OIA Response IR 01 26 11749.pdf

IR-01-26-11749
25 May 2026
Nigel Gray
[FYI request #34336 email]
Tēnā koe Nigel
Request for information
Thank you for your Official Information Act 1982 (OIA) request of 1 April 2026, in which
you asked for information regarding Police ethics frameworks, training models, and
evaluation of ethical conduct.
My response to each part of your request can be found below.
1. ETHICS FRAMEWORKS AND DOCTRINE Please provide copies of al 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.
New Zealand Police operates a values- and conduct based-ethical framework that sets
clear expectations for behavioural and professional standards. Police’s ethical framework
was a topic that was widely traversed fol owing the 2007 report of the Commission of
Inquiry into Police Conduct. The report made 47 recommendations to Police, 17 of them
specifical y related to ethics. Both internal and external reviews of Police’s progress
against those recommendations, including by the Office of the Auditor-General, can be
found on Police’s external website at https://www.police.govt.nz/about-us/nz-
police/commission-inquiry.
This framework is supported by various Police Manual chapters, several of which are
publicly available, including:
•
Management of notifiable incidents, complaints and internal investigations
(https://www.police.govt.nz/about-us/publication/management-notifiable-
incidents-complaints-and-internal-investigations-police)
•
Fraud and corruption (https://www.police.govt.nz/about-us/publication/fraud-
and-corruption-police-manual-chapter)
•
Protected disclosures (https://www.police.govt.nz/about-
us/publication/protected-disclosures-police-manual-chapter)

•
Police use of facial recognition technology (https://www.police.govt.nz/about-
us/publication/police-use-facial-recognition-technology-frt-police-manual-
chapter)
•
Gifts, discounts and hospitality (https://www.police.govt.nz/about-
us/publication/gifts-discounts-and-hospitality-police-manual-chapter)
•
Information security: Acceptable use of information and ICT
(https://www.police.govt.nz/about-us/publication/information-security-
acceptable-use-information-and-ict-police-manual-chapter)
•
Information security: Overview (https://www.police.govt.nz/about-
us/publication/information-security-overview-police-manual-chapter)
•
Managing conflicts of interest (https://www.police.govt.nz/about-
us/publication/managing-conflicts-interest-police-manual-chapter)
Police’s Code of conduct and Values also form part of the broader framework. They are
also publicly available on the New Zealand Police website at:
•
https://www.police.govt.nz/about-us/publication/new-zealand-police-code-
conduct
•
https://www.police.govt.nz/about-us/our-values
To the extent that your request seeks copies of these documents, Police refuses this part
of the request under section 18(d) of the OIA, as the information is publicly available.
Police hold internal policy and guidance documents that describe expected standards of
behaviour, ethical decision-making, and processes for responding where behaviour falls
short of those expectations.
In response to your request, Police is releasing the following non-publicly available
documents, which are attached to this response:
Doc
no.
Document
Release
decision
1
Employment Resolutions and Disciplinary Policy and
Guidelines
Released in full
2
Unacceptable Behaviour – Kia Tū Policy and Guidelines
Released in full
3
SELF-CHECK Ethical Decision-Making Poster
Released in full
These documents collectively describe Police’s expectations of ethical conduct,
decision-making, accountability mechanisms, and responses to unacceptable behaviour.
Police has not identified centrally held or formal documents that explicitly set out its
ethical framework by reference to specific philosophical or psychological theories (for
example, virtue ethics, moral development theory, or behavioural ethics models), nor
documents that articulate a formal theoretical basis for ethical behaviour beyond values,
conduct standards, and accountability frameworks. Ethical expectations are articulated
primarily through values, leadership expectations, professional standards, and
disciplinary systems rather than formal theory-based doctrine. Accordingly, this part of
your request is refused under section 18(e) of the OIA, as the information is not held.
Police examines misconduct and offending through disciplinary, criminal, and
organisational reviews. Police has not identified any internal reviews, reports, or briefings
produced in the last 15 years that evaluate the effectiveness of the ethical framework as a

