PLANNING DELIVERY DIVISION INTEGRITY PLAN 2020-22
PLANNING
DELIVERY
DIVISION
INTEGRITY PLAN 2020-22
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PLANNING DELIVERY DIVISION INTEGRITY PLAN 2020-22
CONTENTS
POLICY STATEMENT ...................................................
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PURPOSE .....................................................................
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OUR INTEGRITY COMMITMENT ........................................................ 4
OPERATIONAL CONTEXT .................................................................. 4
PLAN REQUIREMENTS ............................................... 6
MITIGATION ........................................................................................ 6
1. MITIGATION MEASURES ............................................................................ 6
2. STAFF AWARENESS AND TRAINING ......................................................... 7
3. INTEGRITY RISK ASSESSMENT ................................................................. 7
4. ENGAGEMENT WITH THIRD PARTIES ....................................................... 7
5. INTERNAL POLICIES ................................................................................... 8
DETECTION......................................................................................... 9
1. FRAUD AND CORRUPTION SIGNALS ........................................................ 9
2. REPORTING POTENTIAL BREACHES, RECEIVING ALLEGATIONS ........ 9
3. INTERNAL AND EXTERNAL AUDIT ........................................................... 10
3. PUBLIC INTEREST DISCLOSURES .......................................................... 10
3. THE ACT INTEGRITY COMMISSION ......................................................... 11
INVESTIGATION AND RESPONSES TO INTEGRITY MATTERS ..... 12
1. ADVICE TO DIVISION MANAGEMENT ...................................................... 12
2. RECORDS OF REPORTS .......................................................................... 13
CONTINUOUS IMPROVEMENT ................................. 14
MONITORING AND REVIEW ............................................................. 14
PLAN EVALUATION .......................................................................... 15
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PLANNING DELIVERY DIVISION INTEGRITY PLAN 2020-22
RELATED RESOURCES ................................................................... 16
ATTACHMENTS .......................................................... 17
ATTACHMENT 1: KEY DEFINITIONS ............................................... 17
ATTACHMENT 2: ROLES AND RESPONSIBILITIES ........................ 20
ATTACHMENT 3: INTEGRITY RISK ASSESSMENT ........................ 22
ATTACHMENT 4: DIVISION INTEGRITY ACTION PLAN .................. 23
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PLANNING DELIVERY DIVISION INTEGRITY PLAN 2020-22
POLICY STATEMENT
The Planning Delivery Division within the Environment, Planning and Sustainable Development
Directorate performs statutory decision-making functions on behalf of the planning and land
authority and other planning and land administration functions.
As identified in the Portfolio Fraud and Corruption Prevention Plan 2019-21 (FCPP), the Division has a
zero-tolerance policy towards matters of integrity, including unlawful behaviours or corrupt conduct
by staff, contractors, third-party service providers, and clients.
This Plan applies to all staff within the Division including:
• Permanent and temporary ACT Government personnel and Executives of the Division;
• Non-government personnel including contractors and consultants acting for, or on behalf of,
the Division.
This plan also recognises that many of the Division’s functions involve engagement with external
personnel such as professional consultants, referral entities and other ACT Government agencies.
The statutory and professional relationships with these bodies external to the Division raise their
own set of potential integrity issues which is addressed through this Plan.
PURPOSE
OUR INTEGRITY COMMITMENT
The Planning Delivery Division (the Division) Integrity Plan 2020-22 (the Plan) has been developed to
outline the Division’s commitment to integrity, promote transparent and open business processes
and raise awareness of response measures and policies to be adhered to in the face of integrity
issues, such as fraud, corruption and corrupt conduct. Simultaneously, the operational aim of the
Plan is to assist staff within the Division to prevent, detect and report suspected fraud, corruption
and corrupt conduct and guide the management of cases where allegations or instances are
reported.
The Integrity Plan, Integrity Action Plan and associated risk assessment and risk treatment controls
formulate an Integrity Package for the Division, designed to provide a framework for building the
capacity of staff with the appropriate knowledge and tools to promote confidence in decision-making
and responses that are fit-for purpose.
OPERATIONAL CONTEXT
The Environment, Planning and Sustainable Development Directorate understands that building
public trust is key to upholding organisational integrity. As a global leader in education and
government- focused research, the Australia and New Zealand School of Government (ANZSOG)
identified in 2019 that there are social good consequences for high functioning trust and the
Directorate’s integrity vision promotes transparency of integrity functions to build public trust in its
policies and protocols.
