed a Fact Sheet about upholding the APS Values and the integrity and
good reputation of the APS. The Fact Sheet is available to all employees and managers on
the Code of Conduct and Ethics intranet page.
Also see Departmental policy:
 Allegations of Fraud & Criminal Behaviour by Department of the Environment
Employees
Fraud
The Commonwealth Fraud Control Guidelines (2011) (the Guidelines) advises that:
‘Fraud against the Commonwealth is an extremely serious matter for all
departments and agencies and for the community. Not only is it a criminal offence,
but fraud reduces the funds available for delivering public goods and services and
can undermine public confidence in the Government. The Australian community
rightly expects that Commonwealth agencies and employees acknowledge and
fulfil their responsibilities as stewards of public funds and make every effort to
protect public money and property.’
For the purpose of the Guidelines fraud against the Commonwealth is defined as:
‘Dishonestly obtaining a benefit, or causing a loss, by deception or
other means’
A ‘benefit’ in the context of fraud is not restricted to monetary or material benefits and may be
tangible or intangible, and includes the unauthorised provision of access to or disclosure of
information. A benefit may also be obtained by a third party rather than, or in addition to, the
perpetrator of the fraud.
25
Fraud against the Commonwealth may include, but is not limited to:

Theft

Accounting fraud

Unlawful use of, or obtaining property, equipment, material or services

Causing a loss, or avoiding and/or creating a liability

Providing false or misleading information to the Commonwealth, or failing to provide
it; when there is an obligation to do so

Misuse of Commonwealth assets, equipment or facilities

Making or using false, forged or falsified documents

Wrongfully using Commonwealth information or intellectual property.
Fraud against the Commonwealth takes many forms and may target:








Revenue
Benefits
Property (eg: cash, computers, portable and attractive items, stationary)
Information and intelligence (eg: personal information or classified material)
Program funding and grants
Employee entitlements (eg: expenses, leave, travel allowances, attendance records)
Facilities (eg: unauthorised use of vehicles, information technology and
telecommunication systems)
Money or property held in trust.
Fraud can be perpetrated by departmental employees or contractors inside the Department.
This is known as ‘Internal Fraud’. On the other hand, fraud can be perpetrated by external
parties such as departmental clients, service providers or other members of the public. This is
known as ‘External Fraud’.
All departmental employees have a responsibility to report suspicions or observations of
internal fraud or other potential criminal conduct by departmental employees. Employees
must report their suspicions or any knowledge they may have about any internal fraud or other
potential criminal conduct by a departmental employee as soon as their suspicions develop
and without delay, to:

the Workplace Behaviour and Conduct Unit or

the Agency Head or an Authorised Officer under the Public Interest Disclosure Act
2013.
Authorised Officers who are authorised to receive Public Interest Disclosure reports are listed
in the Public Interest Disclosures Procedures on the Code of Conduct and Ethics intranet page
and on our website.
In some circumstances, and in accordance with the provisions of the Commonwealth Fraud
Control Guidelines 2011, the matter of concern may be required to be referred to the
Australian Federal Police (AFP), or to another external agency or law enforcement body.
26
Departmental employees also have a responsibility to report any suspicions or knowledge they
may have about any potential incidents of external fraud being committed against the
Department as soon as their suspicions develop and without delay to:

the Fraud Liaison Officer - the person occupying the position of Assistant Director,
Compliance and Assurance Section in the Governance Branch within the Policy and
Communications Division

the Department’s Fraud Manager - the person occupying the position of Assistant
Secretary, Governance Branch within the Policy and Communications Division.
Further information
Also see Departmental CEI and policy:
 CEI No 1.2 – Preventing Fraud
 Fraud Control Plan
 Allegations of Fraud & Criminal Behaviour by Department of the Environment
Employees
 Public Interest Disclosure Procedures
NEED MORE ADVICE ?
More advice concerning these guidelines and the APS Values, Employment Principles and the
APS Code of Conduct can be obtained by contacting the WBCU on:

their Hotline number: (02) 6274 1116

via email at: [email protected]

or by normal mail marked ‘Private and Confidential’ addressed to:
Workplace Behaviour and Conduct Unit
GPO Box 787
Canberra ACT 2601
The Department of the Environment Code of Conduct Guidelines have been established
by me in accordance with the Public Service Act 1999, the Public Service Regulations
1999 and the Australian Public Service Commissioner’s Directions 2013. All
Department employees are required to familiarise themselves with and comply with the
APS Values and Employment Principles, the APS Code of Conduct and these
guidelines.
Malcolm Thompson
Acting Secretary
Department of the Environment
January 2014
27
Revision History
Date
Version
Approved
1.0
Description
Document Creation
10.12.2010
21.03.2011
2.0
Draft for DCC consultation
Carl Murphy
18.04.2011
3.0
Carl Murphy
July 2011
4.0
26.09.2011
5.0
25.10.2011
6.0
2.11.2011
6.0
Draft for Intranet – all staff
consultation
Draft for Senior Executive
review
Redraft for Senior Executive
review incorporating Deputy
Secretary’s comments
Final incorporating further
comments by Deputy
Secretary Thompson
Final for Secretary’s approval
3.11.2011
6.0
Final
Secretary – Dr Paul Grimes
.6.2013
7.0
Michelle Wicks
13.01.2014
8.0
Draft for Senior Executive
Review due to legislative and
structural changes
Final due to legislative
changes (PID Act and Antibullying)
28
Carl Murphy
Carl Murphy
Michelle Wicks
Michelle Wicks
Michelle Wicks/Malcolm
Thompson
Malcolm Thompson
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