5. Culture and accountability
   1. It is through a range of frameworks that the obligations of public sector entities and officers are established, operationalised and assessed, including probity and ethical obligations. One such framework through which the public sector assesses whether it is acting with probity and ethically is the integrity framework. In the previous chapter, the Committee examined whether the practice of subsuming probity under the concept of integrity, then using a range of predominantly administrative metrics to demonstrate integrity, allowed agencies to be confident their officers are acting with probity. The Committee questioned this approach.
   2. Integrity frameworks are important and integral to satisfying obligations in the Public Governance, Performance and Accountability Act2013 (PGPA Act) to act honestly, in good faith and for a proper purpose. However, a conflict of interest declaration, a positive performance review, or training in preventing fraud and corruption (and an assurance program to ensure these are undertaken and completed), does not guarantee an officer will undertake a procurement in compliance with the law (as shown in the Artbank audit), or administer a grants program ethically (as shown in the Community Health and Hospitals Program (CHHP) audit).
   3. The previous chapter discussed the Australian Competition and Consumer Commission’s (ACCC) comment that fundamental assurance an agency was acting appropriately and demonstrating probity could occur through independent assessment.[1] Independent audits, such as those conducted by the Australian National Audit Office (ANAO), are an important aspect of accountability. They can examine how officers actually perform their tasks, shine a light on instances where officers do not act with probity or ethically, identify where finance law is breached or where the rules are bent to achieve a pre-determined outcome. However, it is neither possible nor desirable to subject agencies to rolling audits.
   4. Having considered the evidence before it, the Committee concluded what stands between the law (and its regulatory frameworks), and the achievement of outcomes by ethical means, is culture. Possibly the best way to ensure officers act with probity as they go about achieving results is by fostering an organisational culture that expects it.
   5. To this end, the Committee requested agencies:

• provide their definition of culture and explain how a culture that fosters integrity and probity could best be built
• identify metrics and ways by which culture could be measured
• specify how an agency and its leaders could and should be accountable for culture.
  6. In making this request, the Committee was clear that the integrity metrics agencies were embedding appeared able to provide only limited insight on whether officers are actually discharging their duties with probity—if probity is understood in its full sense as acting in a way that models and promotes the highest standard of ethical behaviour, complying with relevant laws and professional standards, acting in a way that is right and proper as well as technically and legally correct, addressing misconduct, and providing leadership.[2] What the evidence provided by entities indicates is that culture is mostly measured by integrity metrics.
  7. This chapter first discusses in general terms the broad themes in responses provided by entities to the Committee’s culture questions.[3] It then addresses the issue of public sector accountability, of entities and policy owners. As outlined in chapter one and discussed further in chapter six, culture and accountability are two of the critical and interdependent aspects of the system necessary to foster an Australian public sector that acts with probity and integrity.
  8. In this chapter, elements of Louder than Words are discussed. Louder than Words is the APS Integrity Plan developed by the APS Integrity Taskforce, which was established by the Secretaries Board to examine APS integrity, identify gaps, and suggest opportunities to learn and improve. The report examined three areas: culture, systems, and accountability, and emphasised the unique role of Australian Public Service (APS) leadership as ‘cultural architects for integrity’.[4] It contains 15 recommendations, some of which are discussed below.

Culture

What is culture

5.9When asked to define culture, the Australian Prudential Regulation Authority (APRA) and the Department of Infrastructure, Transport, Regional Development, Communications and the Arts (DITRDCA) told the Committee about their positive cultures and work to embed integrity.[5] DITRDCA made three statements with regard to its understanding of culture:

• it considers culture in the context of the standards[6] that outline expected behaviours
• it supports staff to understand and embed the standards expected of the public service
• the standards provide DITRDCA with confidence in the way officers work to achieve their objectives.[7]
  10. The Department of Health and Aged Care (Health), the ACCC and the Australian Securities and Investments Commission (ASIC) provided working definitions of culture as encompassing, variously, shared values, beliefs, attitudes, norms, goals, expectations and practices.[8] The ACCC noted culture is dynamic and evolves over time,[9] and Health stated, ‘conduct represents the tangible manifestation of culture through actions, behaviours, and decisions of … individuals’.[10]

