R Standards of Integrity and Conduct Procedure POL 337a 1.pdf

Procedures: Standards of Integrity and Conduct
(POL-337a)
Issue Date
24 April 2025
Approved by
GM People, Governance
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and Capability

Owner
Director People Team
Author
Principal Employment
Act
Relations Specialist

Contents
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Purpose ...................................................................................................................................................... 2
Scope …………………………………………………………………………………………………………………………………………………2
Contact for Help ......................................................................................................................................... 2
Information
Principles .................................................................................................................................................... 3
Processes for raising or addressing actual or potential breaches of conduct and integrity standards ..... 4
1: Informal and formal complaints process ............................................................................................... 4
2: Performance improvement process ...................................................................................................... 5
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Documents, Forms, Links and Other Information ................................................................................... 14
Appendix A ............................................................................................................................................... 15
Appendix B ................................................................................................................................................. 5
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1.  Purpose
These procedures explain the approach and steps Kāinga Ora will take to support consistent
adherence to the Standards set out in the Standards of Integrity and Conduct policy POL-337.
They provide the processes to fol ow when addressing actual or potential breaches of the
Standards of Integrity and Conduct policy and should be read in conjunction with that policy.
The intent of Kāinga Ora in providing these procedures is to:
•  Explain how we respond to concerns or allegations, including complaints, about
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performance, behaviour/values or conduct/integrity that may not meet the requirements
of the Standards of Integrity and Conduct policy.
•  Support a fair, consistent and transparent approach being taken when addressing actual
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or potential breaches of these requirements, across the organisation.
2.  Scope
These procedures apply to employees only.
Where there is any conflict between these procedures and the Investigations policy (which
applies only to investigations undertaken or managed by the Integrity Services Team) the
provisions of these Procedures will apply.
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Where concerns exist about standards set out in the Standards of Integrity and Conduct policy
not being met by people or entities who are not employees, the process to be fol owed wil  be
determined by the contract or agreement in place with them.
3.  Contact for Help
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Employees should approach their People Leader in the first instance if they have questions,
concerns or need advice about standards of integrity or conduct, or possible breaches.
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If there are circumstances where approaching their People Leader is not appropriate, employees
can contact their one-up People Leader.
Employees who are members of the PSA can also contact their PSA delegate for support and
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advice.
Anyone with concerns about serious wrongdoing in the workplace should refer to the Policy and
Procedure: Protected Disclosures (POL338).
People, including external parties, can also raise concerns about certain conduct and integrity
matters by:
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•  cal ing the Integrity Line 0800 8355 469, or
•  emailing [email address].
Further information is available here: What the Integrity Services Team do.
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People Leaders with questions or concerns about integrity and conduct matters should seek
advice from their People Partner. People Leaders must seek advice from their People Partner
where they are considering applying any of the processes contained in the appendices to this
process, to address concerns about performance, behaviour, conduct or integrity, or where they
receive a complaint.
4.  Principles
People Leaders will fol ow these principles to support consistent adherence to the standards set
out in the Standards of Integrity and Conduct policy:
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•  Team members will be made aware of the standards required of them. This will include,
for example, reading and completing e-learning modules to understand the standards
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during their induction, and regular 1:1 or Delivering and Developing conversations where
standards are discussed and reinforced.
•  Incidents where the standards are not met wil  be addressed swiftly and, where
appropriate, informally. Informal corrections are intended to support team members to
make the required improvements themselves, and could take the form of one or more of:
o  More frequent and/or structured 1:1s to provide monitoring, support and
coaching,
o  re-setting of expectations,
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o  identifying and discussing a minor breach that has occurred,
o  implementing a development plan or adjusting Delivering and Developing goals,
o  training or other forms of developmental support, where appropriate.
•  Where a more significant breach of a standards occurs, including where a pattern or
repetition of breaches is identified, or an informal corrective approach has not been
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successful in resolving an issue within a reasonable timeframe, a People Leader may
consider addressing the matter as one of potential misconduct, using the disciplinary
process set out below.  the
•  Disciplinary outcomes or actions from a disciplinary process can include a first warning,
final warning or dismissal. Informal corrective action such as a ‘Letter of Expectation’, or
no action at all, could also be outcomes from a disciplinary process if it is determined, as
a result of that process, that a formal action is not warranted.
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•  Whether addressing an issue through an informal corrective approach or a disciplinary
process, the intent is always to prevent the problem or breach continuing or recurring.

