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Evaluation of SAFECOM

Evaluation report · Independent Commission Against Corruption (South Australia) (SA ICAC) · South Australia · Tabled

Recommendations
25
Report length
90 pages

Official source

Evaluation of SAFECOM

PDF · 90 pages · 896 KB · icac.sa.gov.au

Summary

The report's own summary: Executive summary, page 10

Generated summary: written by an AI model from the report text and checked against the cited pages.

In the body's own words

  1. Conclusion

    The emergency services sector lacks consistent, clear and adequate guidance regarding the identification, disclosure and management of conflicts of interests.

    Evaluation of SAFECOM - Final Report, page 84

  2. Conclusion

    The nature of induction and other training materials available to staff, volunteers and contractors in all agencies about their obligations to identify and disclose conflicts of interests requires improvement.

    Evaluation of SAFECOM - Final Report, page 84

  3. Conclusion

    Only the MFS has a general conflict of interests disclosure form for employees to complete if they identify that they have any conflicts related to their work.

    Evaluation of SAFECOM - Final Report, page 84

  4. Finding

    All four emergency services agencies have taken positive steps in recent years to improve management of conflicts of interests, including endorsing a generally sound Conflict of Interest and Disclosure Policy which applies uniformly across the sector.

    Evaluation of SAFECOM - Final Report, page 10

Findings, opinions and statements

Allegations are not findings. A commission's finding or opinion of corrupt conduct or misconduct is not a finding that a person is guilty of a criminal offence, and the commissions say so in their reports.

No findings are reproduced in this record. This does not establish that the report contains none.

Recommendations 25

  1. Recommendation 1

    SAFECOM to review and take appropriate steps to amend the ESS Policy Framework to: ⊲ Make clear on the face of the document that it is an ESS policy, approved and accepted by the SAFECOM Chief Executive and the Chief Officers of the services. In doing so, it ought to be clearly stated that the Policy Framework is to be used for the development, review and decommissioning of ESS and individual service policies and supporting documents. The Framework should look similar to other ESS policies, with the logos of all four agencies clearly visible. ⊲ Set out the process by which each individual service develops, reviews and decommissions its own policies (or alternatively each service adopts its own Policy Framework to operate in conjunction with the ESS Policy Framework). ⊲ State that the review cycle of the Policy Framework, like other policies, is three years. After amending the Framework, SAFECOM and the services to ensure: ⊲ That their existing policies and supporting documents are in alignment with the Framework, including having a three-year review cycle. ⊲ That the Framework is communicated and distributed through all four agencies as necessary.

    Evaluation of SAFECOM - Final Report, page 14

  2. Recommendation 2

    In consultation with the services, SAFECOM to develop an action plan to improve the implementation of, adherence to and compliance with the Conflict of Interest and Disclosure Policy in the emergency services sector.

    Evaluation of SAFECOM - Final Report, page 14

  3. Recommendation 3

    In consultation with the services, SAFECOM to: ⊲ Review the Human Resource Management Instrument of Delegations and Authorisations to ensure consistency with the ESS Conflict of Interest and Disclosure Policy and ensure the level of delegation and authorisation for managing conflicts of interests in the four agencies are appropriate. ⊲ Amend the ESS Conflict of Interest and Disclosure Policy to clarify the roles suitable to perform the duties of the delegate, and in doing so, ensure this information is consistent with the information in the ESS Human Resources Management Instrument of Delegations and Authorisations.

    Evaluation of SAFECOM - Final Report, page 14

  4. Recommendation 4

    In consultation with the services, SAFECOM to review and amend the ESS Conflict of Interest and Disclosure Policy to incorporate volunteers. Information in the policy should be consistent with both the CFS and SES Codes of Conduct and the Guideline of the CPSE – Volunteers.

    Evaluation of SAFECOM - Final Report, page 15

  5. Recommendation 5

    SAFECOM and the CFS and SES to develop conflict of interests procedures that sit under the Conflict of Interest and Disclosure Policy. This may involve adapting all or part of the MFS procedure into an ESS procedure or developing separate procedures for each agency. The procedure/s should reference and align with the Conflict of Interest and Disclosure Policy.

