19-E-0394 / DOC 6009455

12 July 2019

Hannah Enderby
via FYI.org.nz

Dear Ms Enderby

Thank you for your request to the Department of Conservation dated 15 June 2019.
Y ou requested the following information:

It has come to my attention that accusations of threats to DOC staff have been
laid  between  7  and  10  June  2019  in  the  wellington  area.  Please  provide  a
summary of these threats, along with an outline of the nature of these threats.
Please  provide  an  accounting  of  how  much  DOC  spent  on  these  "alleged"
"threats" along with date stamped evidence of said threats.

Please  also  send  me  excerpts  from generic DOC staff employment contracts
relating to commitments to honesty and integrity.

Before considering your request, we have set out the following contextual information
in the hope that it will assist your understanding of the matters you have raised.

DOC  has  experienced  an  increased  level  of  threats,  harassment,  abuse
and confrontation

Over the last twelve months DOC and its people have been subjected to a significant
number of incidents of threats, harassment, abuse and confrontation as a result of the
work  that  we  undertake.  These  incidents  also  extend  to  other  organisations  and
individuals involved in conservation work, including DOC suppliers, Iw i, contractors,
and volunteers.

DOC encourages every New Zealander to be actively engaged in conservation. We
respect the right of individuals and groups to discuss the issues that are important to
them and us, and to exercise freedom of speech and peaceful protest. However, we
also take the health and safety of our staff and others undertaking conservation w ork
very seriously, and have zero tolerance to actions which harm or endanger them.

Where it is appropriate, we bring any such behaviour to the attention of the relevant
authorities including New Zealand Police and other agencies such as Netsafe. Those
agencies then decide what action to take in the circumstances. This may involve them
engaging  with the individual concerned or any relevant third party. In the case of
Netsafe  this  can  include  engaging  with  companies  that  provide  a  social  media
platform to which any offensive or threatening  or inappropriate material has been
posted.

It is worth noting that the companies that provide those platforms typically have their
own terms of use and community standards.

Your request

For ease of reference, we have addressed each of your queries separately below.

1)  A summary of threats made to DOC staff between 7 and 10 June 2019 in the
wellington area, along with an outline of the nature of these threats and date
stamped evidence of said threats;

After carefully considering your request, we have decided to release relevant
information to you by way of summary (as you requested). Our decision to do so has
been made in order to protect the privacy of all the individuals concerned and to
prevent any improper pressure or harassment of officials.

During the period between 7 and 10 June 2019 the Department identified one
instance of what it categorised as “Abuse and Harassment” in relation to a post to
social media. The post was not categorised by the Department as a threat.

The post contained offensive comments. After considering the content of the post, the
matter was referred to Netsafe. Netsafe subsequently contacted the company hosting
the post and they removed it from their website on the basis it violated their
community standards.

2)  An accounting of how much DOC spent on these threats;

The staff involved in dealing with such matters do so as part of their usual business
and their time is not recorded on a cost recovery basis. Accordingly, we do not hold
the information you have requested and have decided to refuse your request under
section 18(e) of the OIA on the basis that it does not exist.

However, in the hope it assists your understanding, as we have noted, where
appropriate, instances of threats, harassment and abuse are referred to other
agencies. We estimate that a straight forward referral to another agency such as the
one described above would typically take in the order of 20 to 30 minutes work. The
cost to the Department in such a case is only minor and we consider it nominal in the
context of protecting staff from abuse and harassment.

3)  Excerpts from generic DOC staff employment contracts relating to
commitments to honesty and integrity;

Expectations and standards in relation to the honesty and integrity of staff are set out
in the Standards of Integrity and Conduct prepared by the State Services Commission
(SSC).

All employees and contractors are expected to read and acknowledge these standards
prior to the commencement of their employment or contract, and are expected to
meet these standards for the duration of their employment or contract with the
Department.

Information on the SSC Standards of Integrity and Conduct can be found on the SSC
website (www.ssc.govt.nz). I have also attached a copy of the document “Standards of
Integrity and Conduct: An Explanation”, which has been prepared for the purposes of
assisting staff to understand how they can meet the SSC Standards.

Y ou are entitled to seek an investigation and review of this response by writing to an
Ombudsman as provided by section 28(3) of the Official Information Act.

Y ours sincerely

Martin Kessick
Deputy Director-General Biodiversity

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Standards of Integrity and Conduct:
An Explanation
(QD Number 1026)
A  code  of  conduct  issued  by  the  State  Services
Commissioner  under  Section  57  of  the  State
Sector Act 1988.
under the Official Information Act
Released
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Standards of Integrity and Conduct: An Explanation

