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Managing Conflict of Interest - Organisation for Economic Co ...

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154 <strong>Managing</strong> <strong><strong>Co</strong>nflict</strong> <strong>of</strong> <strong>Interest</strong>Agency Procedures and PracticesAgency heads are responsible <strong>for</strong> determining what actionshould be taken where there is a conflict <strong>of</strong> interest. Agencies usethe <strong>Co</strong>mmission’s guidance to develop their own internal policiesand practices <strong>for</strong> managing real or potential or perceived conflicts<strong>of</strong> interest. Agencies’ procedures outline how conflicts are identifiedand managed, and how stakeholders are in<strong>for</strong>med. Proceduresspecify employees’ responsibilities to declare real or apparent conflicts<strong>of</strong> interest and clarify managers’ responsibilities in dealing withconflicts <strong>of</strong> interest. Agency practices include:• Annual completion <strong>of</strong> declarations <strong>of</strong> financial and otherrelated interests (agency heads and senior executive staff);• Deliberate consideration <strong>of</strong> real or possible conflicts <strong>of</strong>interest in work planning and per<strong>for</strong>mance appraisaldiscussions;• Awareness-raising sessions conducted during employeeinduction;• Specific training conducted in relation to the APS Valuesand <strong>Co</strong>de <strong>of</strong> <strong>Co</strong>nduct; and• <strong>Co</strong>nsideration <strong>of</strong> possible conflicts <strong>of</strong> interest and managementresponsibilities in leadership development courses.APS agencies take seriously employees’ failure to appropriatelymanage conflicts <strong>of</strong> interest and, where breaches <strong>of</strong> the <strong>Co</strong>de<strong>of</strong> <strong>Co</strong>nduct are found, agency heads sanction the employeesinvolved.The Australian ExperienceLevels <strong>of</strong> MisconductLevels <strong>of</strong> misconduct are very low in the APS. Of 146,000 employees,only 1% (1,490) were investigated <strong>for</strong> breaches <strong>of</strong> the <strong>Co</strong>de<strong>of</strong> <strong>Co</strong>nduct in 2005–2006. Of all employees investigated, just overthree quarters were found to have breached the <strong>Co</strong>de. 7 Bearing inmind that employees may be investigated simultaneously <strong>for</strong> more7Statistical in<strong>for</strong>mation has been culled from Australian Public Service <strong>Co</strong>mmission.2006. State <strong>of</strong> Service Report, 2005–2006.ADB/OECD Anti-<strong>Co</strong>rruption Initiative <strong>for</strong> Asia and the Pacific

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