Building culture

5.11In terms of building culture, the entities provided similar responses, including that:

• the tone starts at the top[11] with senior executives playing a key role in shaping culture and being accountable through the SES performance framework that places equal emphasis on outcomes and behaviour[12]
• agencies must communicate clearly the expectations for behaviour, including by providing appropriate guidance, tools and training[13]
• there must be a ‘psychologically safe’ environment where staff feel able to contribute ideas, share information and report mistakes, or ‘speak up’[14]
• there must be processes to support the reporting and assessment of instances of non-compliance and misconduct[15]
• there must be broader structures in entities such as integrity and assurance divisions, integrity committees and risk committees, as well as robust internal audit, risk and integrity management frameworks and strategies.[16]
  12. The responses from entities were broadly consistent with the recommendations in Louder than Words with regard to culture, which deal with appointing the right leaders; incentivising good leadership; recognising those who lead with integrity; bolstering the capability of the public sector to lead with integrity by focussing on ethical decision making and fostering psychological safety; and promoting role clarity for the APS.[17]
  13. With regard to the role of senior public servants, Mr Andrew Podger stated the new SES Performance Leadership Framework offered ‘a step in the right direction’. Senior public servants:

… must believe they will be sufficiently rewarded for ethical behaviour, and sufficiently punished for breaches, to outweigh any incentives to the contrary, whether through pleasing Ministers or their offices or public service superiors, because of ‘results’ achieved … for this to have real impact, however, it must feed into the processes for appointment (and termination).[18]

Measuring culture

5.14The following discusses briefly the approach the entities take to measuring culture. Though there is some variation, in general, entities fold probity into integrity, then use a range of integrity metrics (discussed in the previous chapter), in addition to census/survey results, to determine whether their culture is positive.

Department of Infrastructure, Transport, Regional Development, Communications and the Arts

5.15DITRDCA acknowledged it regarded probity and ethics as part of integrity and it built integrity through its Integrity Strategy.[19] DITRDCA told the Committee again about its Integrity Dashboard, which it said provided the Executive with ‘insights on the Department’s Integrity culture and where work may be needed to uplift culture’.[20] The utility of integrity metrics in understanding whether officers are acting with probity and ethically was discussed in the previous chapter.

5.16DITRDCA also told the Committee it participated in the APS Employee Census, which provided useful insights on the ‘department’s workforce planning initiatives that aim to create a skilled, respectful and innovative workplace’.[21] It stated the Department rated highly on diversity, equity and inclusion.[22] Further, it highlighted that 68 percent of staff who participated in the census agreed they ‘have read and understand the department’s Integrity Strategy’.[23]

Department of Health and Aged Care

5.17Health stated it followed the APSC guidance on measuring an integrity culture, and used employee surveys (including the APS Employee Census) and pulse checks. It stated questions in the APS Employee Census that are indicators of an integrity culture included those around the APS Values, bullying and harassment, corruption and fraud, wellbeing, innovation and leadership.[24]

5.18Health stated it also used internal audit measures and metrics. In particular, it assessed the adequacy and effectiveness of the internal control environment as the internal control environment was directly impacted by culture. It is not clear which aspects of the ‘internal control environment’ this refers to. Health also stated it: assessed programs and procedures that communicate values, strategies and objectives; assessed the value and alignment of culture-related training; analysed culture information such as training rates and compliance measures; conducted pre- and post-surveys to analyse aspects of culture; conducted guided behavioural-based interviews; and identified root causes across areas that have received audit based recommendations regarding culture. For instance, Health had recently undertaken an audit of cybersecurity culture and developed a plan to measure security culture uplift.[25]

Australian Competition and Consumer Commission

5.19The ACCC’s approach to measuring culture was to make its expectations of officers transparent. It stated it had three main ways an integrity culture could be measured:

