Dear New Zealand Police,
To: New Zealand Police
From: Nigel Gray
Date: 1 April 2026

Subject: Official Information Act request – Police ethics frameworks, training models, and evaluation of ethical conduct

Under the Official Information Act 1982, I request the following information.

SECTION 1 – ETHICS FRAMEWORKS AND DOCTRINE

Please provide copies of all current documents that set out New Zealand Police’s official ethical framework, including but not limited to:
– codes of conduct
– ethics policies
– integrity frameworks
– values statements
– any internal doctrine describing the ethical duties of police officers.

Please provide copies of any documents that explain the theoretical or conceptual basis for New Zealand Police’s ethical framework, including:
– references to ethical theories, models, or schools of thought
– references to psychological models used to support ethical behaviour
– any internal or external reports that describe “why” officers are expected to act ethically, beyond simple rule compliance.

Please provide copies of any internal reviews, reports, or briefings in the last 15 years that:
– evaluate whether the current ethical framework is effective, or
– identify weaknesses, gaps, or failures in the ethical framework, or
– recommend changes to the ethical framework.

SECTION 2 – ETHICS AND INTEGRITY TRAINING CONTENT

Please provide copies of all current training materials (or detailed syllabi where full materials cannot be released) used for:
– recruit training on ethics, integrity, and professional standards
– in‑service or ongoing ethics/integrity training for serving officers
– leadership training on ethics for sergeants, senior sergeants, inspectors, and above.

For each training module identified in question 4, please provide:
– the learning objectives
– the total hours allocated
– the delivery method (e.g. classroom, online, scenario‑based, assessment‑based)
– the date the module was first introduced and the date of any significant revisions.

Please provide copies of any documents that explain:
– how psychology is used in ethics or integrity training
– what psychological models or theories are relied on
– how these models are expected to support ethical behaviour and reduce misconduct.

SECTION 3 – EVALUATION OF ETHICS TRAINING EFFECTIVENESS

Please provide copies of any evaluations, reviews, or assessments (internal or external) carried out in the last 15 years that:
– measure the effectiveness of ethics or integrity training
– assess whether training has reduced misconduct, complaints, or criminal offending by officers
– recommend changes to ethics or integrity training.

Please provide any documents that set out:
– how New Zealand Police defines “success” for ethics or integrity training
– what indicators or metrics are used to determine whether ethics training is working
– how often these indicators are reviewed.

Please provide any documents that discuss:
– the relationship between ethics training and actual instances of misconduct or criminal offending by officers
– whether ethics training has been modified in response to specific cases or patterns of misconduct.

SECTION 4 – INTERNAL RECOGNITION OF ETHICAL FAILURE

Please provide copies of any internal reports, briefings, or reviews in the last 20 years that:
– explicitly acknowledge that existing ethics or integrity training has failed or been inadequate, or
– identify that officers have engaged in serious misconduct or criminal offending despite having completed ethics training, or
– recommend a fundamental review or redesign of ethics training or ethical frameworks.

Please provide copies of any documents where New Zealand Police has:
– considered alternative ethical models or training approaches (for example, moral development models, virtue ethics, restorative or harm‑based ethics), and
– recorded reasons for adopting or rejecting such models.

SECTION 5 – GOVERNANCE, RESPONSIBILITY, AND EXTERNAL INPUT

Please identify the current role titles and units responsible for:
– designing ethics and integrity training
– maintaining the ethical framework and codes of conduct
– monitoring and reviewing the effectiveness of ethics training.

Please provide copies of any terms of reference, minutes, or reports from any committees, working groups, or governance bodies that:
– oversee ethics and integrity policy
– review serious misconduct or criminal offending by officers from an ethical or systemic perspective
– recommend changes to ethics frameworks or training.

Please provide details of any external experts, academics, or organisations that have:
– been consulted on police ethics or integrity training in the last 20 years
– provided written advice, reports, or reviews on police ethics or integrity
– delivered ethics‑related training to New Zealand Police.

SECTION 6 – LINK BETWEEN ETHICS TRAINING AND OFFICER OFFENDING

Please provide any documents, reports, or analyses that:
– examine why police officers commit criminal offences despite having received ethics or integrity training
– identify underlying causes or contributing factors for criminal offending by officers
– propose changes to training, recruitment, or organisational culture to address these causes.

If no such analyses exist, please confirm whether New Zealand Police has ever:
– formally examined the question of why its own staff commit criminal offences, from an ethical or training perspective, and
– considered commissioning such an examination.