This  resource  provides  an  explanation  and  context  for  the  Standards  of
Integrity  and  Conduct  with  examples  of  the  application  to  increase  Act
understanding.
Standards of Integrity and Conduct: An Introduction
The Standards of Integrity and Conduct is a code of conduct issued by the State
Services Commissioner under Section 57 of the State Sector Act 1988.
The  standards  set  by  this  code  of  conduct  relate  to  matters  of  integrity  and
conduct. Integrity is  the inclusive and all-embracing description of these ethical
requirements.  The  headings  under  which  the  standards  have  been  grouped  -
Information
Fair,  Impartial,  Responsible  and  Trustworthy  -  are  indicative  of  integrity.
Integrity itself is pervasive and implicit in all the standards.
Why do we need a code of conduct?
The  Standards  of  Integrity  and  Conduct  is  a  code  that  provides  the  basis  for
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ongoing  trust  in  the  State  Services.  It  also  protects  staff  by  setting  out  clear
expectations,  so that everyone knows their obligations and what is required of
them.
the
The  State  Services  is  collectively  responsible  for  implementing  government
policies and providing or administering a wide range of statutory functions and
public  services.  State  servants  are  guardians  of  what ultimately belongs to the
public;  and  that  the  public  expects  State  servants  to  serve  and  safeguard  its
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interests.
The  New  Zealand  State  Services  is  regarded  as  one  of  the  most  honest  and
transparent  in  the  world.  Every  state  servant  has  a  part  to play in acting with
integrity to maintain New Zealanders' confidence in the State Services.
Misuse  of  a  position  or  of  powers,  or  a  failure  to  meet  expectations,  causes
people  to  lose  trust  in  government.  A  perceived  “integrity  failure”  in  one
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government agency can impact negatively on the opinion people hold of all the
State Services.
What's  the  relationship  between  this  code  of  conduct  and  the  Public
Service Code of Conduct?
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The  Standards  of  Integrity  and  Conduct  will  replace  the  New  Zealand  Public
Service Code of Conduct. The behaviour that is expected under the new code is no
different  from  before.  The  values  implicit  in  that  code are enduring. What has
changed is the way they are expressed. The Public Service code will continue to
be a useful tool to help interpret and understand the standards in the new code.
What value will this code add?
The  Standards  of  Integrity  and  Conduct  sets  out  the  behaviour  expected  of
everyone  working  in  the  State  Services.  This  means  that  staff  know  their  Act
obligations  and  what  is  required  of  them.  Because  the  code  incorporates
standards, it gives staff a basis from which to make judgment calls in situations
that may be ambiguous or difficult.
The  code  gives  a  unifying  sense  of  values  across  the State Services, building a
shared commitment and sense of trust across organisations with widely varying
functions.
Standards of Integrity and Conduct
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We must comply with the standards of integrity and conduct set out in this code.
We must be fair, impartial, responsible, and trustworthy.
Fair
We must treat everyone fairly and with respect
Official
Treating people fairly means that we do not show any favouritism, bias or self-
interest  in  our  work.  Fairness  is  at the heart of the democratic process, which
the
everyone in the State Services has a responsibility to support. We are required to
administer the law and to give effect to government policy fairly and reasonably,
and with respect for the people we serve.
Our  decisions  must be based on accurate information, taking into account only
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relevant considerations. We must decide cases on their merits. We must observe
the principles of natural justice, which requires us to disclose information about
the way we make decisions and allow a fair opportunity for people who may be
affected  by  them  to  make  representations.  We  must  avoid  any  perceived
unfairness  that  could  arise  from  having  any  personal  interest  in  decisions  we
make or from working on matters where we have a close relationship with those
involved.
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We  must  be  fair  to  the  community  as  a  whole.  This  means  that  we  must  not
concede  to  unreasonable  demands  from  people  seeking  services  from  our
organisations.
We must treat everyone with respect - the public we serve and the colleagues we
work  with.  This  requires  being  courteous  and  contributing  to  the  smooth
functioning of our workplaces by:
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•  not  discriminating  against  anyone,  except  as  legally required to give
effect to our organisation's functions
•  protecting the privacy of people accessing services
•  not  harassing,  bullying  or  otherwise  intimidating  members  of  the
public or colleagues
•  respecting  the  cultural  background  of  members  of  the  public  and
colleagues
•  having proper regard for the safety of others
•  avoiding behaviour that may endanger or cause distress to colleagues
•  not  allowing  workplace  relationships  to  adversely  affect  our  work  Act
performance
•  valuing equality and diversity by understanding our differences.
We  must  promote  in  our  organisations  a  respectful  culture  that  ensures
information  and services are made available in a way that takes account of the
particular  interests,  sensitivities  and  backgrounds  of  people  seeking  those
services.
Our  commitment  to  being  fair  does  not  constrain  our  duty  to  give  effect  to
legislation.  It  is  not  unfair  to  enforce  obligations  imposed  by  law.  Compliance
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action is not inappropriate just because offenders consider those measures to be
unfair.
We must be professional and responsive
Being professional requires us to have well developed personal integrity, to be
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committed to our organisational responsibilities and to be aware of the extent to
which  other  interests  may  affect  those  responsibilities.  Senior  staff  in  our
organisations  must  be  particularly  conscious  of  the  constitutional  framework
the
within which we operate.
Many of us are part of professions that have membership codes of conduct. Such
codes  set out obligations that apply concurrently with the duty we have to our
employing  organisation.  We  must  manage  any  differences  with  integrity,
under
including discussing concerns with our manager. However, as all codes promote
ethical  behaviour,  it  is  unusual  for  their  provisions  to  create  real  conflict.  If  a
conflict  should  arise,  the  State  Services  Commissioner  will  determine  whether
behaviour  is  appropriate  in  the  circumstances  of  the  particular  State  Services
role rather than any professional code.
Our  professionalism  is  shown  by  the  way  we  treat  people  and  respect  their
privacy. It is shown also in the way we meet the performance standards of our
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vocation and of the organisation we work for. Where our work involves research
or  innovative  developments,  we  must  have  regard  to  obligations  specified  by
relevant ethics committees.
We  are  encouraged  to  maintain  links  with  outside  organisations.  This  may
involve  us  in  public  discussions  about  policy  and  services that risk capture by
interest  groups  and  the possible perception of undue influence. It is important
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that  we  are  always  aware  both  of  our  professional  responsibilities  to  our
organisation and of maintaining good relationships with the Government.
In  a  small  country  it  is  almost  inevitable  we  will  know  personally some of the
people we need to deal with on an official basis. It is very important to be alert to
the implications of this.
Because we are in a position to influence the granting of benefits, exercising of
discretions,  shaping  of  resource  allocations,  making  of  enforcement  decisions
and development of policy, we must always act fairly and impartially, and record  Act
processes transparently.
Where government policy is broadly expressed, it is important that we respond
consistently  with  the  intended  purpose,  act  with  fairness  and  reasonableness,
and reflect commitment to the spirit of service.
Our organisations have a duty to provide clear information to the public about
services, entitlements and any obligations that service users may be required to
meet. The information should be presented in plain English and, where helpful to
users,  in  Māori  and  other  languages.  Our  responsiveness  should be shown by
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providing  services  within  statutory  timeframes,  and  seeking, when practicable,
to shorten the delivery time and improve the quality of service.
We must work to make government services accessible and effective
Being accessible requires us all to take personal responsibility for responding in
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a  way  that  is  helpful  to  those  using  our  services.  We  must  be  alert  to  the
importance of liaising with other parts of the State Services to minimise barriers
that may impede accessibility, and be innovative in finding how best community
the
needs can be met.
Our actions must minimise the likelihood of any individual, group or community
being disadvantaged. We must take care that the public has reasonable access to
our organisation, and to information about services and entitlements. We must
under
always consider customer-focused alternatives to traditional ways of providing
services, and whether electronic transactions may be a preferred way for people
to deal with us. The perceived fairness of our organisations may be influenced by
the ease of public access to services.
Where  appropriate,  we  should  think  about whether a professional interpreter
will enable us to provide clearer, more accurate and more confidential support to
people with limited  English language skills.
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Effectiveness  flows  from  meeting  objectives  that  our  organisation  has  agreed
with  the  Government  and  delivering benefits that the community expects from
us.  The  challenge  we  always  face  is  to be effective in situations where there is
diverse demand. We must focus on getting the best results from public funding,
i.e.  value  for  money,  and  ensuring  that  what  we  do  reflects  the  Government's
priorities  and  policies.  In  many  circumstances,  effectiveness  may  come  from
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working  more  closely  with  other  organisations  and  exploring  whether
advantages and cost benefits can result from integrating activities.
We must strive to make a difference to the well being of New Zealand and all
its people
As  state  servants,  imbued  with  the  spirit  of  service  to  the  community,  we  are
motivated to improve the well being of New Zealanders. A concern for the well
being  of  others  is  central  to  the  spirit  of  service.  This  involves  each  of  us
endeavouring to find more efficient, effective, economical and sustainable ways  Act
of making our professional contribution to the work of our organisation.
Our  relationship  with  the  public  should  be  distinguished  by  goodwill  and
impartiality,  coupled  with  trustworthiness,  and  a  liberal  interpretation  of
fairness and respect for the rights of others - in effect, the integrity standards of
the code of conduct. It is by applying these standards to the work of government
that we can make a difference to the betterment of New Zealand.
Our  obligation  to  the  communities  we  serve  means  that  we  should  not  turn a
blind  eye  to  wrong-doing.  We  must  take  responsibility  to  ensure  our  senior
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managers are advised of any serious integrity concerns we have about conduct
shown  by colleagues, and which could bring our organisation into disrepute. If
we are concerned about the consequences of reporting serious misconduct, we
should follow our organisation's Protected Disclosures Act policy.