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PLANNING DELIVERY DIVISION INTEGRITY PLAN 2020-22
The Directorate appreciates that if confidence in public integrity is high, it can result in a range of
high trust consequences including greater civic participation and social cohesion leading to higher
public sector performance, however if public integrity is low, it can result in low trust consequences
which can lead to reduced performance. Figure 1.1. below provides an overview of ANZSOG’s
analysis of the impact of public trust on public sector performance which provides the context for the
Division’s approach to designing this Plan.
Figure 1.1. ANZSOG Analysis of Public Integrity, Performance and Trust Consequences1
This Plan should be read in conjunction with the EPSDD Portfolio Fraud and Corruption Prevention
Plan 2019-21 and the Integrity Framework (Framework) which outlines the integrity management
response arrangements, activities and obligations required of all staff within the Portfolio. The
Framework draws together relevant policies to ensure staff are aware of their responsibilities to act
ethically and appropriately recognising the trust of the community.
The ACT Government has introduced the
Integrity Commission Act 2018 which establishes a formal
Integrity Commission for the ACT. The Integrity Commission is focussed on the investigation of
potential corrupt conduct within the ACT Government and its agencies. This Plan responds to the
potential integrity matters that would come before the Integrity Commission and seeks to develop
proactive policies, procedures and actions to educate staff, prevent fraud, corruption and corrupt
conduct, and mitigate risks.
Integrity risk management forms part of the business planning cycle and contributes to business
performance through minimisation of the Division’s risks. This provides assurance to Executives,
relevant audit and risk committees, and the public that appropriate risk management is occurring
within the Division.
1
Image, ANZSOG Analysis of Public Integrity, Performance and Trust Consequences/Kirby, N. & Webbe, S./2019/Being a trusted and
respected partner: the APD integrity framework, An ANZSOG Paper for the Australian Public Service Review/
https://www.apsreview.gov.au/sites/default/files/resources/being-trusted-respected-partner-aps-integrity-framework.pdf. Web 27022020
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PLANNING DELIVERY DIVISION INTEGRITY PLAN 2020-22
PLAN REQUIREMENTS
Consistent with the FCPP, the Division’s approach to integrity risk control is based on three elements:
• mitigation
• detection
• investigation and response.
MITIGATION
The Division endorses integrity control activities and promotes a culture of staff reporting potential
cases of fraud, corruption and corrupt conduct.
Executives should ensure that all business processes, particularly those assessed as having a higher
predisposition to the risks of fraud, corruption or corrupt conduct, are subject to a rigorous system of
internal controls that are well documented, reviewed and updated regularly, and understood by
staff.
The accompanying Division integrity risk assessment identifies integrity risks specific to the functions
performed in the Division. General fraud and corruption risks are considered through the Portfolio
Fraud and Corruption Prevention Plan and Risk Assessment.
The Division risk assessment identifies risks and the current risk treatment controls currently in place.
It also identifies additional risk treatment controls which are recommended to be implemented.
Together, the risk treatment controls have been combined into an Integrity Action Plan,
implementation of which will be overseen by an Integrity Manager. The Integrity Manager is a senior
officer within the Division appointed by the Executive Group Manager. An Integrity Officer may also
be appointed to assist the Integrity Manager with implementation and administration of the Integrity
Action Plan.
1. MITIGATION MEASURES
Generally, the Division implements the fol owing integrity risk mitigation measures:
• Standard Operating Procedures and work instructions, are available to staff and brought to
their attention by the team leaders, Directors, Senior Directors and Executives
• Staff training, including on fraud, corruption, integrity and ethics
• Fraud, corruption and corrupt conduct control expectations are included in the new staff
induction program and regular training and communications
• Division integrity risk assessments are conducted at least every two years
• Staff are made aware of their obligations under the relevant legislation, policies and
procedures
• Facilitation of audits and reviews
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PLANNING DELIVERY DIVISION INTEGRITY PLAN 2020-22
• Conflict of interest policies and procedures are regularly communicated to staff
• Statutory delegations and internal work classification instructions are regularly reviewed and
updated and available to all staff
• Communications with external personnel, including consultants, referral entities and other
ACT Government agencies, on integrity matters relating to planning and development, such
as conflict of interest procedures and integrity complaint handling processes.