    Evaluation of SAFECOM - Final Report, page 15

  6. Recommendation 6

    The CFS and SES to review their Codes of Conduct to: ⊲ Remove a focus on the avoidance of conflicts of interests. ⊲ Clarify that it is not unethical to have a conflict of interests. ⊲ State that the most appropriate way to deal with a conflict is to ensure it is identified, disclosed and appropriately managed.

    Evaluation of SAFECOM - Final Report, page 15

  7. Recommendation 7

    In consultation with the services, SAFECOM to review the MFS Conflict of Interest Procedure and the CFS and SES Codes of Conduct along with the ESS Conflict of Interest and Disclosure Policy and Human Resource Management Instrument of Delegations and Authorisations to ensure: ⊲ The guidance provided by these documents on the management of conflicts of interests is aligned. ⊲ That the MFS procedure and the CFS and SES Codes of Conduct refer to the ESS Conflict of Interest and Disclosure Policy.

    Evaluation of SAFECOM - Final Report, page 15

  8. Recommendation 8

    In consultation with the services, SAFECOM to adapt the MFS Conflict of Interest Declaration Form into an ESS conflict of interest declaration form for all four agencies. This should involve amending the form to document a management plan for conflicts of interests rather than ‘management discussion’, and to include reference to volunteers for the CFS and SES versions of the form. The adapted form should also clarify whether contractors are expected to use it to disclose conflicts of interests.

    Evaluation of SAFECOM - Final Report, page 15

  9. Recommendation 9

    In consultation with the services, SAFECOM to review and amend the ESS Gifts and Benefits Policy, and the CFS to review and amend its Gifts and Benefits Procedure to: ⊲ Include volunteers. ⊲ Improve clarity on the actual, as well as perceived impropriety that can result from the inappropriate acceptance of gifts and benefits.

    Evaluation of SAFECOM - Final Report, page 16

  10. Recommendation 10

    The CFS to: ⊲ Amend its Code of Conduct to include guidance for volunteers relating to gifts and benefits. ⊲ Review its Gifts and Benefits Procedure to improve clarity and consistency of information, and take action to ensure the procedure is approved and does not remain in draft.

    Evaluation of SAFECOM - Final Report, page 16

  11. Recommendation 11

    SAFECOM to ensure that all gifts and benefits for SAFECOM, the CFS, MFS and SES are publicly disclosed, in line with the ESS Gifts and Benefits Policy.

    Evaluation of SAFECOM - Final Report, page 16

  12. Recommendation 12

    In consultation with the services, SAFECOM to amend the draft ESS Procurement Framework to set out the process for managing a conflict of interests when disclosed by the chair of a procurement evaluation panel.

    Evaluation of SAFECOM - Final Report, page 16

  13. Recommendation 13

    In consultation with the services, SAFECOM to amend the draft Contract Management Framework prior to finalisation so that it refers to the ESS Conflict of Interest and Disclosure Policy (and any associated procedures).

    Evaluation of SAFECOM - Final Report, page 16

  14. Recommendation 14

    The SES to amend wording of its Recruitment of Staff Procedure to clarify that: ⊲ The responsibility for identifying and disclosing conflicts of interests rests with selection panel members instead of the chairperson. ⊲ Panel members must disclose any conflicts of interest after reviewing the initial list of applicants, rather than after short-listing has occurred.

    Evaluation of SAFECOM - Final Report, page 16

  15. Recommendation 15

    In consultation with the services, SAFECOM to develop, review and amend recruitment procedures and associated supporting documents in all four agencies to: ⊲ Include clear guidance relating to the identification and management of conflicts of interests in recruitment panels ⊲ Ensure that all discussions about conflicts of interests in recruitment panels are documented in writing. This could be achieved by SAFECOM developing an ESS conflicts of interests disclosure form for recruitment panel members, or another mechanism for documenting discussions in writing that SAFECOM and the services deem appropriate.

    Evaluation of SAFECOM - Final Report, page 17

  16. Recommendation 16

    The CFS and SES to outline in writing a process for managing conflicts of interests when appointing a decision maker to investigate complaints of poor volunteer conduct.