discrete framework, or that explicitly identify weaknesses, failures, or recommended
changes framed in those terms. Where broader reviews relating to organisational culture,
integrity, or professional conduct exist, these are publicly available and include, for
example, the Commission of Inquiry into Police Conduct, Fifteen Years of Change 2007–
2022 published by New Zealand Police, and Part 5 of the Office of the Auditor General’s
report on performance management, values, behaviour, and discipline.
To the extent that your request seeks access to such publicly available material, it is
refused under section 18(d) of the OIA, as the information is publicly available. To the
extent that the request seeks information beyond this, it is refused under section 18(e) of
the OIA, as the requested information is not held.
2. ETHICS AND INTEGRITY TRAINING CONTENT  Please provide copies of al
current training materials (or detailed syl abi where ful  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.
Recruit training
New Zealand Police provides ethics, integrity and professional standards training to
recruits throughout the initial training programme at the Royal New Zealand Police
College. This training is delivered through a combination of classroom instruction,
facilitated discussion, scenario-based learning, online modules, and external oversight
presentations.
Ethics, integrity and professional standards content is introduced early in recruit training
and reinforced at multiple points throughout the programme.
Week 1 – Our Business / Our Values
Recruits receive a formal classroom-based session (approximately 60 minutes)
introducing:
•
Police Values and the Code of Conduct;
•
ethical behaviour and alignment of personal conduct with organisational values;
•
the prevention first mindset; and
•
the role of legislation (including the Policing Act 2008 and the New Zealand Bil  of
Rights Act 1990) in guiding police conduct.
This session is supported by a lesson plan and presentation materials developed in 2024
and includes facilitated discussion and ethical decision-making scenarios using the SELF
Check framework.
Recruits also complete an Our Business / Our Values workbook during their first week of
training. This workbook, introduced in 2024, contains scenario-based questions and
reflective exercises focused on ethics, values, and professional behaviour. A copy of the
completed workbook is provided to the recruit’s section sergeant.
A presentation by the Director of Training is also delivered during this period. No written
materials are produced for this presentation.

Online ethics and integrity learning
Recruits complete online learning modules in their own time, including:
•
Our Code 1 and Our Code 2, which are Code of Conduct training videos using
decision making scenarios (episodes released in 2015 and 2017); and
•
Conflict of Interest training, delivered through a series of short videos updated
between 2017 and 2020.
These modules reinforce expectations around ethical behaviour, professional boundaries,
conflicts of interest, and accountability.
Further integrity-focused sessions
Ethics and integrity themes are reinforced later in the recruit programme through
externally delivered classroom sessions, including:
•
Police History: Institutional Bias (Week 2);
•
National Integrity Unit presentation (Week 11); and
•
presentations on early intervention, Kia Tū, and the Independent Police Conduct
Authority (Weeks 19–20).
These sessions focus on integrity risks, accountability, oversight, and public trust. No
standalone training documents are produced for these presentations.
Police have provided a high-level overview of ethics, integrity, and professional standards
training; however, the underlying lesson plans, presentations, workbooks, and scenario
materials are operational training resources.
The release of these materials is refused under section 9(2)(g)(i) of the OIA, as release
would be likely to prejudice the effective conduct of public affairs by undermining the
integrity and effectiveness of Police training, assessment, and integrity management
processes, including by enabling individuals to anticipate, rehearse, or circumvent training
scenarios and assessment approaches. In some cases, section 9(2)(k) may also apply,
as release could enable the misuse of training and assessment materials by allowing
individuals to anticipate, rehearse, or otherwise circumvent integrity-related training and
evaluation processes, reducing their effectiveness as tools for assessing genuine
behaviour.
Leadership development training (Sergeant to Inspector)
Ethics, integrity and professional standards are embedded throughout leadership
development training for commissioned and non-commissioned leaders from Sergeant to
Inspector level. This training is delivered through the New Zealand Police Leadership
Development Framework (LDF) and is designed to support leaders to model ethical
behaviour, manage integrity risks, and uphold professional standards within their teams.
Rather than being delivered as standalone ethics courses, ethics and integrity content is
integrated across leadership programmes and reinforced through values-based
leadership, ethical decision making, and accountability discussions appropriate to each
leadership level.
Sergeant and Senior Sergeant level
At Sergeant and Senior Sergeant level, ethics and integrity training focuses on
operational leadership and people management responsibilities.
Key themes include:
•
leading by Police Values and the Code of Conduct;
•
ethical decision making in complex and pressured operational environments;