Specific actions, including current actions to be maintained and actions to be implemented, can
be found in the Integrity Action Plan.
2. STAFF AWARENESS AND TRAINING
In addition to training provided by EPSDD, the Integrity Manager will provide initial training and
information to all staff within the Division about the content of the Plan and their obligations under
it. Refreshing training will be provided at least once yearly for all staff.
Staff awareness of the Plan will allow staff to confidently perform their statutory and administrative
functions in the planning and development system. New staff into the Division wil be made aware of
the Plan and their integrity obligations under it through the induction and training process.
3. INTEGRITY RISK ASSESSMENT
An integrity risk assessment measures the vulnerability of an organisation to fraud, corruption and
corrupt conduct and is essential for risk mitigation and control. At least once every two years, a
targeted integrity risk assessment is to be conducted for the Division.
In the development of this Plan, a Division integrity risk assessment was undertaken, involving senior
officers and executives across the Division. The risk assessment also drew on the broader EPSDD
Portfolio Fraud and Corruption Risk Assessment. The Division integrity risk assessment identified two
key integrity risks, both of which were rated high. These high-level risks were: Failure to protect
personal or corporate information; and Misuse of delegations and position in decision-making and
processing of applications. The Division integrity risk assessment is provided as an attachment in this
document.
The most important outcome of an integrity risk assessment process is the development of an
effective risk treatment program that specifically addresses the risks faced by the Division.
Treatments should be measured for effectiveness over time.
4. ENGAGEMENT WITH THIRD PARTIES
This Plan and the Division integrity risk assessment recognise that much of the work of the Division
involves engagement with external personnel, including professional consultants, referral entities,
other ACT Government agencies, people providing representations on applications and the
interested public.
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PLANNING DELIVERY DIVISION INTEGRITY PLAN 2020-22
This engagement raises the potential for integrity risks, including personal and professional
relationships, conflict of interest, process corruption and bias in decision-making. While the risk
mitigation and treatments identified in this Plan are largely inward facing to the Division, the Plan
also recognises these external integrity risks and identifies actions and communications to raise
awareness and address risks external to the Division. While often these are beyond the complete
control of the Division, it is considered necessary to raise awareness, and proactively consider, the
management of integrity risks within the broader planning and development system.
In the course of its duties, the Division is involved in a number of processes which involve the
provision of advice prior to formal determination of an application for a relevant approval. Some
examples include the ACT Civil and Administrative Tribunal mediation process, the provision of pre-
application advice for development applications under the Planning and Development Act, and the
provision of informal advice prior to applications being lodged with the Division.
In all cases, the Division’s focus is on determining whether an applicant meets statutory criteria for
approval. Any advice given is always subject to assessment and determination through a formal
application process.
The Division acknowledges that consultants/applicants seek the best outcome for their
client/themselves. The Division also acknowledges that there is a difference between seeking a
positive outcome on an application, and improper influence or pressure applied to a decision-maker,
or attempting to corrupt an assessment process. This Plan and the associated Integrity Action Plan
aims to identify this risk and propose appropriate control measures through assessment policies and
procedures and integrity actions.
The Division also acknowledges the regular interactions with people making representations through
statutory consultation processes and corresponding with the Division on applications. The Division
recognises its role in the planning system is to engage with and assist members of the public, as well
as receive relevant information relating to an application. The Division acknowledges that the risks of
improper influence, pressure applied to a decision-maker, or attempts to corrupt an assessment
process are also relevant when engaging with the general public.
At all times, the Division follows its established internal processes, is guided by the statutory
framework and is concerned with procedural fairness in all processes and decisions.
5. INTERNAL POLICIES
Other relevant policies are available on the EPSDD intranet, via objective and through regular all-staff
emails. For further information, including a list of policies please refer to the FCPP link within the
Additional Resources section of this document.
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PLANNING DELIVERY DIVISION INTEGRITY PLAN 2020-22
DETECTION
As identified in the FCPP, fraud, corruption and corrupt conduct can be detected by establishing
effective system controls and by recognising variations from standard practice. In addition, staff
cooperation, observation and initiative are important in preventing and detecting fraud, corruption
and corrupt conduct in the workplace.