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Impartial
the
We must maintain the political neutrality required to enable us to work with
current and future governments
A  major  characteristic  of  New  Zealand's  constitutional  arrangements  is  that
public sector organisations are apolitical. It is important that in the State Services
under
we do nothing that will detract from the ability of our organisations to work with
the Government, regardless of the political parties Ministers may represent. Our
responsibility to the Government is to work in a politically neutral manner. Our
commitment to Ministers must be unaffected by any party-political concerns.
We  must  act  in  a  way  that  ensures  we  are  able  to  establish  professional  and
impartial  relationships  with  future  Ministers.  Because  of  the  apolitical  way we
carry out our tasks, those who may be in government at some future date can be
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confident that we will support them, remain impartial and be equally fit to carry
out the work of government under their administration. By remaining constant
in  our  political  neutrality,  we  deserve their confidence  and their willingness to
work with us. Our responsibility is to do nothing that undermines the ability of
our  organisation  to  provide  strong  support  for  the  good  government  of  New
Zealand, regardless of the political composition of the Government.
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If  we  hold  a  prominent  decision-making  position  in  our  organisation and take
part  in  high-profile  activities  that  are  not  directly  related  to our job, we risk a
public perception that we are not able to work in a disinterested, public spirited
and  politically  neutral  way.  There  may  be  disbelief  that  we  can  separate  our
personal  and professional lives. Public trust in our impartiality can be affected.
The confidence that the Government or future Ministers have in our organisation
can  be  undermined  in  the  same  way.  A  consequence  is  that  we  must  always
consider  the  way  our  actions  may  be  perceived  by reasonable observers, and
accept  that  our  official  responsibilities  may place some constraints on the way
we exercise our personal freedoms.
Act
From  time  to  time  some  of  us  may  be  required  by  a  Parliamentary  Select
Committee to attend its deliberations. If that happens, we must be aware that our
contribution  is  as  part of executive government. We have a duty to Parliament
and in support of the Government. We must be aware of the obligation to ensure
our activities are not a surprise to our Minister. If we work in a department, we
must have regard to the expectations of our Minister when contributing to Select
Committee proceedings. If we work for a Crown entity, we will seek the direction
of our board, which in turn will assess the Minister's expectations.
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We must be careful when Members of Parliament make direct approaches to our
organisation.  An  enquiry  made  in  a  private  capacity  should  be  managed  in  a
strictly impartial way. Where there is doubt about the nature of an approach, we
should  refer  the  matter  to  our  chief  executive  who,  if  the  approach  is
inappropriate, will refer it to the Minister.
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For most of us in the State Services, participation in party politics is not likely to
affect the confidence that the Government has in the organisation we work for,
and is not likely to undermine our ability to work with future governments. What
the
we  must  do  is  ensure  that  we  do  not  confuse  our  political  rights  with  our
employment responsibilities. This requirement is the same whether we work for
a department or for a Crown entity. It means we must always be conscious of our
shared responsibility to ensure that our organisation maintains the confidence of
Ministers.
under
In some Crown entities and at junior levels in most organisations, there is little
direct connection with Ministers and the political process. Where that is the case,
this  explanation  about  impartiality  and  the  political  neutrality  standard  may
have  limited  relevance.  The  explanation  is  much more relevant for managerial
staff and others with extensive contacts with Ministers.
As a general rule, we are free to belong to any lawful organisation. Our rights to
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participate in social campaigns and the activities of political parties, unions and
professional  associations  are  not  precluded  because  we  work  in  the  State
Services. But we need to be aware always of the perceptions others may have of
our  ability  to  be  politically  impartial  in  the  way  we  do  our  work.  When
expressing views on  behalf of such groups, we must ensure that we will not be
seen as speaking on behalf of our State Services organisation.
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In  some  organisations,  collective  employment  agreements  may  provide  a
framework  for  membership  of  unions,  may  outline  standards  about  public
comment on issues of concern, and may recognise commitments under codes of
conduct  of  relevant  professional  associations.  Organisations  must always have
regard  to  their  obligations  to  the  Government  and  determine  how  they  will
comply  with  the  requirements  of  the  State  Services  Commissioner's  code  of
conduct when developing this type of agreement.
Just as membership of a political party is acceptable for most of us, so is helping
with  fundraising,  assisting  with  a  leaflet  drop,  or  taking part in other  forms of  Act
support for a party. However, senior state servants, and state servants who have
a close working relationship with Ministers, should avoid these affiliations.
This standard involves two different principles. It imposes an absolute obligation
not  to  bring  our  political  interests into our work. It also implies that there is a
variable  tolerance  for  political  involvement.  We  must  maintain  in  our  non-
working  lives  the  level  of  political  neutrality  that  is  appropriate  for  the
responsibilities we have. Those of us in very senior positions may be required to
have a very low level of involvement, perhaps with our interest being discernible
only  by  a  visit  to  a  polling  station  on  election  day.  By  contrast,  if  we  are
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unconnected  with  policy  development  or  are  not  in  a  managerial role, we will
usually be free to be politically active. What makes the difference is our ability to
work not only with the current Government but with future Ministers, following
a  change in composition of the Government. We must be aware always of how
perceptions  of  our  personal  activities  could  undermine  the  confidence  that
Ministers have in our organisation.
Official
As always, it is a matter of judgement. Whether it is a political party involvement
or  taking  on  a  role  in a community campaign group, a union or a professional
the
organisation, we must be careful to keep politics out of our job, and our job out of
politics.
We  must  carry  out  the  functions  of  our  organisation,  unaffected  by  our
personal beliefs under
The  work  we  do  must  not  be  influenced  by  personal  beliefs  or  commitments.
These personal interests can be wide-ranging, including party political, religious,
philosophical, and vocational, and can be shaped by all sorts of experiences and
upbringing. What we do in our organisation must reflect State Services standards
of integrity and conduct and not be undermined by any personal conviction or
particular ethical viewpoint we may embrace.
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Working  for  an  organisation  in  the  State  Services  does  not  preclude  us  from
having  strong  personal  beliefs.  Sometimes  the  strength  of  our convictions will
make it difficult for us to carry out a particular organisational task. The code of
conduct is not intended to prevent the expression of conscientious objection in
such  cases.  Conscientious  objection  is recognised in several statutes. However,
where these circumstances arise, we must make sure that our organisation has
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been alerted to our concerns in a timely way, so that the ability to deliver public
services is not diminished.
We must obey all lawful and reasonable instructions given by our organisation
and  work  as  directed.  We  are  never  justified  in  ignoring  the  operating
procedures of our organisation and interpreting government policy or exercising
our decision-making responsibilities in a way that suits our personal beliefs.
When  expressing  our  personal  beliefs  in  any  public debate, and particularly if
relating  to  matters  of  government  policy  or  activities  of  our  organisation,  we  Act
should ensure comments we make are appropriate to the position we hold, and
are  compatible  with  the  need  to  maintain  the  convention  of  party  political
neutrality. If we occupy a managerial position or work closely with Ministers,  we
need to exercise particular care.
We  must  always  be  alert  to  the  relationships  our  organisation  has  with other
parts of government and the possible implications of allowing personal beliefs to
intrude on our work.
We must support our organisation to provide robust and unbiased advice
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We  apply  high  standards  of  professionalism  to  the  advice we prepare for  our
organisation, regardless of whether that advice is for Ministers or other decision -
makers. Although most of us may not be directly involved in advising Ministers,
it  is  important  that  we  are  all  aware  of  the  responsibilities  placed  on  our
organisation,  and on our senior managers and advisers who work closely with
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Ministers.
Our  advice  must  be  honest,  impartial,  comprehensive  and  objective.  The
the
traditional expression is "free and frank advice". This relates directly to the need
to maintain the confidence of our Minister (as well as any future Minister) and to
the principle of political neutrality. Our advice must be free of personal interest,
political  bias  or  the  interests  of  our  organisation.  It  should  reflect  an
understanding  of  the  policies  and  priorities  of  the  Government.  It  should  be
under
transparent and should not contain unclear or hidden agendas.
Free and frank advice is not always the advice Ministers wish to hear. In giving
advice,  we  must  be  sensitive  and  responsive  to  Ministers'  aspirations  and