    Evaluation of SAFECOM - Final Report, page 17

  17. Recommendation 17

    To the extent they do not already, the CFS and SES to provide regular (at least annual) reminders to volunteers to consult the Managing Local Funds Information Sheet through whatever means each organisation deem appropriate.

    Evaluation of SAFECOM - Final Report, page 17

  18. Recommendation 18

    Each agency to provide regular (at least annual) written reminders to staff on the topic of conflicts of interests.

    Evaluation of SAFECOM - Final Report, page 17

  19. Recommendation 19

    SAFECOM and the CFS, MFS and SES to review all relevant document templates (including forms, meeting agendas and minutes) to ensure that the requirement to disclose conflicts of interests is included, and to avoid the prefilling of text to suggest there will be no conflicts of interest to disclose.

    Evaluation of SAFECOM - Final Report, page 17

  20. Recommendation 20

    SAFECOM to amend the ESS Induction Checklist so that in the ‘On Commencement’ section or in another appropriate location, it specifically requires new employees to become familiar with integrity related policies and procedures, including the ESS: ⊲ Fraud, Corruption, Misconduct and Maladministration Policy. ⊲ Conflict of Interest and Disclosure Policy. ⊲ Public Interest Disclosure policy.

    Evaluation of SAFECOM - Final Report, page 17

  21. Recommendation 21

    The SES to ensure that its New Employee Induction Checklist: ⊲ Includes the requirement for new employees to review the ESS Conflict of Interest and Disclosure Policy and other integrity related policies, in addition to its own Codes of Conduct and other integrity related procedures and supporting documents. ⊲ Is reviewed and updated as soon as possible, and provision made for it to be reviewed every three years, in line with the ESS Policy Framework.

    Evaluation of SAFECOM - Final Report, page 18

  22. Recommendation 22

    SAFECOM and the CFS, MFS and SES to encourage staff and volunteers (where appropriate) to complete the Commission’s online conflicts of interests and preserving integrity in public administration training courses.

    Evaluation of SAFECOM - Final Report, page 18

  23. Recommendation 23

    SAFECOM to finalise the ethical decision making training package and all four agencies to endorse it as an ESS resource for delivery in the sector, ensuring that: ⊲ In consultation with the CFS and SES, consideration is given to how a version of the package can be tailored to be useful for all volunteers in the sector. This may be different to the final package for employees. ⊲ That the final package/s are disseminated to staff and volunteers of all four agencies and are mandatory to complete.

    Evaluation of SAFECOM - Final Report, page 18

  24. Recommendation 24

    In consultation with the services, SAFECOM take action to increase contractor awareness of their obligations to identify and disclose conflicts of interests. This should include: ⊲ Developing ESS induction materials for contractors to set out their integrity obligations according to sector-specific policies, procedures and codes of conduct and broader public sector guidelines. ⊲ Ensuring that all agencies set out in their conflicts of interests procedures and codes of conduct the penalties that apply to contractors who breach their obligations to identify and disclose conflicts of interest (in addition to penalties for breaches of other integrity obligations).

    Evaluation of SAFECOM - Final Report, page 18

  25. Recommendation 25

    In consultation with the services and to ensure compliance with the Conflict of Interest and Disclosure Policy, SAFECOM to coordinate the establishment of conflicts of interests registers for each organisation. In doing so, SAFECOM should consider the feasibility of having central responsibility for managing and maintaining all registers. This may require amending the ESS Conflict of Interest and Disclosure Policy.

    Evaluation of SAFECOM - Final Report, page 18

Published responses

No published response was found.

Official documents 4

Coverage

This publisher

  • Office for Public Integrity: publishes only its annual reports (excluded); no OPI report or statement records.
  • Since October 2021 the Commission does not make findings of corrupt conduct; most records have no findings.
  • Government and agency responses are recorded only where the Commission's page links them or the report reproduces them; implementation status is not published by the Commission as structured data.
  • Scanned reports without a text layer are not read (no OCR); their recommendations stay not_extracted.
  • Recommendations are extracted only from numbered 'Recommendation N' lists; reports that set out recommendations in prose, tables or unnumbered lists keep recommendations_status not_extracted.
  • Findings are extracted only from investigation reports that state them in the Commissioner's own words (Oakden 2018, Gillman 2015); public statements are not read for findings.