ANAO shares insights on public sector probity

The national audit office has released an insights report to guide government officials who are responsible for managing probity risks.

General public sector ethical and probity requirements are set out in the APS Values and APS Code of Conduct, and there are specific frameworks around particular activities such as grants administration, procurement, risk management and fraud control. Further probity requirements apply to SES employees and agency heads.

However, the ANAO report notes there’s no single definition of probity for the public sector and suggests ethical behaviour, integrity, uprightness and honesty as a good working definition.

Probity is best achieved when it is well embedded in an entity and responsibilities are understood.


While the resource is based on a series of audits of the financial regulators APRA, ASIC and the ACCC released in June, the audit office says the document brings together insights that can be applied across the public sector.

It provides seven key lessons for managing probity in a government entity:

  • promote a culture that supports probity
  • identify probity requirements and assess risks
  • develop policies and procedures to manage probity risks
  • ensure staff are informed of probity requirements via accessible information, specialist officers and training
  • ensure internal risk management controls are effective
  • follow up compliance with probity requirements
  • keep records

It also contains tips on how to enhance probity around procurement, gifts, benefits and hospitality and case studies on assessing the effectiveness of internal controls, and compliance management.

Setting the tone from the top

Understanding the unique probity requirements and risks an entity faces will help leaders manage probity effectively via  the development of fit-for-purpose policies and procedures, the report says.

“Probity is best achieved when it is well embedded in an entity and responsibilities are understood,” it says.

“An entity should create a culture that supports probity, through active promotion and modelling.

“Senior leaders can demonstrate that their entity values probity by ensuring that policies are aligned to ethical expectations and by setting the ‘tone at the top.”

Good record keeping is also essential, and sloppy practices will not only undermine  transparency and accountability, but make it hard for an agency to show it is taking taking probity seriously.

Thought also needs to be given to probity training – including whether it should be mandatory, if refreshers are required and what the consequence of non-compliance with mandatory training are.

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