• public transparency and reporting, including through the use of clear metrics, such as those contained in the APS Employee Census, as well as gauging the level of internal fraud and corruption and monitoring ‘whistleblower’ reports
• requiring leaders to demonstrate pro-integrity behaviours
• setting higher expectations above mandated requirements (for instance through its gifts and benefits policy) and adopting best-practice guidance.[26]

Australian Securities and Investments Commission

5.20ASIC highlighted a number of measures it used to measure culture, including:

• key risk factors: training completion rates; annual attestations of compliance with integrity policies; monitoring of declarations of conflicts of interest, gifts register entries, code of conduct investigations, and reported breaches of integrity policies; and monitoring of the number and nature of complaints about agency team members
• exit surveys
• culture surveys and diagnostics, including asking officers to what extent they believe the agency expects them to behave ethically, which includes acting according to the intent of the law
• external reviews, including by the Financial Regulator Assessment Authority.[27]
  21. In particular, ASIC stated its Code of Conduct specifically required officers to go further than simply complying with the law and policies, and that when making decisions, officers are required to consider factors broader than whether the decision complies with legislation.[28]

Australian Prudential Regulation Authority

5.22APRA stated its Integrity Review Group received reporting from data points across the organisation including: whistleblowing; public interest disclosures; and risk and people and culture incidents. It also recently undertook an initial assessment against the APSC Integrity Metrics Maturity Model, and encourages the reporting of wrongdoing by current and former public officials in accordance with the Public Interest Disclosure Act 2013.[29] As discussed in the previous chapter, the capacity of integrity metrics to reveal whether officers are acting with probity or ethically can be limited.

5.23APRA also assesses itself against the integrity maturity framework published by the National Anti-Corruption Commission; gathers data that can indicate how the organisation’s culture fosters ethical behaviour, including through the annual Engagement Survey; measures staff perceptions relating to risk culture through a Risk Culture Survey; and uses ‘various psychometric tools’ to build strong teams with high trust and integrity.[30]

APS Employee Census

5.24Aside from ASIC and APRA,[31] entities mentioned the utility of the APS Employee Census to measuring culture and understanding whether officers are acting with probity and ethically. The APS Census asks questions in a range of areas, including:

• general impressions of current job, including whether the officer feels a sense of accomplishment or is inspired, views on remuneration, willingness to go the extra mile, and ability to participate in decision-making
• general impressions of current work group, including communication, cooperation, adapting to new priorities and tasks, and resourcing
• general impressions of immediate supervisor, including communication, ability to provide feedback, inclusion, and openness to alternative views
• general impressions of senior executive service, including communication, cooperation, persuasion, creating a positive environment, promoting the use of data and evidence
• general impressions of agency and APS, including feelings of personal attachment and pride, whether an officer would recommend their agency, whether an agency inspires the officer to do their best work every day
• a self-assessment of current workloads and productivity, including potential barriers to an officer working at their best (such as clarity, competing priorities, layers of decision making, mobility, flexible work practices)
• how an agency develops officer capability
• staff perceptions of their wellbeing
• staff plans for their future employment, and mobility opportunities
• whether officers feel their agency encourages innovation
• APS Code of Conduct (CoC) questions asking whether staff have observed discrimination, harassment, bullying and corruption
• a variety of entity-specific questions.[32]
  25. There are no questions that test whether and to what extent officers are aware of the legislative and regulatory frameworks under which they work, and whether they act in a way that complies with the intent, rather than just the letter, of the law. Audit reports show officials have repeatedly fail to comply with both the letter and the intent of the law, and it is not clear how the APS Employee Census would provide insights on this.
  26. The absence of questions in the census on sensitive subjects, such as staff confidence in agency advice on grants or decisions on procurement, is discussed below.

Accountability for performance

5.27The Committee heard that accountability for performance rightly sits with individual officers and the accountable authority, however, it does not only sit there—policy owners also have a central role in integrity in the public sector.