Given the significant engagement with external third parties in the Division, there must be a
mechanism to receive complaints and allegations of fraud, corruption or corrupt conduct. The Plan
includes processes for receiving complaints and allegations from any person, including internal staff,
external third parties, and the general public.
1. FRAUD AND CORRUPTION SIGNALS
Managers and staff should be alert to common signs of fraud, corruption and corrupt conduct.
Signals may include:
• Implausible excuses and reasons for unusual events or actions
• Senior staff involved in routine process work such as purchasing, ordering and receiving
goods
• Staff evidently living beyond their means, who have access to funds, or control or influence
over service providers
• Staff requesting to assess/determine applications for the same applicant
• Staff who do not take holidays for extended periods
• Potential conflicts of interest not declared
• Staff who treat controls and standard practices as challenges to be overcome or defied
• Unauthorised changes to systems or work practices
• Missing documentation relating to decision-making
• “Blind approval”, where the decision-maker does not consider the merits of an application.
2. REPORTING POTENTIAL BREACHES AND RECEIVING ALLEGATIONS
If a staff member becomes aware of possible fraud, corruption, or corrupt conduct, they are obliged
to report their concerns. In the first instance, it is generally best to report any concerns to an
immediate supervisor, who is required to refer the report/al egation to the Integrity Manager. The
Integrity Manager will liaise with the relevant Division Executives and the EPSDD Legal Services and
Integrity team. Any report or allegation of a serious nature, or which requires further investigation,
will be referred to the Legal Services and Integrity team. The Legal Services and Integrity will
investigate the matter and brief the Senior Executive Responsible for Business Integrity and Risk
(SERBIR), as outlined in Section 3 below.
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PLANNING DELIVERY DIVISION INTEGRITY PLAN 2020-22
Staff should report suspicions to only those people who absolutely need to know. This protects
people from al egations that may not be proven and prevents the possible destruction of evidence.
All staff within the Division may receive complaints or allegations from third parties, such as
applicants or the general public. In this instance, the complaint/allegation should be referred to the
Integrity Manager to be dealt with as per the process outlined above.
The Integrity Commission Act also includes a mandatory requirement for senior executive service
officers to report any matter they suspect, on reasonable grounds, involves serious corrupt conduct
or systemic corrupt conduct. It is an offence under that Act to not notify the Commission as soon as
practicable where they know that a public official has engaged in serious or systemic corrupt
conduct.
3. INTERNAL AND EXTERNAL AUDIT
The Division is expected to comply with policies and procedures and are subject to review under
their internal audit programs, as well as external audits undertaken by the ACT Audit Office.
Specifically, the Division will undertake audits throughout the life of the Plan to ensure that
procedures and processes are being actively implemented and followed by all staff. Audits present an
opportunity to detect fraud, corruption or corrupt conduct. The Division executives and Senior
officers wil consider outcomes to determine process improvements and whether the risk
assessment and risk treatments contained in the Integrity Action Plan remain current and effective.
4. PUBLIC INTEREST DISCLOSURES
The
Public Interest Disclosure Act 2012 (PID Act) supports the reporting, assessment and
investigation of reported wrongdoing by an ACT public servant, including fraud and corruption. The
PID Act and procedures adopted by agencies provide a method of investigating allegations, while
protecting the individual who has made the disclosure from any reprisals.
Members of the public, as well as current and former ACT public servants may make a public interest
disclosure to any ACT government agency.
Disclosable conduct includes activity or conduct (or combination thereof) by an individual or an ACT
Public Sector entity that is any of the following:
• Is illegal
• Misuses or wastes public money or resources
• Is misconduct
• Is maladministration
• Presents a danger to the health or safety of the public
• Presents a danger to the environment.
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PLANNING DELIVERY DIVISION INTEGRITY PLAN 2020-22
5. THE ACT INTEGRITY COMMISSION
The ACT Integrity Commission is empowered to investigate a wide range of allegations concerning
corrupt conduct on the part of ACT public officials and ACT public sector entities dating back to the
start of self-government. As described above the Integrity Commission is focussed on the
investigation of potential corrupt conduct within the ACT Government and its agencies. The Division
wil respond to any enquiries from the Commission in a prompt manner.