Al  interactions about standards of integrity and conduct, whether formal or informal, must be
conducted in good faith. Good faith obligations apply to People Leaders, team members and
anyone acting as a support person or representative, and require us to:
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•  act honestly, openly, and without hidden or ulterior motives
•  raise issues in a fair and timely way
•  not act in a misleading way
•  be constructive and cooperative
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•  be proactive in providing relevant information and considering all information
•  respond promptly and thoroughly to reasonable requests and concerns
•  keep an open mind, listen to each other, and be prepared to change opinion views about
a particular situation or behaviour
•  treat each other respectfully.
5.  Processes for raising or addressing actual or potential breaches of
Integrity and Conduct standards
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5.1.  Informal and formal complaints process
From time to time, Kāinga Ora receives complaints about our people from customers, tenants,
other Kāinga Ora employees or members of the public. When addressing complaints we need to
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balance the needs and rights of al  parties. We do this by adhering to the fol owing principles:
•  Kāinga Ora employees, customers, tenants and stakeholders have the right to raise
concerns and complaints in good faith and to expect them to be dealt with fairly,
efficiently and appropriately;
•  Complaints provide useful feedback, together with an opportunity for Kāinga Ora to
continue to build and develop confidence in our people, services and management;
•  Complaints will be resolved at the earliest and lowest level that is appropriate to the
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complaint and relevant context.
Kāinga Ora will work to protect the rights of all parties involved in complaints processes by:
•  Making every effort to resolve the matter wherever appropriate;
•  Making Kāinga Ora employees aware of their right to support and representation;
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•  Fol owing the principles of natural justice, which includes providing any Kāinga Ora
employee who has allegations raised against them that Kāinga Ora is addressing as a
complaint, with:
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o  a copy of the complaint against them and its supporting information,
o  a reasonable opportunity to respond to the complaint, and
o  for their response to be fairly considered
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o  Note: very limited exceptions to this could apply to certain Protected Disclosures – refer
to POL-338;
•  Wherever appropriate, offering a range of processes to support co-operative and early
resolution;
•  Keeping all information relating to the complaint confidential, sharing only on a “need to
know” basis;
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•  Taking prompt action to remedy any substantiated complaints;
•  Where appropriate, following the disciplinary process set out below;
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•  Failing to fol ow a reasonable instruction from a People Leader.
•  Breach of a Kāinga Ora policy, process or procedure, including conduct requirements for
public servants set by the Public Service Commissioner.
•  Acting outside delegated authority.
•  Poor performance or behaviours that do not align to our values (but first, refer to the
performance issues section above).
•  Failing to consistently meet the hours of work and location of work requirements in the
employment agreement/letter of offer (includes absenteeism and lateness).
•  Misuse, or unauthorised access or use of, Kāinga Ora property including confidential
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information.
•  Failing to meet the duties and responsibilities of the role as set out in the position
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description.
•  Any action or inaction that has the effect of unjustifiably disadvantaging (discriminating
against) a person due to their age, race or colour, ethnicity or national origins, gender,
sexual orientation, disability, religious or ethical belief, marital or family status,
employment status, political opinion, being affected by family violence, or involvement,
or association with, unions or union activities.
Serious misconduct issues or allegations that are so serious that they:
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•  fundamental y and irreparably damage the trust and confidence necessary to sustain an
employment relationship, and/or
•  indicate the employee no longer intends to be bound by their employment agreement.
Non-exhaustive, illustrative examples of serious misconduct issues or allegations that could lead
to summary (instant) dismissal include:  Official
•  Very serious incidents of misconduct, e.g. a very serious breach of Kāinga Ora policy,
procedures, or conduct requirements set by the Public Service Commission.
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•  Criminal harassment and/or conduct.
•  Dishonest conduct, including false or incomplete disclosure of relevant information
during the recruitment process.
•  Conduct that could reasonably bring Kāinga Ora or the government of the day into
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disrepute.
•  Incurring or approving financial expenditure for Kāinga Ora without proper justification
and authority to do so (includes P-cards, fuel cards, etc).
•  Abusive, threatening, violent or deliberate/targeted discriminatory actions or behaviour,
including racial or sexual harassment.
•  Actions or behaviour that amounts to a significant hazard (whether or not it causes actual
harm) in respect of the health and safety of self or others at work, including when
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undertaking activities associated with work, e.g. when travelling for work, representing
Kāinga Ora, or attending a work function.
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o  Where the same allegations have already been  investigated and/or  resolved in
another way.
o  Where it is not reasonably possible or practical to investigate the allegations.
o  Where the allegations are historic (depending on the nature of the al egations,
events that occurred more than three  months ago may not be appropriate to
investigate).
•  It may be necessary to clarify allegations, conduct initial fact finding and/or put
al egations to the employee for their initial response, prior to deciding whether
conducting a formal, stand-alone investigation is necessary, fair and reasonable in the  1982
circumstances.
•  Investigations into misconduct concerns or al egations can be conducted within a
disciplinary process. In many cases, following the Disciplinary Process Steps above is all
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that is required. It will usually be only where serious and/or complex allegations are
denied by the employee, that a stand-alone (‘formal’) investigation process is required.
•  Decisions to investigate al egations must be made in accordance with the People
Management Delegations.
•  When conducting a formal, stand-alone investigation process, the nature of the
al egations and scope of the investigation must be made clear to the employee, any
complainant and the investigator. This wil  usual y be documented in a Terms of
Reference that is set by Kāinga Ora.
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•  All investigations will adhere to the principles of good faith and natural justice. This
includes providing al  information that supports the al egations against an employee to
that employee for comment / response prior to findings being decided upon.
•  Where a formal, stand-alone investigation process is conducted, the investigator’s role
will be limited to making findings of fact and degree on the al egations they are
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investigating; they will not make any recommendations or decisions about possible
disciplinary action. The investigator will be independent of the allegations they are tasked
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with investigating, and may be internal or external to Kāinga Ora.
•  All parties to an investigation may use a support person or representative who is
independent of the al egations being investigated, to help them participate in the
investigation process.
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5.6.  Suspension
Kāinga Ora has the option of suspending an employee pending the outcome of a disciplinary
process when the al egation made could amount to serious misconduct and Kāinga Ora cannot
reasonably accommodate the employee remaining in the workplace. The People Management
Delegations policy specifies the level of People Leader authorised to make proposals and
decisions about suspensions.
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Prior to any decision being made to suspend an employee, the employee must be advised that
suspension is being proposed and the reasons why Kāinga Ora believes a suspension may be
necessary. The employee wil  then have the opportunity to comment, before Kāinga Ora makes a
decision on whether or not to suspend.
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Suspension will usually be on normal pay, and arrangements will be confirmed in writing after it
takes effect. Where factors beyond the control of Kāinga Ora result in a suspension becoming
unreasonably lengthy (e.g. criminal proceedings) Kāinga Ora may consider the suspension
continuing without pay.
Disciplinary outcomes/actions explained
Possible outcome/action
Appropriate circumstances
Ramifications
No action (includes informal
Where it is decided that the
No disciplinary action has
corrective action e.g.
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providing a letter confirming  proven or is not sufficiently
form of informal corrective
future expectations).
serious to warrant a formal
action may be put in place to