•
recognising and responding to misconduct, conflicts of interest, and integrity
concerns;
•
managing performance, conduct, and early intervention;
•
supporting staff wellbeing while maintaining professional standards.
Training is delivered through a combination of self-paced pre-course learning, facilitated
face to face workshops, scenario-based discussion, reflective exercises, and workplace
based applied learning. Practical scenarios are used to support leaders to identify ethical
risks and apply judgement consistent with Police expectations.
Inspector level
At Inspector level, ethics and integrity training expands to cover organisational leadership,
systemic risk, and accountability. Key themes include:
•
values based strategic leadership and ethical culture;
•
oversight of conduct and integrity within commands and districts;
•
governance, assurance, and accountability obligations;
•
managing high risk integrity issues and critical incidents;
•
reinforcing public trust, transparency, and confidence in policing.
Inspector level training emphasises leadership responsibility for setting ethical tone,
managing organisational risk, and ensuring compliance with professional standards
across broader operational settings.
Training materials
Police holds programme outlines and training materials supporting leadership
development training. However, these materials form part of operational leadership and
integrity training resources.
The release of detailed leadership training materials is refused under section 9(2)(g)(i) of
the OIA, as release would be likely to prejudice the effective conduct of public affairs by
undermining the integrity and effectiveness of Police leadership development, integrity
management, and conduct processes, including by enabling individuals to anticipate,
rehearse, or circumvent training scenarios and assessment approaches. Release of
detailed training materials would also reduce the realism and behavioural testing value of
scenario-based training, which relies on participants responding to unfamiliar situations in
real time. In some circumstances, section 9(2)(k) may also apply as release could enable
the misuse of training and assessment materials by allowing individuals to anticipate,
rehearse, or otherwise circumvent integrity-related training and evaluation processes,
reducing their effectiveness as tools for assessing genuine behaviour.
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.
New Zealand Police undertakes a range of organisational evaluations, surveys, reviews,
and monitoring activities relating to conduct, culture, complaints, integrity, and

professional standards. Police publishes a range of evaluation and review material on its
website at:
https://www.police.govt.nz/about-us/publications/corporate/evaluations-reviews
Police also publishes Professional Conduct statistics, which provide transparency about
reported incidents and misconduct outcomes:
https://www.police.govt.nz/about-us/about-new-zealand-police/police-professional-
conduct/professional-conduct-statistics
To the extent that your request seeks copies of publicly available evaluations, reviews, or
statistical information that touch on ethics, integrity, professional conduct, leadership, or
organisational culture, this part of your request is refused under section 18(d) of the OIA,
as the information is publicly available.
Police has not identified any discrete evaluation reports or assessments that isolate
ethics or integrity training as a single variable and measure its causal impact on
misconduct, complaints, or criminal offending by officers, nor documents that establish
direct causal links between ethics training and changes in offending or misconduct
outcomes. Accordingly, this part of your request is refused under section 18(e) of the OIA,
as the information is not held.
Police has not identified any documents that define “success” specifically for ethics or
integrity training, establish discrete success indicators or metrics solely for ethics training,
or record formal review cycles specific to ethics training effectiveness. While broader
integrity and conduct metrics are monitored at an organisational level, they are not
framed or recorded as ethics training specific measures. This part of your request is
therefore refused under section 18(e) of the OIA, as the information is not held.
Police has also not identified documents that formally analyse the relationship between
ethics training and individual instances or patterns of misconduct or criminal offending, or
that record changes to ethics training made in response to particular misconduct cases.
This part of your request is refused under section 18(e), as the information is not held.
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
Public reviews, including the Commission of Inquiry into Police Conduct and subsequent
independent oversight and monitoring, have explicitly identified ethical, cultural, and
systemic failures within New Zealand Police and informed significant reform programmes.
Police has published progress reports and related material responding to those findings,
which are publicly available and remain the primary record of recognised ethical and
organisational failure at a system level.
To the extent that your request seeks copies of those publicly available reports and
associated material, this part of your request is refused under section 18(d) of the OIA, as
the information is publicly available.

Police has not identified internal reports, briefings, or reviews from the last 20 years that
explicitly frame ethics or integrity training as a discrete causal factor or having “failed” or
been “inadequate”, nor documents that formally recommend a fundamental redesign of
ethics training or ethical frameworks using those terms. While misconduct by officers who
have completed ethics training has occurred and has been addressed through
disciplinary, criminal, and oversight processes, Police has not identified centrally held or
formal documents that explicitly analyse or acknowledge this as failure of ethics training
itself. Accordingly, this part of your request is refused under section 18(e) of the OIA, as
the information is not held.
Police has also not identified documents that record the formal consideration, adoption, or
rejection of alternative ethical models or training approaches (such as virtue ethics, moral
development models, or restorative or harm based ethics) in the form described in your
request. While ethical concepts may be discussed at a general or informal level in training
and reform contexts, Police has not identified central y held or formal documents setting
out a documented evaluation of alternative ethical frameworks or recorded decisions to
adopt or reject such models. This part of your request is therefore refused under
section 18(e) of the OIA, as the information is not held.
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.
Responsibility for ethics, integrity, and professional conduct within New Zealand Police is
shared across several functions:
•
The ethical framework, Code of Conduct, and ethics and integrity training is
designed and maintained through Organisational Development and the Manager
of Organisational Development in conjunction with Manager of Learning Solutions
at RNZPC.
•
Monitoring and review of conduct and integrity occurs through Professional
Conduct, Assurance, Organisational Development functions, and external
oversight bodies.
You have requested terms of reference, minutes, and reports from any committees or
working groups that oversee ethics and integrity policy or review serious misconduct or
criminal offending from an ethical or systemic perspective.
Police has utilised a range of governance, working, and advisory groups over time, not al
of which have had a primary or exclusive ethics or integrity focus. Identifying all such
bodies and reviewing their records over an extended period would require identifying
historical governance arrangements across multiple business areas and reviewing a large
volume of material, which may involve substantial collation and research.
Before making a decision on this part of your request, Police invites you to clarify or refine
the scope in accordance with section 18A of the OIA.
For example, you may wish to clarify whether you are seeking information relating to:

•
current governance structures only; or
•
a specific, named committee, working group, or role; or
•
high level descriptions of governance arrangements rather than copies of minutes
and detailed papers.
Please advise how you would like to refine this aspect of your request.
Where relevant material is publicly available (for example, through published reviews or
independent oversight reports), this information will be refused under section 18(d) of the
OIA. Where documents are not held or were not formally documented, this information will
be refused under section 18(e) of the OIA, as the information is not held.
Part of your request seeks details of any external experts, academics, or organisations
consulted on police ethics or integrity training over the past 20 years, including those who
have provided advice, reports, or delivered ethics related training.
Police does not hold a single central register of all external engagements over this period.
Relevant information, if held, would be dispersed across multiple business units and
historical records, and responding in full would likely require substantial col ation and
research. However, the landing page for Police’s response to the Commission into Police
Conduct, which is referenced above - https://www.police.govt.nz/about-us/nz-
police/commission-inquiry, provides links to external reviews. Professor Mike Rowe, one
of the reviewers commissioned by Police, published an earlier paper, which is available at
https://researchportal.northumbria.ac.uk/en/publications/notes-on-a-scandal-the-official-
enquiry-into-deviance-and-corrupt/
Police does hold a copy of the fol owing academic paper, which is relevant to issues of
police culture, ethics, and professional norms:
•
Rowe, M. & Macaulay, A. – study on storytel ing and police culture
This paper is attached to this response.
Before determining whether this part of your request should be refused under
section 18(f) of the Act, Police invites you to consider refining the scope of this aspect of
your request, in accordance with section 18A. For example, you may wish to:
•
limit the timeframe to a more recent period; or
•
focus on formal written reports or reviews commissioned by Police; or
•
restrict the request to national level ethics or integrity programmes.
Please let us know if you would like to refine this aspect of your request.
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:–
formal y examined the question of why its own staff commit criminal offences, from
an ethical or training perspective, and – considered commissioning such an
examination.
Police has not identified centrally held or formal documents, reports, or analyses that
specifical y examine why police officers commit criminal offences despite having received
ethics or integrity training, framed from an ethics or integrity training perspective. Police

has also not identified analyses that isolate ethics training as a causal factor in criminal
offending by officers, identify underlying causes in those terms, or propose changes to
training, recruitment, or organisational culture based on such an analysis.
Where misconduct or criminal offending by officers occurs, Police responses focus on
prevention, accountability, and organisational learning through disciplinary and criminal
processes, leadership oversight, integrity systems, and broader organisational reform,
rather than through formal analyses attributing offending to the effectiveness or failure of
ethics training alone.
Police has not formally undertaken, nor identified records of having considered
commissioning, a discrete examination of why its own staff commit criminal offences
framed specifically from an ethics or integrity training perspective. Accordingly, this part of
your request is refused under section 18(e) of the OIA, as the information is not held.
Please advise whether you wish to refine any of the above aspects of your request that
are subject to consultation. If we do not hear from you, we wil  proceed to make final
decisions on the remaining parts of your request based on its current wording. This will
include confirming existing refusals and determining whether any further grounds for
refusal apply under the OIA.
Police considers the interests requiring protection by withholding the information are not
outweighed by any public interest in release of the information.
Please note that as part of its commitment to openness and transparency, Police
proactively releases some information and documents that may be of interest to the
public. An anonymised version of this response may be publicly released on the New
Zealand Police website.
In closing, I trust you find the provided information useful, and that you understand the
reasons why it has not been possible to provide you with every piece of information you
requested. If not, however, then as you may already be aware, you have the right to seek
an investigation and review by the Ombudsman of Police’s handling of your OIA request.
Information about how to do so is available at www.ombudsman.parliament.nz or
freephone 0800 802 602.
Nāku noa, nā
Judith Fairbrother
a/Assurance Practice Manager
New Zealand Police