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PLANNING DELIVERY DIVISION INTEGRITY PLAN 2020-22
INVESTIGATION AND RESPONSES TO INTEGRITY MATTERS
The Division maintains a zero-tolerance approach to all matters of integrity in accordance with the
FCPP. In order to coordinate integrity matters and respond immediately if required, all reports,
complaints, or allegations on integrity matters should be made or referred to the Integrity Manager
in the first instance. The Integrity Manager, in consultation with the relevant Executive, will consider
if any immediate risk prevention actions must be taken.
Any report or allegation of a serious nature, or which requires further investigation, will be referred
to the Legal Services and Integrity team. The Legal Services and Integrity will investigate the matter
and brief the Senior Executive Responsible for Business Integrity and Risk (SERBIR).
Initial investigation into integrity matters will be made by the SERBIR who will determine whether
there is any basis for further action. The SERBIR may appoint an officer within the Portfolio to
undertake enquiries or may acquire the services of external experts to assist in the conduct of any
inquiry. The SERBIR may refer the matter to the police for investigation and potential prosecution.
During investigation processes al egations are assessed to determine whether there is any merit to
further investigation and/or referral. The presumption of innocence applies, meaning that people
alleged to have committed fraud, corruption and/or corrupt conduct are innocent until proven guilty.
People suspected of engaging in fraud, corruption or corrupt conduct will be afforded natural justice.
Following the discovery of fraud, corruption, or corrupt conduct, the SERBIR will determine if an
internal control review is required. An internal control review will include a reassessment of the
adequacy of the internal control environment (particularly those controls directly impacting on the
fraud or corruption incident and potentially allowing it to occur) and wil consider whether
improvements are required. Where improvements are required, these should be implemented as
soon as practicable.
In addition, a staff member committing fraud or engaging in corrupt conduct may be in breach of the
Public Sector Management Act 1994 (section 9) and may be subject to separate disciplinary action.
Possible outcomes of disciplinary action range from receiving a warning about the conduct to
dismissal.
1. ADVICE TO DIVISION MANAGEMENT
Team Leaders, Directors and Senior Directors are leaders in the Division and are required to display
high levels of integrity and probity in their work. They have an obligation to apply the Public Sector
Management Act, the Code of Conduct and ACTPS Signature Values and Behaviours, and to make
their staff aware of their obligations and appropriate behaviour.
Fraud, corruption or corrupt conduct allegations, or suspected cases, can be extremely sensitive and
cause disruption in the workplace and severely damage the reputation of the Division. Allegations
remain
allegations until confirmed, and the presumption of innocence applies.
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PLANNING DELIVERY DIVISION INTEGRITY PLAN 2020-22
Discretion is to be maintained and information on fraud, corruption, or corrupt conduct
investigations is on a strict need to know basis. The appropriate parties who must be informed will
also vary from case-to-case and be subject to change based on the particulars.
Al public servants are bound by the
Information Privacy Act 2014 and therefore individuals who have
made allegations or are the subject of an investigation are to have their privacy protected, in
accordance with the Information Privacy Act and Information Privacy Policy.
Team Leaders, Directors and Senior Directors should provide support to their staff and may wish to
encourage staff who have made an allegation or are the subject of an allegation to seek assistance
from the Employee Assistance Program.
2. RECORDS OF REPORTS
All reports of fraud, corruption or corrupt conduct are recorded on the EPSDD Fraud and Corruption
Incident Register for each entity within the Portfolio, which is maintained by Legal Services and
Integrity. These registers are updated regularly to reflect the outcome of investigations into each
incident.
Legal Services and Integrity prepares a report for the SERBIR for EPSDD’s Audit Committee on
allegations of fraud and/or corruption and their assessments and investigations. A summary of each
incident is also recorded in Annual Reports.
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PLANNING DELIVERY DIVISION INTEGRITY PLAN 2020-22
CONTINUOUS IMPROVEMENT
MONITORING AND REVIEW
Continuous improvement of processes, procedures and operations is a priority for the Division as a
central component of quality management of its activities. For this reason, the Plan endeavours to
embed mechanisms for ongoing monitoring, review and evaluation to ensure Divisional processes
and the Plan itself maintain currency to achieve the intended purpose.