action.
support the employee to
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meet the expected standards
consistently going forward.
First warning
This will normally be applied
A first warning will usually be
the first time an employee
considered ‘live’ for up to 12
has acted or behaved in a way  months from date of issue,
that amounts to misconduct
but this will be confirmed in
that is too serious to be
the outcome letter. Any
addressed informally. It can
further incidents of
also be used if informal
misconduct may lead to a
corrective action has been
final warning.
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unsuccessful in addressing a
less serious conduct or
performance problem.
Final warning
This will normally be
A final warning will usually be
considered when a further
considered ‘live’ for up to 12
incident of misconduct o
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while a first warning is
but this will be confirmed in
already ‘live’ for the
the outcome letter. Any
employ
the ee. It may also be  further incidents of
considered in response to a
misconduct may lead to
single issue, in cases of more  dismissal with notice.
serious misconduct.
Dismissal with notice
This will normally be
The employee’s employment
considered when a further
will be terminated at the end
under  incident of misconduct occurs  of the notice period
while a final warning is
contained in their
already ‘live’ for the
employment agreement
employee.
(usual y one month).
Summary dismissal (without
This may only be used for
The employee’s employment
notice)
proven issues or allegations
wil  be terminated with
of serious misconduct, where  immediate effect.
the employee’s actions mean
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Kāinga Ora has reasonable
grounds to consider they no
longer have the necessary
trust and confidence in the
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employee for their
employment to continue,
having first considered any
relevant mitigating
circumstances.