FORMAT AND TIMEFRAME

I am happy to receive the requested information in electronic form.
If any part of this request is refused, please provide the grounds for refusal and the specific sections of the Official Information Act relied upon.

If the scope of this request is considered too broad, please contact me so that I can refine it. However, I note that the core focus of this request is on:

– the ethical frameworks New Zealand Police relies on
– the training models used to instil ethics and integrity
– the evaluation of whether those models work in practice.

Yours faithfully,

Nigel Gray

Clarification to OIA IR‑01‑26‑11749
Dear Ministerial Services,
Thank you for your response of 25 May 2026.
I would like to submit the following clarification under section 18A of the Official Information Act, as it relates directly to the subject matter of my original request concerning Police’s ethical framework, ethical expectations, and ethics‑related training.
Please provide New Zealand Police’s formal definition of the term “ethics” as used in:
– the Code of Conduct – Police Values – ethics or integrity training materials – organisational policies, guidance, or doctrine
If no formal or documented definition exists, please confirm that New Zealand Police uses the term “ethics” without a formally adopted or documented definition.
This clarification is necessary to understand the basis on which Police describes its “ethical framework”, “ethical expectations”, and “ethics and integrity training” in the response provided.

Yours sincerely,

Nigel Gray

Dear Ministerial Services,
On 25 May I submitted a clarification under section 18A of the Official Information Act.
The clarification was simple:

What is New Zealand Police’s formal definition of “ethics”?
As used in the Code of Conduct, Police Values, ethics training, and organisational doctrine.

This clarification was necessary because Police’s earlier response relied heavily on the term “ethical framework” while providing no definition of the underlying concept.

What Police did next is procedurally irregular.
Instead of treating the clarification as part of the original request (IR‑01‑26‑11749), Police:

opened a brand‑new OIA

assigned a new reference number (IR‑01‑26‑18730)

restarted the 20‑working‑day clock

treated the clarification as a fresh request

This is not a minor administrative choice.
It is a material deviation from the OIA’s statutory scheme.

1. Clarifications under s18A must be processed within the original request
The Ombudsman’s guidance is explicit:

A clarification is not a new request

Agencies must not restart the statutory timeframe

The purpose of s18A is to assist the requester, not to delay the agency’s obligations

Police’s decision to open a new OIA is therefore:

procedurally incorrect

inconsistent with Ombudsman guidance

indicative of an unreasonable delay

2. The subject matter is identical — Police cannot reclassify it as “new”
The clarification did not expand the scope.
It did not introduce new subject matter.
It did not request additional categories of information.

It asked Police to define the very term they used in their own response.

If Police cannot answer the clarification within the original request, that raises a further question:

On what basis did Police claim to have an “ethical framework” if they cannot define the term “ethics”?

3. Opening a second OIA creates a procedural contradiction
Police now have:

two active OIAs on the same topic,

both concerning Police ethics,

both arising from the same chain of correspondence,

one of which exists solely because Police reclassified a clarification as a new request.

This duplication is not neutral.
It creates:

an artificial delay

a break in the audit trail

a fragmentation of the record

a potential breach of the duty to provide reasonable assistance

It also raises the question of whether Police are attempting to:

avoid acknowledging deficiencies in the original response

avoid admitting that no definition of “ethics” exists

avoid committing to a position that could be scrutinised

4. The legal significance of the definition question
If Police have:

no formal definition of “ethics”,

no documented doctrine,

no consistent organisational meaning,

then the following follow logically:

Police cannot meaningfully claim to have an “ethical framework”

Police cannot train staff in “ethics” in any coherent sense

Police cannot evaluate “ethical conduct” against an undefined standard

Police cannot enforce “ethical expectations” without risking arbitrariness

This is not a semantic issue.
It is a rule‑of‑law issue.

A public power cannot be exercised on the basis of undefined concepts.

5. The procedural irregularity strengthens the public interest
The public has a legitimate interest in knowing:

whether Police can define the ethical standards they claim to uphold

whether Police are applying undefined concepts to staff or the public

whether Police are using procedural manoeuvres to avoid scrutiny

whether Police are complying with the OIA in good faith

The decision to open a second OIA — instead of answering a clarification — heightens that interest.

Conclusion
Police’s handling of this clarification is not consistent with the OIA’s purpose, structure, or Ombudsman guidance.
It raises substantive questions about:

procedural compliance

organisational transparency

the existence (or non‑existence) of a definitional foundation for Police ethics

The public is entitled to clear, documented, and accountable standards — not undefined terminology and procedural detours.

Yours sincerely,

Nigel Gray