In alignment with this aim, the Division commits to reviewing delegations, standard operating
procedures and work instructions at least annually (or more frequently as required) to ensure
documents remain appropriate to business needs and are used appropriately.
As the Division’s functions change and evolve, new systems and processes are introduced or
modified, then the risk of possible fraud or corruption may increase. Every change presents the
possibility of new or altered business risks and changes must therefore be subjected to the risk
assessment process. This includes an assessment of any change of general integrity risks, including
fraud and corruption risks, and addressing fresh or revised measures to control or manage those
risks.
The Integrity Manager, after consulting with Senior Directors, Directors and Team Leaders, will
provide half yearly reports to the Executive Group Manager, Planning Delivery on the
implementation of the Plan. In addition, the respective audit committee may initiate audits designed
to measure or monitor the implementation of the Plan or associated aspects of fraud and corruption.
The Plan itself will be reviewed at least once every two years, including undertaking an integrity risk
assessment.
Documents created or used during the management of an al eged integrity incident wil be stored in
an electronic document and records management system (EDRMS) in accordance with the
Territory
Records Act 2002. Access to relevant files should be restricted in accordance with the relevant
permissions policy. Personal information will be collected, used and disclosed in accordance with the
Information Privacy Act 2014 and the Information Privacy Policy.
Data and statistics, with personal information removed, may be generated to assist with reporting on
the management of allegations related to integrity and their investigations.
Directorate name
Long name
Date 2016
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PLANNING DELIVERY DIVISION INTEGRITY PLAN 2020-22
PLAN EVALUATION
The Plan will be evaluated periodically to ensure it remains fit-for-purpose by delivering on the Division’s
integrity commitment. Evaluation of the effectiveness of the Plan will be in accordance with the outcome
measures below and wil be undertaken with the monitoring and review of the Plan.
OUTCOME MEASURE
METHOD
RESPONSIBILITY
What wil be measured to
determine achievement - has the
How wil this be done?
Who is responsible for
plan purpose occurred?
evaluation?
Divisional staff emails
Accessible on intranet/Objective
Attendance at ‘Fraud and Ethics’ and
Integrity training sessions.
Undertaking eLearning on MyLearning,
Division staff are aware of Integrity which includes an assessment of the
Integrity Manager
risks and how to identify potential
participants’ knowledge and
instances of fraud and corruption
understanding of fraud, corruption and
Senior Directors, Directors,
and how to report
ethics
Team Leaders
Induction of new staff into Division
Divisional staff training on
commencement of the plan
Executives and managers regularly and
actively addressing integrity risk
prevention in business units
Divisional staff emails
Accessible on intranet/Objective
Attendance at ‘Fraud and Ethics’ and
Division staff are aware of the
Integrity training sessions.
Integrity Manager
Integrity Plan and their
Senior Directors, Directors,
responsibilities under the Plan
Induction of new staff into Division
Team Leaders
Divisional staff training on
commencement of the plan
Executives and managers promote the
Plan
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PLANNING DELIVERY DIVISION INTEGRITY PLAN 2020-22
RELATED RESOURCES
The table below provides an overview of broader resources which relate to this Plan and are useful
sources of additional information.
For a ful list of documents related to integrity matters please refer to the Fraud and Corruption
Prevention Plan 2019-2021.
RESOURCE LINK
Fraud Corruption and •
https://actgovernment.sharepoint.com/sites/Intranet-
Prevention Plan
EPSDD/Shared%20Documents/Fraud%20and%20Corruption%20Preve
ntion%20Plan%202019-
2021.pdf#search=fraud%20and%20corruption%20plan
SOPs
• See Planning Delivery objective files for relevant SOPs
Public Interest
Disclosures
•
https://www.planning.act.gov.au/about-us/public-interest-disclosures
Mandatory reporting •
https://www.integrity.act.gov.au/reporting-corruption/mandatory-
of corrupt conduct
reporting-of-corruption
Directorate
•
https://www.environment.act.gov.au/__data/assets/pdf_file/0010/1
Governance
305883/EPSDD-Governance-Commitment-Statement.pdf
Statement
•
https://www.cmtedd.act.gov.au/__data/assets/pdf_file/0006/101374
ACTPS Integrity Policy
8/Integrity-Policy.pdf
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PLANNING DELIVERY DIVISION INTEGRITY PLAN 2020-22
ATTACHMENTS
ATTACHMENT 1: KEY DEFINITIONS
TERM
DEFINITION
In relation to an employee, [corruption] means that the employee
seeks, obtains or receives any benefit, other than lawful salary and
al owances on the understanding that the employee wil do or
refrain from doing anything in the course of their duties or will
attempt to influence any other employee on behalf of any person.