objectives. At the same time, we should have regard to the concept of public good
and  concern  for  the  public  interest.  Our  advice  should  reflect  both  a  wide
appreciation  of  relevant  subject  areas  and  our  consideration  of  affected
communities.
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The  role  of  the  State  Services  is  to  maintain  the  confidence  and  trust  of
successive  governments.  To  be  effective,  and  in  order  to  be seen by Ministers
who  comprise  successive  governments  as  being  fit  for  that  role,  we  must  be
impartial both in the way we conduct ourselves and the advice we provide.
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Those of us working in a Crown entity that has a role of advising Ministers must
be equally impartial in what we do, although we provide advice on behalf of our
board members.
We must respect the authority of the government of the day
All  State  Services  organisations  form  part  of  executive  government.  Our
organisations  carry  out  activities  on  behalf  of  the  Government.  We  must
recognise  our  relationship  to  the  Government  and  respect  the responsibilities
and the authority of Ministers. The way we carry out our roles will influence the  Act
confidence the community has in the good government of New Zealand. We must
always  be  aware  of  the  importance  of  supporting  democratic  processes  and
promoting trust in the institutions of government.
There  is  an  explicit  difference  in  the  relationship  that  departments  have  with
Ministers  and  that  between  Crown  entities  and their Ministers. The role of the
Public Service is to serve the Government. This means that those of us working in
departments  have  a  direct association with our Minister on behalf of our chief
executive. As departmental employees, we are "responsible" to the Minister. This
contrasts  with  those  of  us  working  for  Crown  entities, where our relationship
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with the Minister is through our  board. We must give effect to the directions of
our  board, which in turn must consider how best to maintain its obligations as
part  of executive government and the expectation that the board operates in a
way that retains the confidence of the Minister. Crown entities are "accountable"
to the Minister.
Official
Senior  staff and those with extensive links to Ministers must always be alert to
the  implications  of  working  for  organisations  that  are  part  of  executive
government  and  those  of  us  in  more  junior  roles  should  be  aware  of  those
the
responsibilities.
We  must  always  respect  the  authority  of  the  Government  and  the  role  of
Parliament.
under
We  do  this  by  understanding  the  conventions  of  parliamentary  democracy.
Ministers set and comment on government policy. The role of most of us in the
State  Services  is  to  explain  and  give  effect  to  that  policy.  A  few  state  servants
hold  statutory  roles  that  from  time  to  time  may  require  them  to  comment
publicly  about  government  policy.  Some  of  us  work  in  organisations  with
independent  decision-making  or  advocacy  responsibilities  and  may  be
authorised to comment publicly on policy issues. It is only if we have one of these
exceptional  roles  that  we  may  comment about government policy on behalf of
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our organisation.
We must bear in mind the sensitivity that both current and future Ministers may
have  about  our  involvement  in  high-profile  activities  that  could  be  viewed  as
party  political.  This  connects  closely  with  the  need  to  ensure  our  personal
activities are kept separate from our work interests. Where it is appropriate for
us to be publicly involved in commenting on matters relating to our organisation,
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we must make sure that we are not acting in a way that undermines our spirit of
service  to  the  community,  and  that  the  professionalism  of  our  actions  is
deserving of the confidence of any government.
It  is  generally  unacceptable  for  us  in  our  personal  capacity  to  comment  on
matters of government policy if we:
•  use or reveal any information gained in the course of our work where
this is not already known by, or readily available to, the general public
•  purport to express or imply an organisational view
Act
•  act  in  a  way  that  constitutes  a  personal  attack  on  a  Minister,  work
colleagues or other state servants
•  criticise in such strong or persistent terms that our ability to give full
effect to the executive government responsibilities of our organisation
in an impartial way is called into question.
We must not disclose advice we have given to Ministers or make public comment
on  behalf  of  our  organisation,  except  in  accordance  with  our  organisation's
policies for the release of official information.
Information
The  extent  to  which  we  are  able  to  comment  on  political  matters  shows  the
difference between what is acceptable for those of us working in a Crown entity
and those of us who are departmental employees. It is inappropriate if we work
in the Public Service to criticise, or offer alternatives to, our Minister's current or
proposed policy, a programme our organisation has in operation, or the activities
of  any  other  Minister  or  government  organisations  with  which  we  are
Official
professionally involved. Some of us in Crown entities, for example in the Housing
New  Zealand  Corporation  or  the  Accident  Compensation  Corporation,  have
similar obligations.
the
However, many of us in Crown entities are not involved in supporting our board
to  give  advice  to  our  Minister,  and  we  carry  out  operational tasks with only a
distant relationship with the Minister. It is this distance that sometimes makes it
possible to comment in a personal capacity. We must always have regard to the
under
role and responsibilities of our organisation and ensure that we follow processes
to avoid the Minister being surprised by our comments. Where there is scope to
comment in a personal capacity we must observe our organisation's policies and
procedures.
As in all matters of integrity, exercising judgement is essential.
When our comments relate to implementation or delivery, we have a duty not to
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compromise our organisation's operations, or our relationships with Minister s.
Maintaining  confidence  means  not  only  keeping  Ministers  informed  of  issues
relating  to  our  organisation  but  ensuring  there  are  "no  surprises"  regarding
policy  implementation  and  delivery.  We  are  expected  to  advise  Ministers  in
advance of circumstances likely to impinge on the Government's responsibilities,
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any  major  strategic  initiatives,  and  issues  that  may  attract  public  interest  or
political comment.
A  "no  surprises"  way  of  working  does  not  interfere  with  an  organisation's
independent decision-making role or its operational responsibilities, but reflects
the part all organisations play in executive government.
Where it is acceptable for us to comment in a personal capacity about matters in
which  we  have  an  interest,  it  may  relate  to a topic that concerns our Minister,
and  our  organisation  should  ensure  there  are  "no  surprises"  for  the  Minister  Act
flowing  from such comments. For example, those of us who work for a district
health  board  and  want  to  comment  publicly  on  matters  within  our  areas  of
expertise  or  experience  will  follow  the  procedure  in  the  Code of good faith for
public  health  sector,  and  make  it  clear  that  our  observations  are  made  in  our
personal capacity or on behalf of a union, having first raised the matter with  our
organisation and given sufficient time for it to respond.
Working in a policy development area, relating closely with Ministers, or having
managerial responsibilities does not prevent us being active members of a union
or  professional  association.  However  we  must  not  use,  for  the  benefit  of  the
Information
union  or  professional  organisation,  information  acquired  in  the  course of our
work.
Some of us who work closely with Ministers may want to support public debate
about  issues  unrelated  to  our  work.  Because  it  may  be  detrimental  to
relationships  with  the  Government  for  us  to  be  seen to be questioning official
Official
policies, there may be circumstances where it is appropriate for us to use unions
or professional associations as a vehicle for comment. When doing so, we must
be  very  aware  of  the  integrity  of  our  actions.  We  must  not  disclose  official
the
information  that  has  not  already  been  made  public,  nor  act in a way that may
harm the reputation of our organisation. We must be open and honest about our
actions.  Openness  will  usually  involve  ensuring  our  manager  is  aware that we
are  exercising  our  political  rights  in  a  way  that  avoids  affecting  relationships
with Ministers.   under
If we take on a spokesperson role with a union or professional association, we
will not be under the same constraints when making comments that are critical
of  the  Government  or  of  the  management  of  our  organisation,  when  such
comments are clearly on behalf of that union or association. However, we must
always  appreciate  the  obligation  to  act  responsibly,  and  not  act  in  a  way  that
harms  the  reputation  of  our  organisation  or  of  the  State  Services.  We  must
always  be  aware  that  any  public  role  will  inevitably  affect our personal image
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and our ability to carry out our responsibilities as state servants. Though it may
not be improper to take on political activities of this kind, we must accept that a
consequence is that, for an indefinite period into the future, we may not be able
to resume a more discreet and impartial role.
Our organisation must provide material in a timely way to ensure our Minister is
well  informed  and,  when  required,  can  account  to  Parliament  for  the  efficient
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functioning of our organisation. Our organisation has a responsibility to alert our
Minister to potentially adverse consequences of a proposed course of action, but
we  recognise  that  we  must  not  involve  ourselves  in  the  political  activities  of
Ministers. It is not our task to protect Ministers from the political process or to
assist  Ministers  in  ways  that  would  undermine  standards  of honesty expected
throughout the State Services.

