Probity health check

Some of the recent ANAO findings in relation to probity have been:

• Conflict of interest registers were not regularly maintained.
• Declared conflicts of interest were not followed up or managed, and where management plans were in place, they were not followed.
• Failure to set and follow protocols for industry engagement in large projects.
• Inconsistency in the application of evaluation criteria to tender responses.
• Agencies not being able to demonstrate achievement of value for money.

Given the ANAO’s current focus, it is important to ensure your agency has robust and up-to-date documentation and procedures in place to withstand an ANAO audit. Probity templates and processes are often not reviewed or updated regularly to incorporate emerging probity issues. Updating your agency’s probity templates and processes could save significant embarrassment down the track.

Some of the key areas to check are:

Agency’s probity plan and other templates (such as conflict of interest declarations, confidentiality undertakings, probity register, tender evaluation plans) are up to date on emerging probity issues.

• Whether clear and robust processes are in place for probity management including guidance around when to engage external probity advisors, probity checkpoints throughout a project, requirements for documenting decisions and agency policies around conflicts.
• Staff in procurement and other relevant areas are upskilled in probity and understand the emerging probity risks.

It’s important to remember that fulfilling probity obligations is not just a ‘tick-box’ process. It’s about using probity principles to guide projects and ensuring the end to end process is defensible and robust and agency templates and processes should reflect this.

We have unique insights and experience identifying recurring patterns and common gaps in probity documentation and processes, so please come and speak to us if you think your agency needs a probity
health check.