Relevant examples of corruption for this Plan include:
Corruption (as defined in
• Unauthorised use of government facilities and time to operate
the ACTPS Integrity Policy
a private business
2010)
• Misusing information or material obtained during the course of
official duties
• Receiving personal benefits in exchange providing
inappropriate advantage to commercial partners (e.g. supplies,
Lessees, etc) or other (e.g. levy payers, developers etc)
• Not disclosing and/or allowing a conflict of interest to obtain a
preferred outcome.
Taking or obtaining by deception, money or another benefit from
the government when not entitled to the money or benefit, or
attempting to do so – this includes evading a liability to the
government.
Fraud is not restricted to obtaining monetary or material benefit.
Fraud (as defined in the
The benefits of fraudulent acts can either be tangible or intangible.
ACTPS Integrity Policy 2010) Relevant examples of fraud include:
• Assisting others to obtain a benefit
• Theft of money (cash, cheques, EFTPOS) due to the government
• Releasing misleading or inaccurate information for the purpose
of deceiving, misleading or to hide wrongdoing.
Corrupt conduct (as defined (1) For this Act corrupt conduct is conduct:
in the Integrity Commission
(a) that could:
Act 2018)
(i)
constitute a criminal offence; or
(ii)
constitute a serious disciplinary offence; or
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PLANNING DELIVERY DIVISION INTEGRITY PLAN 2020-22
(iii)
constitute reasonable grounds for dismissing,
dispensing with the services of, or otherwise
terminating the services of, a public official; and
(b) that is any of the following:
(i)
conduct by a public official that constitutes the
exercise of the public official’s functions as a public
official in a way that is not honest or is not
impartial;
(ii)
conduct by a public official or former public official
that:
(A) constitutes a breach of public trust; or
(B) constitutes the misuse of information or
material acquired by the official in the course
of performing their official functions, whether
or not the misuse is for the benefit of the
official or another person;
(iii)
conduct that adversely affects, either directly or
indirectly the honest or impartial exercise of
functions by a public official or a public sector
entity;
(iv)
conduct that:
(A) adversely affects, either directly or indirectly
the exercise of official functions by a public
official or public sector entity; and
(B) would constitute, if proved, an offence against
a provision of the Criminal Code, chapter 3
(Theft, fraud, bribery and related offences);
(v)
conduct that involves any of the following:
(A) collusive tendering;
(B) fraud in relation to applications for licences,
permits or other authorities under legislation
designed to protect health and safety, protect
the environment or facilitate the management
and commercial exploitation of resources;
(C) dishonestly obtaining or assisting in obtaining,
or dishonestly benefiting from, the payment or
application of public funds for private
advantage or the disposition of public assets
for private advantage;
(D) defrauding the public revenue;
(E) fraudulently obtaining or retaining
employment or appointment as a public
official;
(vi)
conduct engaged in by a person in relation to
conduct mentioned in subparagraphs (i) to (iv) (the
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PLANNING DELIVERY DIVISION INTEGRITY PLAN 2020-22
primary conduct), that would constitute an
offence against the Criminal Code, part 2.4
(Extensions of criminal responsibility) on the basis
that the primary conduct is an offence, whether or
not the primary conduct is in fact an offence.
(2) For subsection (1)(a) it does not matter if:
(a) proceedings or action in relation to the conduct can no
longer be taken; or
(b) the conduct happened outside the Territory.
(3) In this section:
criminal offence means a criminal offence under the law of the
Territory or under any other law relevant to the conduct in
question.
serious disciplinary offence includes:
(a) any serious misconduct; or
(b) any other matter that constitutes or may constitute
grounds for:
(i)
termination action under any law; or
(ii)
a significant employment penalty
Serious corrupt conduct (as serious corrupt conduct means corrupt conduct that is likely to
defined in the Integrity
threaten public confidence in the integrity of government or public
Commission Act 2018)
administration.
