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Answer to Question on Notice on ACLEI's
Conflict of Interest – Declarations Policy
Question No. 1
the hearing on 25 November 2011, Senator Parry asked the following question:
“... could we receive a copy of
the policy that governs the declaration of financial statements and interests
and maybe any supplementary information about time frames involved with
declaring any major changes at all the different levels within the
Hansard, p 6)
The answer to the Senator’s question is as follows:
approach to fraud and corruption risk is outlined in the following sections of
the Integrity Commissioner’s 2010–11 Annual Report:
professional and ethical standards and integrity assurance is described at pages
and fraud management framework is set out on page 80; and
requirements are outlined at page 84.
of the Law Enforcement Integrity Commissioner Act 2006 (the LEIC Act)
provides for arrangements to deal with any corruption issue that may involve an
ACLEI staff member or the Integrity Commissioner.
policy and management framework affecting ACLEI staff members
of Interest - Declarations Policy (APA 2007-001) sets out the ACLEI policy
on conflict of interest and the declaration of financial and other interests. A
copy of the policy is attached for the Committee’s information.
policy requires ACLEI staff members to submit a Declaration of Private
Interests to the Integrity Commissioner upon commencement and to update
that declaration at least annually, or more often as their personal
declarations allow information to be collected about one form of corruption
risk indicator. In addition, ACLEI managers are asked to remain alert to other
indicators, such as lifestyle anomaly and changes in behaviour or “life
factors” (for examples, see Figure Four, page 71 of the 2010–11 Annual
Report). ACLEI staff are also required to provide Contact Incident Reports to
their managers in circumstances when a contact with a person may present a risk
to the agency or to the staff member’s integrity.
addition, all ACLEI permanent and temporary staff members are required to hold
a personnel security clearance from the Australian Government Security Vetting
Agency (AGSVA), issued in accordance with the Australian Government Protective
Security Policy Framework (PSPF). In early 2011, the Integrity Commissioner
upgraded that requirement to Negative Vetting Level 2 (Top Secret).
PSPF requires that all personnel security clearance holders must inform the
AGSVA of any relevant changes to their personal circumstances at the time of
the change and to provide an information copy to their Agency Security Advisor,
in order to allow agencies to manage any risk that may be created. The PSPF
can be found on the Attorney General’s Department website: www.ag.gov.au.
the first instance, all declarations are analysed by the Agency Security
Adviser or his assistant. When warranted, managers are alerted to information
that may concern agency security or integrity. These arrangements are intended
to assist the Integrity Commissioner and ACLEI staff to manage risk, for
example by adjusting a staff member’s duties or removing them from a potential,
actual or perceived conflict of interest.
the onus is on employees to self-declare their interests. Consistent with
ACLEI’s changing risk profile—which is influenced by factors such as staff
numbers, use of secondees, decentralisation of activity, operational tempo and
external threat environment—ACLEI has recently introduced new measures to
improve compliance with existing policies.
requirements concerning the Integrity Commissioner
respect of the Integrity Commissioner, under section 184 of the LEIC Act, the
Integrity Commissioner must give written notice to the Minister of all
interests (financial or otherwise) that the Integrity Commissioner has or
acquires and that could conflict with the proper performance of his or her
the LEIC Act does not specify any specific time frame, the Integrity
Commissioner’s practice is to notify the Minister as soon as practicable of any
relevant interests. The Integrity Commissioner’s declaration of interests is up
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