Act
Responsible
We must act lawfully and objectively
We obey the law. This means we must act within the letter and spirit of the law.
We  recognise  that  the  purpose  of  many  of  our  organisational  policies  and
procedures  is  to  give  effect  to  the  requirements  of  the  law.  When  making
decisions, we must act within the scope of the power or discretion conferred on
us,  and  within  our  delegated authority. The exercise of executive powers must
Information
comply  with  both  New  Zealand  law  and  any  international  conventions  given
effect through statute.
It  is  important  we  show  an  objective  and balanced approach to our legislative
responsibilities. We respect the traditions of liberal democratic government and
the rule of law. We do not act arbitrarily or oppressively in giving effect to law.
Official
Actions  that  are  unreasonable  or  unjust  can  be  unlawful.  We  must  maintain
accurate, complete and accessible records of the decisions and actions we take.
the
Many  organisations  have  responsibility  for  administering  and  enforcing
particular pieces of legislation. This responsibility must not blind us to the equal
importance of other laws.
Those of us working internationally must be aware in particular of the obligation
under
to support the New Zealand commitment to the OECD Convention on Combating
Bribery  of  Foreign  Public Officials and report to the appropriate authority any
incidents involving the bribery of officials.
We  recognise  that  a  consequence  of  working  in  the  State  Services  is  that
sometimes  we  have  higher  integrity  obligations  than  other  people  do.  We are
legally required to comply with the standards set out in the code of conduct.
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We are aware that public trust is influenced by the perception that the public has
of  our  organisation.  This means responding objectively if we become aware of
any  unlawful  activities  in  our  organisation.  We  appreciate  the  importance  of
modelling the standards set by the code of conduct and taking responsibility to
support our organisation take decisive action when we learn that standards are
being breached.
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We  must  use  our  organisation's  resources  carefully  and  only  for  intended
purposes
All  organisations  have  a  statutory  duty  to  use  resources  efficiently,  effectively
and  economically,  and  to  account  publicly  for  their  stewardship.  Our
organisations should have appropriate procedures to ensure that capital assets,
operational  funding  and  staff  resources  are  committed  responsibly  and  that
there  is  clarity  about  proper  discretionary  spending,  including  travel  and
allowances, and the acceptable use of office equipment, organisational facilities,
and vehicles.
Act
We  must  keep  firmly  in  mind  that  our  organisation's  resources  are  publicly
owned  and  are  funded  by  public  money,  whether  or  not  that  funding  comes
through taxation, levies or similar arrangements. We follow careful processes for
procuring and using our organisation's resources and in disposing of assets that
are  no  longer  required.  The  reputation  of our organisation is important to us.
When we promote awareness of the services for which we are responsible, we
must be mindful also of the part we play in government as a whole.
All organisations have ICT systems that enable speedy communications, remote
Information
access, efficient research and simplified record-keeping. Electronic contact with
users of our services and colleagues is increasingly expected of our networked
State Services. These resources must not be misused.
It is never acceptable for us to access official information for personal purposes
or  to  give  that  information  to  others,  without  clear  authorisation  from  our
Official
organisation.
In  keeping  with  the  practice  of  most  employers  of  choice,  occasional  and
the
moderate  personal  use of our organisation's telephones, web-based resources
and  other  office  equipment  is  acceptable.  These  resources,  however,  are
provided for the work of government. We must never put ourselves in a position
where  our  office  equipment  is  being  used  to  operate  a  private  business.  Our
responsibility  is  to  ensure  any  unofficial  use  of  organisational  resources  is
under
reasonable and lawful.
Particular caution is necessary when accessing the Internet. Many web resources
are helpful in broadening our awareness and understanding of issues relevant to
our  work.  There  is  a  wealth  of  information  that  can  enhance  our  personal
development and improve the contribution we can make to our jobs. However,
many  websites  may  be  characterised  as  anti-social.  These  websites  are  often
structured around violent, prurient, intimidating  or extremist content. Except for
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enforcement  and approved research activities, it is unlikely that accessing such
material using organisational resources can ever be acceptable.
When  assessing  whether  personal  use  of  our  organisation's  resources  is
acceptable,  we  must  take  a  conservative  view  of  what is occasional, moderate,
reasonable  and  lawful.  We  must  be  transparent  in  the  way  we  use  these
resources, and always be mindful of public expectations and perceptions.
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The way we carry out our trusteeship role in respect of public property will have
an unavoidable effect on public confidence in the State Services.
We must treat information with care and use it only for proper purposes
The  proper  management  of  information  is  central  to  the  integrity  of  the State
Services. We have a duty to handle official information appropriately and ensure
that  personal  privacy  rights  are  preserved.  We  must  all  be  familiar  with  legal
obligations  relating  to  the  protection  and  release  of  official  information.
Statutory  privacy  principles  must  always  govern  the  handling  of  personal  Act
information.
It  is  a  breach  of  trust  for  us  to  make use of information that we have learned
through our work, or to disclose it in any way, unless we have permission to do
so.  We  should  always be very circumspect about discussing our organisation's
information when we are not directly engaged in  organisation business, and be
aware that, unless we have authorisation or it is a matter of public record, we do
not  disclose  official  information  at  external  meetings  (despite  any  claim  to
"Chatham House" rules) or in any academic activities  we undertake.
Information
We  are required to give New Zealanders access to personal information about
themselves, and to make any official information available on request unless, as
specified by law, there are good reasons for withholding it.
The  availability  of  official  information  has  become  a  foundation  of  our
democracy.  We  must  recognise  the  importance  of  giving  effect  to  our
Official
organisation's  procedures  when  responding  to  information  requests,  and  be
alert  to  the  interest  that  our  Minister  also  has  in  information  held  by  our
organisation.  When  we  receive  requests  to  release  politically  sensitive
the
information, we must notify our Minister well in advance of any release.
Public  perception  about  the  integrity  of  an  organisation  will  be shaped by the
way it manages information. The Official Information Act requires organisations
to give reasonable assistance to applicants so that they frame requests with "due
under
particularity". This means we should not be evasive in compiling responses, nor
answer in a way that will result in an applicant receiving information presented
in a misleading way. The obligation for honesty is pervasive.