Accountability of accountable authorities

5.28The PGPA Act establishes the governance framework for the public sector. Section15 of the PGPA Act deals with the duty to govern a Commonwealth entity and applies to the accountable authority. It requires the accountable authority, amongst other things, to govern the entity in a way that promotes the proper (efficient, effective, economical and ethical) use and management of public resources.[33]

5.29The Public Service Act 1999 (PS Act) mandates that departmental secretaries are responsible ‘to manage the affairs of the Department efficiently, effectively, economically and ethically’.[34] Under the PS Act the responsibilities of the Secretary of a department include: ‘to implement measures directed at ensuring that the Department complies with the law’.[35]

5.30The APS CoC, which is contained in the PS Act, contains 13 requirements, including that officials behave honestly and with integrity; act with care and diligence; comply with all applicable Australian laws; comply with any lawful and reasonable direction given by someone who has authority to give the direction; and use Commonwealth resources in a proper manner and for a proper purpose.[36]

5.31The heads of public sector organisations are also required to establish internal frameworks within their organisations to instruct their personnel on certain matters. For example, the accountable authority of a PGPA entity is authorised to issue Accountable Authority Instructions (AAIs), which can impose obligations additional to the minimum standards established under the PGPA Act and PGPA Rule.[37]

5.32Despite this governance framework that sets expectations for public sector officials, including accountable authorities, Andrew Podger suggested a number of reviews had shown accountability for performance had not been firm enough, and when there was accountability, it was lower level public servants who were held to account, not the senior executive service. These reviews included the Robodebt Royal Commission, which identified a large number of individual public servants who allegedly breached the CoC; and audits by the ANAO which also reveal situations where public servants do not actually meet their obligations under the CoC. However, Mr Podger stated, there is no evidence anybody has been held accountable. He was of the view the matter of holding senior public servants accountable for their performance was not ‘taken very seriously’:[38]

The facts are that senior public servants are extremely rarely held directly to account let alone charged with breaching the Code of Conduct, notwithstanding the responsibilities and duties set out in the Public Service Act and PGPA Act (including to promote, not just to uphold, the APS Values, Employment Principles and Code of Conduct).[39]

5.33When asked by the Committee whether anyone senior has ever been held accountable for failures to deliver, the APSC did not provide an answer, stating secretaries were accountable to the Prime Minister and the relevant minister for their performance, including through an annual review.[40] When further asked whether there were any consequences for failed programs—which failed in terms of ethics, probity, contracting, management, delivery of a contract—the APSC referred to its previous answer and explained to the Committee how the APS CoC functions and its Tranche 2 APS Reforms that would ‘hold senior leaders to account’ including through merit-based appointment.[41]

5.34In his evidence, Mr Podger stated it was:

… evident … that the incentives for secretaries are not sufficiently aligned to probity and ethical behaviour. Pleasing ministers has too often outweighed probity responsibilities. … for secretaries, the probity issues have not been as important to them and their careers as pleasing ministers’.[42]

5.35Part of the problem, Mr Podger suggested, was that performance in the public sector emphasised too heavily the results or outcomes, which was a consequence of a framework adopted in the 1980s of ‘management for results’, which means there is accountability as to results but insufficient accountability for the ethical behaviours, or lack thereof, behind them.[43]

5.36This focus on outcomes was illustrated in an audit report on the performance of the Digital Transformation Agency (DTA), highlighted by the ANAO in its submission. For nine ICT-related procurements examined by the ANAO, the DTA’s procurement of ICT-related services was ineffective and fell short of ethical requirements. None of the procurements fully complied with the CPRs: the DTA did not conduct approach to market or tender evaluation processes effectively, and it did not consistently provide sound advice to decision-makers. The DTA’s frequent direct sourcing of suppliers using panel arrangements did not support the intent of the CPRs including achieving value for money. The DTA responded ‘While the audit report identifies shortfalls in relation to internal procurement processes, controls and education, each of the sampled procurements still achieved their intended outcomes’.[44]

5.37Andrew Podger suggested there was perhaps a misunderstanding amongst ministers and senior public servants as to what is meant by ‘accountability’. He stated:

Under Section 3 of the Act, the first main object of the Act is:

‘to establish an apolitical public service that is efficient and effective in serving the Government, the Parliament and the Australian public’.