6.  Documents, Forms, Links and Other Information
Related Kāinga Ora policies:
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•  POL-337 Standards of Integrity and Conduct Policy
•  POL-341 Acceptable Use of ICT Policy
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•  POL-111 Conflicts of Interest Policy
•  POL-338 Protect Disclosures Policy
•  H-227   People Management Delegations Policy
•  POL-336 Health, Safety and Security Policy
•  SK-POL-002 Privacy Policy
•  POL-314 Investigations Policy
Other related Kāinga Ora documents:
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•  Collective employment agreement
•  Individual employment agreements
•  Employee position description
•  CT-GDL-004 Guidelines for tenancy management
•  CT757 Receive and action complaints and feedback.
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Relevant legislation, regulations and standards:
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•  Kāinga Ora Values
•  Crown Entities Act 2004
•  Clean Slate Act 2004
•  Employment Relations Act 2000
•  Equal Pay Act 1972
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•  Harassment Act 1997
•  Health Safety at Work Act 2015
•  Human Rights Act 1993
•  Kāinga Ora – Homes and Communities Act 2019
•  Privacy Act 2020
•  Protected Disclosures (Protection of Whistleblowers) Act 2022
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•  Public Service Act 2020
•  Public Service Commission Standards of Integrity and Conduct

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7.  Document control
Date
Reviewed/Modified by
Comments/Descriptions of changes
November 2024  Employment Relations Team
Update
October 2019
People Partnership Team
Update for Kāinga Ora

Details of previous versions of policies and guidelines will be stored in the Kāinga Ora document
management system (Objective).
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Performance Improvement Plan
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Section 2 – Progress meetings
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This section is a working document and should be updated regularly, ideal y weekly (depending on the overal  length of the plan), to discuss progress against the
plan, chal enges, provide feedback and identify how you are tracking. Any additional/alternative support that may be needed may also be identified during these
meetings.

Week 1
Date of meeting: _______________________
Performance Issue
Progress/improvements (against standard/measure)
Comments
1


2


3

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Week 2
Date of meeting: _______________________
Performance Issue
Progress/improvements (against standard/measure)
Comments
1


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2


3


4


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Week 3
Date of meeting: _______________________
Performance Issue
Progress/improvements (against standard/measure)
Comments
1


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2


3


4



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Week 4
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Date of meeting: _______________________
Performance Issue
Progress/improvements (against standard/measure)
Comments
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2


3


4



Final Review meeting – Overal  performance
Date of meeting: _______________________
Performance Issue
Progress/improvements (against standard/measure)
Comments
Information
1


2


3


4



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Appendix B
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Disciplinary process: People Leader’s checklist
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Before initiating a disciplinary process:
1.  Is there reasonable evidence to support an allegation that conduct issue/s exist?
Yes / No
2.  Have you consulted with your People Partner on conducting a disciplinary process? Do you need to seek an initial response from the employee
before deciding whether proceeding to a disciplinary process is reasonable and necessary?
Yes / No
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3.  Have you consulted with your People Partner on preparing letters and supporting documents to give to the employee(s) subject to the allegation/s?
Yes / No
When preparing an invitation to disciplinary meeting letter:
4.  Have you arranged time for meeting with the employee(s) and their representative in conjunction with your People Partner?
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Yes / No
5.  Have you provided all relevant evidence of the misconduct allegation/s to the employee before the meeting? Have you prepared for the meeting
with your People Partner by deciding on the questions you need to ask the employee and the other points you need to cover with them during the
the
meeting?
Yes / No
During the disciplinary meeting:
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6.  Have you gathered enough information about the employee’s response or explanation to properly understand and consider it? Do they have any
mitigating factors they want you to consider? Are there any points that require further investigation or clarification? Is there a need to adjourn the
meeting to seek further information or check any points raised by the employee? Adjournments can be short (10 minutes) or longer (rescheduled
for next day or week) depending on the responses given. If any new information is gathered during an adjournment it should be presented to the
employee, and they should be given a reasonable opportunity to comment on it.
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Yes / No
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7. Having considered the employee’s explanation/response, what is your preliminary view on a) whether misconduct occurred, and b) on that basis,
what an appropriate response (action/outcome) could be?
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Yes / No
8. What is the employee’s response to your preliminary decision on a) what occurred and b) a possible appropriate action/outcome? Do you ful y
understand their position in respect of each?
Yes / No
After an adjournment, during a subsequent meeting or if necessary/if agreed, in writing:

Have you verbally (usually) and in writing (always) clearly communicated your decision and the reasons for your final decision? Did you properly take
into account the employee’s response and is this clear in your decision letter?
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Yes / No
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