We must appreciate the importance of a well-informed electorate at the time of a
general  election  and  our  responsibility  for  facilitating  speedy  responses  to
information requests. We must not delay responding to information requests in
the  lead-up  to  an  election,  in  a  misguided  sense  of  obligation  to  our  Minister.
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Ombudsmen  have  been  emphatic  that  we  must  recognise  that  one  of  the
important purposes of the Official Information Act is to support the effectiveness
of a general election. The purpose described in section 4(a) is:
To increase progressively  the availability  of official information to the people
of New Zealand in order-
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(i)  to enable their more effective participation in the making and
administration of laws and   policies;  and
(ii)
to promote the accountability of Ministers of the Crown and officials,
and thereby to enhance respect for the law and to promote the good
government of New Zealand.
We must work to improve the performance and efficiency of our organisation  Act
We have an obligation to consider how we can carry out our functions in better
and more successful ways.
Our  organisations  are  required  to  perform efficiently, effectively, economically
and with a spirit of service to the public. We must be aware of the sustainability
implications of what we are doing.
We  must  always  act  in  the  public  interest.  This  requires  us  to  understand the
communities  we  serve  and  appreciate  the  important  duty  we  have  to   rise  to
public  need  when  circumstances  demand.  Our  work  involves  delivering  the
Information
quality  services  that  the  Government  expects  of  us,  and  contributing  to  the
results  that  New  Zealanders are entitled to. We must consider the part we can
each  play  in  improving  the  effectiveness  of  our  organisation  and  take
responsibility  for  improving  our  own  performance.  Personal improvements in
efficiency  will  contribute  to  improvements  in  the  overall  efficiency  of  our
organisation.
Official
Improvements  flow  from  attention  to  what  we  do  and  how  we  do  it.  This
involves our decision-making and performance management systems. We must
the
be  able  to  measure  how  effective and efficient we are if we are to improve on
what  we  do.  Ways  of  doing  this  include  programme  evaluations  that focus on
results, client surveys, analysis of complaints, and use of research.
Trustworthy
under
We must be honest
We are expected to act honestly.
This  obligation  is  not  only  work-related.  It  arises  at  any  time  when  the
consequences of dishonest conduct may have an impact on public trust or on the
confidence that Ministers, Parliament, or others in the State Services, can have in
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our organisation.
The  principle  of  honesty  underpins  the  obligations  of  all  of  us  in  the  State
Services.  Public  trust  in  the  State  Services  will  be  determined primarily by the
degree  to  which  New  Zealanders  believe  that  at  all times we act with honesty.
We are expected to respond to what we believe to be true, and to act always with
a focus on accuracy and authenticity.
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Honesty  does  not  necessarily  mean  continuous,  full  disclosure.  In  some
circumstances, full disclosure is a requirement. Other circumstances may require
care.  For  example,  the  courts  have  recognised  that  organisations  with
responsibility to enforce legislation cannot be required to openly disclose their
evidence-gathering activities.  It is sometimes necessary to disguise the way these
activities  are  carried  out.  But  these  circumstances  are  rare.  Unless  there  is  a
lawful reason for doing so, we must not act on the premise that the end justifies
the means.
Honesty  is  frequently  associated  with  professional  courage.  We  must  not  act  Act
with  guile  for  administrative  convenience  or  to  conform  to  political
arrangements. We must not deceive or knowingly mislead. Being honest requires
us to set out facts and relevant issues truthfully and to correct any errors as soon
as possible. We must be careful about providing only some of the facts about an
issue if we anticipate that we may encourage misunderstanding. Providing only
half the facts may mean we are telling only half the truth.
Honesty means that we are truthful and open.
We must work to the best of our abilities
Information
Working  to  the  best  of  our  abilities  is  a  way  of  demonstrating  our  spirit  of
service.  We  have respect for the taxpayers who fund our employment, and we
are committed to working diligently in return.
We recognise that it is important for the people of New Zealand to be aware of
Official
the work we carry out on their behalf, and that they trust us to act always in the
public  interest.  We  appreciate  that  properly  documenting  our  decisions  and
actions  is  part  of  promoting  public  understanding and maintaining community
the
confidence.  It  is  important  that  we  keep  accurate  records  that  can  be  readily
accessed. This enables us to let the public know what we  do and how decisions
and  outcomes  have  been  reached.  Ombudsmen  have  commented  that  . .  "the
ability  to  communicate  and  explain  is  often  dependent  on  the  quality  and
accessibility of records of a citizen's interaction with public sector agencies".
under
We are expected not only to be apolitical, responsive, objective and accountable
in  carrying  out the work of our organisation, but to endeavour to improve the
quality  and  quantity  of the contribution we make. This may involve supporting
others  within  and  across  organisations  to  share  knowledge and expertise. We
should  use  personal  development  opportunities  to  increase  our  skills  and the
value we can add to our organisation. This has been described as working with
pride, passion, pace and professionalism.
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We  must  ensure  our  actions  are  not  affected  by  our  personal  interests  or
relationships
Ensuring  our  actions  are  not  affected  by  personal interests or relationships is
essential if we are to be worthy of public trust. It is equally important that we do
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not act in a way that improperly benefits our family or friends or groups in which
we have a personal interest.
We  must  avoid  circumstances  where  our  personal  interests  or  relationships
conflict  with  the  interests  of  our  organisation.  We  must  also  avoid  situations
where there could be an appearance of such conflict. Our actions need to be fair
and  unbiased  and  should  always  be  able  to  bear  close  public  scrutiny.  An
important  part  of  strengthening  trustworthiness  is  our  commitment  to
transparency. Openness allows organisations to ensure that conflicts are avoided
or  managed.  By  being  open  with  our  organisation  and  disclosing  non-work  Act
commitments, we enhance our trustworthiness.
It is important we do not give preferential treatment to people we are connected
with,  either  socially,  personally,  through  work  or  in  any  other  way.  Our
organisations must have processes that preclude our being involved in deciding
matters relating to friends or family, and we must not take part in employment
selection  processes,  or  have  supervisory  responsibilities,  that  involve  another
family member.
Any  commercial  activities,  investments  or  other  personal  interests  must  not
Information
influence the work we do, and we must be open in declaring where our interests
may potentially conflict with our responsibilities. Just as we must first obtain the