Accordingly, the APS has responsibilities to the Parliament and the public, not just the Government. It must act according to the law. And it has a degree of independence reflected in the words used in the APS Values and Employment Principles such as ‘professional’, ‘apolitical’, ‘impartial’ and ‘merit’.

This requires ‘frank and fearless advice’, keeping records and following ‘due process’, actions which, from time to time, Ministers or their staff may prefer not to occur …

Getting the balance right is a perennial challenge, but the evidence suggests that in recent years it has drifted seriously awry, and the rewards for pleasing Ministers have exceeded any penalties from being held to account for lapses in due process.[45]

5.38Mr Podger stated there was a need for a stronger performance framework for secretaries conducted by the Secretary of the Department of Prime Minister and Cabinet, and the Australian Public Service Commissioner, which would look more carefully at the behaviour of secretaries in addition to the results they achieve. While providing ‘frank and fearless advice is a function of character’, it is nevertheless affected by the incentive framework in which people operate.[46] He emphasized:

… there are a lot of good words and good intentions, but the rubber has to hit the road at some point. The performance management of secretaries has to be serious. The incentive framework for secretaries has to be that getting those things wrong is going to be far more serious for their careers … than making a minister feel good that they can make a decision which has political benefits but isn't actually abiding by the rules.[47]

5.39The Department of Prime Minister and Cabinet acknowledged under the second tranche of APS reforms, greater accountability would be put on Secretaries:

… [the reforms] include legislative initiatives around merit based appointments and, particularly, performance of secretaries of departments and agency heads. So that work is looking at strengthening requirements in relation to sustained underperformance in the context of a transparent performance framework, including through consideration of appropriate consequences. Another one of the initiatives that the minister has announced is the strengthening of the commissioner's powers by looking at own motion powers and expanded inquiry powers for the APS commissioner to initiate reviews and investigate alleged code of conduct breaches. So there are some strengthening of legislative provisions that go to some of these issues at a whole-of-system level.[48]

5.40The APS integrity action plan, Louder than Words, contains several recommendations relating to accountability. Mr Podger stated the recommendations in Louder than Words could be strengthened so as to provide the Committee ‘with more confidence that they would lead to sufficient accountability of secretaries and the SES for the performance of their agencies in terms of probity, ethics and integrity’.[49]

5.41The accountability recommendations in the report call for: building a strategic approach to integrity; upscaling institutional integrity; strengthening the integrity of supplier conduct; addressing risks associated with ‘revolving door’ and other conflicts of interest; and measuring and reporting on integrity data across the APS.[50]

5.42Mr Podger suggested the recommendations dealing with building a strategic approach to integrity and upscaling institutional integrity foreshadowed APS-wide and agency-level efforts to promote integrity, but did not, in themselves, provide any metric for measuring integrity performance or ensuring there were consequences for failure.[51]

5.43With regard to the recommendation on measuring and reporting integrity data across the APS, Mr Podger noted the absence of information on what this would entail. He suggested the APSC’s annual employee census could provide relevant information if it included questions on sensitive subjects such as staff confidence in agencies’ advice on grants, or in agencies’ decisions on procurements, or more generally in their managers’ promotion of the APS values, and in relations with Ministers and their offices. Mr Podger suggested such information would complement direct data on breaches of the CoC; on adverse reports by the ANAO, Information Commissioner or Ombudsman; and on promotion appeals.[52]

Accountability of policy owners

5.44The ANAO stated the 2019 Thodey Review of the APS, the 2023 Capability Review of the APSC, and the 2023 Robodebt Royal Commission had highlighted the ‘critical role of policy owners in maintaining a culture of integrity in the sector, including respect for the rule of law’.[53] The Auditor-General stated:

While entity accountable authorities and agency heads must be responsible for compliance within their organisations, policy owners should at least have processes in place to identify the level of compliance across the sector and be willing to modify their regulatory approach if it is not working.[54]

5.45As noted previously, policy owners in the Australian public sector include the Department of Finance; Australian Public Service Commission; National Archives of Australia; and Attorney-General’s Department.[55]

