Australian Public Sector Integrity Frameworks: Rebuilding Trust Amid Ongoing Scrutiny

The integrity wave: Has it receded or gone underground?

Public attention may have moved on, but structural and cultural vulnerabilities remain. Recent reforms and action plans — including the APS Integrity Taskforce’s ‘Louder than Words: An APS Integrity Action Plan’ and increased audit oversight by the Australian National Audit Office (ANAO) — have moved the needle, but only partway.

Recent data supports this. According to the 2024 Commonwealth Integrity Survey^[2], only 63% of respondents rated their agency’s anti-corruption controls as strong, and just 20% of employees correctly identified all five scenarios of corrupt conduct, highlighting significant gaps in both prevention systems and practical understanding. At the same time:

• Agencies are introducing “active bystander” training and rethinking integrity-related education.^[3]
• The Ethics Index 2024^[4] shows a disconnect between public expectations and perceived government performance.
• Even the NACC has attracted scrutiny, including its leaders’ access to exclusive perks during unrelated political controversies.^[5]

The reality is that absence of headlines does not equate to absence of risk. Integrity issues may still exist; they’re just under the surface and hidden from the public eye. Which raises the question: How can APS leaders be confident that their agency is operating with integrity?

What is an integrity framework?

An integrity framework offers a proactive, systemic way to embed ethical decision-making, strengthen compliance and safeguard public trust. It is not merely a set of policies; it’s a structured approach to identifying, managing and mitigating integrity risks.

A robust integrity framework typically includes:

• A tailored code of conduct: Going beyond the APS values and code of conduct, outline how the agency defines and enforces expected behaviour in real-world scenarios. A tailored code of conduct should include guidance for grey areas, such as conflicts of interest, use of discretion and ethical dilemmas in service delivery. It supports ethical conduct in the agency through practical guidance, helping guide staff in complex, high-risk situations.
• Ethics and conduct policies: Clearly articulated policies that staff can understand and apply — not just legalese buried in handbooks. This includes practical guidance for gifts and benefits, secondary employment and whistleblower protections.
• Compliance and review processes: Established internal checks that align with legislative obligations (like the PGPA Act) but also identify blind spots, such as procurement irregularities or recruitment practices that could invite nepotism or bias.
• Training and capability-building: Regular, role-specific ethics training that doesn’t stop at onboarding. Some agencies now embed integrity modules into leadership development or require scenario-based workshops for higher risk functions. The Australian Public Service Academy also plays a critical role by providing foundational and advanced learning in public sector ethics, supporting the development of a consistent and high-integrity culture across the APS.
• Transparent reporting and escalation mechanisms: Clear and accessible reporting processes that surface integrity issues and are perceived as safe. Agencies should evaluate whether their current systems encourage or discourage staff to speak up and whether follow-through is visible and effective.
• Alignment with broader internal controls: A framework that is aligned effectively with other related internal controls, such as enterprise risk management, fraud and corruption control plans and protective security measures. An integrity framework should function as a key risk management tool and help create a more cohesive and resilient approach to governance, risk and accountability.

Several public sector governance models are already in motion. The ANAO’s 2024-25 Integrity Framework^[6] and the “Towards Integrity Maturity” initiative^[7] provide public sector models that can be adapted based on an agency’s size, function, complexity and risk appetite.

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Source: Australian Public Service Commission Integrity (apsc.gov.au)

Beyond compliance: Tangible benefits of integrity frameworks

• They provide assurance to Executives that integrity risks are known and managed — not just hidden.
• They enhance defensibility in times of scrutiny, particularly in the face of the inevitable “Senate Estimates Test”.
• They bolster public confidence, reinforcing that agencies are operating transparently, ethically, and in the public interest - upholding both APS values and code of conduct and the broader expectations of governance in the public sector.

Integrity isn’t a ‘set and forget’ activity

Many APS leaders feel confident in their existing integrity culture and compliance. But history shows that integrity breaches often emerge not from malice, but from blind spots — where processes fail, accountability is unclear or small misjudgements go unchecked.

Agencies with robust training programs can still fall short without early detection tools, clear escalation channels or active oversight of high-risk decisions. Waiting for a potential audit or external review to introduce more comprehensive mechanisms is a risky strategy — agencies need to be ready to demonstrate integrity every day, not just under scrutiny.

To support this, integrity uplift efforts across the APS are increasingly focused on four practical areas: communication, education, evaluation and coordination. These pillars provide a useful structure for maturing integrity controls and embedding a culture of continuous improvement and shared accountability.

A role for assurance in providing confidence to Senior Responsible Officers.

Assurance can play an important role in maturing integrity controls and providing confidence to Senior Responsible Officers (SROs) and their teams that the agency’s integrity arrangements are fit for purpose, robust and contemporary. One of the challenges agencies face is getting access to the right skills, experiences and resources in monitoring and evaluating integrity frameworks. Independent third-party assurance can complement in-house teams to offer broader perspectives, share leading practices and objectively ‘check and challenge’ controls, to facilitate conversations about what’s working, what’s not and what needs to change. A strong assurance relationship gives the SRO access to honest perspectives and equips them with the foresight to make informed decisions before integrity risks escalate.

When a continuous improvement mindset is embedded more broadly in agencies, it supports a more structured and risk-aware approach to monitoring integrity across the organisation and helps agencies to proactively learn, adapt and course-correct before issues emerge.

Critically, implementing an integrity framework doesn’t require a “big bang” approach. It should be iterative — built to match the agency’s risk profile, resourcing and maturity. In many cases, elements of a framework can be integrated into existing structures like internal audit programs, fraud control plans, protective security arrangements, compliance reporting and enterprise risk management. Done well, an integrity framework strengthens governance, mitigates reputational risk and supports a more systematic, risk-based approach to ongoing monitoring, evaluation and uplift.

[1] The Canberra Times “Farewell speech: Glyn Davis on public service integrity,” Accessed July 7, 2025.

[2] National Anti-Corruption Commission “Commonwealth Integrity Survey overall results 2024,” Accessed April 13, 2025.

[3] The Mandarin “Treasury beefs up integrity and ‘active bystander’ training,” October 21, 2024.

[4] Governance Institute of Australia “Ethics Index 2024,” Accessed April 13, 2025.

[5] The Mandarin “Qantas forced to reveal public servants with Chairman’s Lounge access,” October 6, 2023.

[6] Australian National Audit Office “ANAO Integrity Framework 2024–25,” November 1, 2024.

[7] National Anti-Corruption Commission “Towards Integrity Maturity: Mapping the Commonwealth integrity landscape,” Accessed April 13, 2025.