consent  of our organisation before undertaking additional employment so that
any conflicts can be avoided, we must also disclose any commercial business we
set up that will operate concurrently with our work in the State Services.
Official
We must never use for personal advantage any information that we may access
in the course of our work and that is not already generally available to the public.
the
We  must  always  be  conscious  of  the  potential  for  conflict  in  what  we  do.
Avoiding bias and avoiding any appearance of bias are equally important. If we
have  an  interest,  and  our  official  responsibilities  connect  to  that  interest,  our
impartiality is at risk. We must avoid creating any sense among reasonable, fair -
minded  and  informed  observers  that  we  favour  any  party  to  a  decision,  and
under
avoid anything that would make them feel there is a real danger of bias in what
we do.
We must never misuse our position for personal gain
We have a range of roles, responsibilities and powers that enable us to carry out
our  organisational  functions.  These  must  be  applied, and the resources of our
organisation used, only for the intended purpose and in the intended way. This is
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reflected in the duty of statutory Crown entities to ensure that everyone workin g
for  the  organisation  acts  in  a  manner  consistent  with  its  objectives,  functions,
current statement of intent and any output agreement.
Using our position properly incorporates all the integrity standards of the code
of conduct. It requires fairness and for us to act within the spirit and the letter of
law and policy. It means that we remain impartial in our work and must not be
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influenced  in  our  decision-making  by  personal  interests  or  advantage  to  any
person or organisation with which we are connected.
We  must  be  objective  in  the  way  we  manage  our  work,  ensuring  we  are  fair,
consistent and transparent in what we do. Acting inappropriately will inevitably
conflict  with  the  statutory  requirement  for  our organisations to function in an
efficient,  effective  and  economical  way,  as  managing complaints about the way
we do things will divert resources from productive activities. We must maintain
accurate  records  about  what  we  do,  and  respond  openly  to  requests  for
information,  so  that  the  public  can  be  confident  that  we  do  not  misuse  our  Act
position.
New Zealanders expect us to work impartially, not to be influenced by personal
motives,  not  to  show  favouritism  and  not  to  misuse  public  resources  for  our
personal  benefit.  This  means  we  must  always  be  careful  that  we  do  not  put
ourselves  in  a  position  where  our  work  responsibilities  could  be  affected  by
some  other  interest  that  we  have.  It  is  equally  important  that  we  avoid
circumstances where other people could reasonably consider that our personal
interests create a conflict with our work responsibilities. Information
There is always a possibility of conflicts between our professional and personal
lives.  We  need  to  be alert to this. If such circumstances arise, we must be very
open  and  ensure  that  we  have  properly  disclosed  the  potential  conflict,  have
distanced  ourselves  from  involvement  and  avoided  acquiring  information that
could be seen as giving us a personal advantage.
Official
We  must  decline  gifts  or  benefits  that  place  us  under  any  obligation  or
perceived influence
the
We must be very careful about accepting any form of benefit that is not provided
by our organisation and be aware always of the public perception that can result
from accepting favours.
Using an official position for personal gain is a form of dishonesty that is likely  to
under
impact  on  public  confidence  in  government  and,  particularly,  in  the  State
Services. Expectations in this area therefore are more demanding than is the case
in the private sector and for the public generally. We understand that anything
that  is  proffered  to  us  in  connection  with  our  work  can  only  be  accepted  if
specifically permitted by the policies of our organisation.
There  will  usually  be  perceptions  of  influence or personal benefit if we accept
gifts,  hospitality  or  'quid  pro  quo'  exchanges  of  favours.  We must not seek or
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accept  favours  from  anyone,  or  on  behalf  of  anyone,  who  could  benefit  from
influencing us or our organisation. Organisations' policies on accepting gifts and
hospitality vary, depending on their business. In all cases, it is expected that gifts
will  only  be  accepted  following  a  transparent  process  of  declaration  and
registration.  To  avoid  misperceptions,  it  is  essential  that  the  process  is  public.
This  requirement  applies  equally  when  gifts  and  opportunities  are  offered  to
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organisations  as  a  whole  -  for  example,  donations  to  social  clubs  and  staff
discount arrangements.
When we are presented with ceremonial gifts, these are expected to remain the
property of our organisation, reflecting the relationship that gave rise to the gift.
Offers of hospitality, as with gift offers, must always be assessed in terms of the
purpose  of  the  donor.  The  business  reason  for  this  type  of  spending on state
servants  will  usually  relate  to  managing the relationship with organisations by
facilitating  access  to  decision-makers,  or  acquiring  some  implied  endorsement  Act
through  association  with  organisations.  Receiving  hospitality  is  usually
inappropriate if it extends beyond courtesy.
There is potential for abuse in air points schemes and other product promotion
programmes.  We must ensure that work-related purchasing decisions are kept
separate from arrangements of this type, unless our organisation has published
policies that specifically address any apparent personal interest that may arise.
We  must  not  receive  personal  benefits  or  gratuities  from  third  parties  for
carrying  out  our  organisation's  functions,  participating  in  activities  as  an
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organisation representative or undertaking work-related speaking engagements.
Any payments should either be declined or paid to our organisation.
We  must  avoid  any  activities,  work  or  non-work,  that  may  harm  the
reputation of our organisation or of the State Services
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As a general principle, what we do in our personal lives is of no concern to our
organisation unless it interferes with our work performance or reflects badly on
the integrity or standing of the State Services.
the
Our employers have a legitimate interest in any of our activities if they are likely
to affect relationships with the Government, other Members of Parliament, o r the
public.
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We must avoid being connected publicly with behaviour that creates a sense of
public  disquiet,  and  that,  implicitly,  diminishes  trust  in  the  State  Services.
Involvement  in  some  personal  activities,  including  unlawful  behaviour  or
incidents  involving  a  breach  of  trust,  is  likely  to  bring  our  organisation  into
disrepute.
We  must  use  judgement  when  exercising  our  personal  democratic  rights  or
voicing professional concerns. We must be careful that we act lawfully, and that
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we do not misuse official or personal information we have acquired through our
work.  We  must  always  be  careful  that  our  actions  do  not  compromise  our
organisation or our Minister.