Systemic corrupt conduct
systemic corrupt conduct means instances of corrupt conduct that
(as defined in the Integrity
reveal a pattern of corrupt conduct in 1 or more public sector
Commission Act 2018)
entities.
The Division performs the statutory functions of the planning and
land authority through the development assessment and approvals
process. The Division also performs many land administration
Planning Delivery Division
functions including lease administration, deed management and
(the Division)
strategic assessments. The Division includes the Office of the
Surveyor-General and Land Information whose functions include
mapping, surveying approvals and the management of land
information databases.
19
PLANNING DELIVERY DIVISION INTEGRITY PLAN 2020-22
ATTACHMENT 2: ROLES AND RESPONSIBILITIES
The following roles and responsibilities are identified in the Plan.
ROLE
RESPONSIBILITY
• Ensure the Division has a current Integrity Plan and that this plan is
reviewed at least every two years
• Monitor the Plan’s implementation and coordinate any risk treatments
• Act as the primary senior executive point of contact for integrity
al egations, including fraud and corruption, and determine how
escalated allegations should be handled
Executive Group
• Mandatory reporting of any matter suspected of involving serious
Manager, Planning
corrupt conduct or systemic corrupt conduct to the Integrity
Delivery
Commission
• Promote a culture of a well-informed, engaged and ethical workforce
Executive Branch
• Provide oversight and make decisions on the direction of enquiries
Manager,
related to integrity, such as fraud and corruption
Development
• Ensure that Risk Registers reflect integrity risks and are regularly
Assessment
reviewed and updated
• Report to the Audit Committee, Executive Steering Committee, and
Executive Management Board on the implementation of the Plan
• Ensure that the Plan is brought to the attention of staff through training
sessions and regular communications
• Review effectiveness of integrity measures following significant
functional or structural changes.
• Appointed by the Executive Group Manager, Planning Delivery to the
role of Integrity Manager for the Division for the purposes of this plan
• Coordinates the implementation of the Integrity Plan with Senior
Directors, Directors and Team Leaders across the Division
• Coordinates the keeping of a Division Conflict of Interest Register
• Coordinates the undertaking of specific identified actions to deliver the
Integrity Manager
Integrity Plan
• Ensures all planning and land authority and internal Division
delegations are up-to-date, accurate, accessible and appropriately
stored
• Coordinate the attendance of staff at relevant training programs,
including development and delivery of training relating to this Plan and
staff obligations
20
PLANNING DELIVERY DIVISION INTEGRITY PLAN 2020-22
• Responsible for undertaking initial assessments of a
complaint/disclosure (and decide whether a disclosure is a public
interest disclosure), referral to the relevant Executive or the Legal
Services and Integrity team for further investigation, and act as a
central coordination point for all matters relating to integrity including
implementation of agreed actions, complaints and investigations
• A person appointed by the Executive Group Manager, Planning Delivery
Integrity Officer
to assist the Integrity Manager with the implementation and
administration of the Integrity Plan
• Take a lead role in entrenching a positive workplace integrity culture
Senior Directors,
• Report potential integrity incidents or system risks, and encourage
Directors, Team
team members to do the same
Leaders
• Work with the Integrity Manager to implement the actions of the
Integrity Plan and ensure staff are aware of their integrity obligations
and practices are entrenched within teams
• Become familiar with the Plan and contribute to its effective
implementation, thereby assisting in minimising the incidence of fraud,
corruption and corrupt conduct within the Division
• Report any fraudulent activity or corrupt behaviour within the Division
that they become aware of or suspect. Reports can be made to
managers/supervisors, the Integrity Manager, an Executive within the
Division, or EPSDD Legal Services and Integrity (as the situation
All staff
necessitates)
• Ensure declarations of any conflict of interest, either actual, potential
or perceived, are made as soon as practicable after the conflict
becomes apparent
• Comply with the
Public Sector Management Act 1994, specifically
section 9 – General obligations of public employees, the ACTPS Code of
Conduct and the ACTPS Values and Signature Behaviours.
21
PLANNING DELIVERY DIVISION INTEGRITY PLAN 2020-22
ATTACHMENT 3: INTEGRITY RISK ASSESSMENT
22
PLANNING DELIVERY DIVISION INTEGRITY PLAN 2020-22
ATTACHMENT 4: DIVISION INTEGRITY ACTION PLAN
23
Document Outline