In making judgements about our non-work activities, we should consider:
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•  the nature and circumstances of the activity
•  our position, duties, and responsibilities
•  the consequences of the activity on our ability to fulfil our duties and
responsibilities
•  the  effects  of  the  activity  or  its  consequences  on  our  organisation's
relationships with Ministers and people using our services
•  any  legal  framework,  e.g.  the  Health  Sector  Code of Good Faith, and
other professional codes
•  the likely public perception of the appropriateness of what we do, and
the "angle" that commentators may adopt if there is media reporting  Act
of our activities
•  implications  of  the  behaviour  on  levels  of  public  trust  in  the  State
Services.
Membership of unions and professional associations, and active participation in
groups of this type, are not the sorts of actions that, in themselves, will harm the
reputation  of  our  organisation.  Where  activities  involve  direct  criticism  of,  or
opposition to, government policy, there is a need to ensure that we are part of
collective action and that we are not disregarding the criteria set out above. The
importance  of  keeping  politics  out  of  our  job  and  our  job  out  of  politics  is
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undiminished.
Before  starting  a  business  activity,  or  accepting  any  secondary  or  additional
employment,  whether  or  not  it  is  for  payment,  we  should  obtain  specific
approval from our organisation. We should ensure that there will be no conflict
with our official duties and no adverse effect on our efficiency or performance,
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and that the additional work can be performed wholly in our own time. Part-time
employment  is  a  tradition  in  areas  such  as  the  health  sector,  although  it  is
increasingly common for us to work part-time. We must have clear authorisation
the
from our organisation before we begin any secondary or additional work.
Additional employment may create a conflict if it involves:
•  work in a business that has or is developing a contractual relationship
under
with any government organisation
•  an organisation that receives public funding
•  a  business  that  lobbies  Ministers,  or  Members  of  Parliament,  or
government organisations
•  a business that is regulated by the organisation we work for
•  demands that may undermine our ability to fulfil our duties
•  a business that has an interest in the privileged, private or confidential
information that we can access.
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When  considering  whether  an  activity  may  be  harmful  and  therefore
unacceptable,  our immediate feelings can often be a useful guide.  What is your
conscience telling you? Another test of appropriateness may be the opinions of
colleagues following discussion of all the facts, in effect a collective conscience. A
reluctance  to  openly  discuss  an  activity  may  reflect  our innate awareness tha t
the activity is not acceptable.
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Standards of Integrity and Conduct: An Explanation
Updated 26 November  2007

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Act
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Official
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DOCDM-228772
Standards of Integrity and Conduct: An Explanation
Updated 26 November 2007

Document Outline