5.46However, the Auditor-General suggested policy owners were not well informed about how their frameworks were used:

The problem that we see with the system is that those responsible for establishing the frameworks rarely undertake any action to assess whether the frameworks are successful or not. They don't collect data. They don't look at whether the system needs to be changed in order to drive improvement, or it's not transparent to the Parliament that action is taken on systemic noncompliance and transparency, which I think is an important role in accountability.[56]

5.47When considering the fact there is almost no formal mechanisms in public sector integrity frameworks to provide assurance on compliance,[57] the Auditor-General was of the view:

It is currently difficult to see how most framework owners are able to provide assurance to government or the Parliament on the effectiveness of the frameworks they, largely, advised should be implemented and which they administer.[58]

5.48When Finance was asked whether it was responsible for ‘holding accountable people accountable’, an official stated it was responsible and accountable for the framework, in particular understanding the practices occurring under the framework and updating the framework as necessary; accountability for compliance with the framework lay elsewhere:

… it comes down to the actions and the practices that exist under that framework, and how people are going about their day-to-day work and businesses, and making sure they comply with that framework. There are accountability mechanisms in place. They include where people act inconsistently with finance law. There are actions that can be taken under the [APS CoC] … So I don't think there's an absence of accountability mechanisms … more often than not performance audits go to practices of individuals and organisations rather than the framework.[59]

5.49Finance expressed its view the framework was functioning:

… there's a difference between practices that are occurring that are inconsistent with the framework and causing problems, and the framework being fundamentally broken, and I don't agree that the framework itself is fundamentally broken.[60]

5.50The Auditor-General questioned whether policy owners did, in fact, understand the practices occurring under their frameworks:

The idea is to know what's going on. We hear a lot about some changes that are going on, but, in any of the information and reports that I see, I never hear an entity responsible for the policy framework suggesting that they haven't been doing a wonderful job and that nothing needs to change. It's always a case of doing some improvement without recognising that there's a problem. Certainly you don't ever hear any suggestion that the problem may be with those who are establishing the policy framework. If the problem exists, it exists in entities and accountability authorities or in individuals. I struggle to see how you can develop a learning culture if you don't confront the issues in the first place.[61]

5.51When it comes to providing advice on the use of the frameworks, the ANAO stated its audits had observed that ‘policy owners are reluctant to take accountability for providing robust advice to entities, defaulting to advising that decisions are for accountable authorities’.[62]

5.52When asked whether it expected entities to follow its advice, the Department of Finance stated the weight its advice carried:

… depends on the nature of the advice and whether we're being asked for a specific view versus a good-practice view. Where we are giving specific advice we expect it to be taken into consideration and actioned.[63]

5.53The AGS took a similar approach to Finance with regard to accountability. When asked directly whether the AGS considered entities should follow its advice, the AGS emphasised its role as legal adviser [emphasis in original]; stating that the AGS was accountable to the Attorney-General as the First Law Officer and consistent with its role, ‘seeks to provide expert and accurate legal advice to government’.[64] The AGS continued:

… compliance with the law is ultimately a matter for government, informed by the legal advice it receives, including advice from AGS.[65]

5.54When asked during the hearing, the Australian Government Solicitor stated ‘I have no doubt that, when AGS advice is sought, agencies do take our advice very seriously.’ The AGS confirmed it did ‘routinely and regularly’ tell decisions makers, whether officials or ministers, where it would locate a proposed decision with respect to lawful power.[66]

5.55However, the AGS said ultimately it did not always have visibility of how that advice was used; and how it was used was ‘something for the agencies … in the context of … their roles, responsibilities and duties’. The AGS role is to ‘assist our clients and those in government by advising in relation to how we would locate a proposed decision with respect to lawful power’.[67]

Footnotes

[1]Australian Competition and Consumer Commission (ACCC), Submission 6.2, p. 2.

[2]This definition is drawn from the Australian Public Service Commissioner’s 2022 directions with regard to the APS Values. See: Australian Public Service Commissioner’s Directions 2022, section 14.

[3]The full detail of entity responses can be found in their respective submissions to the inquiry; this chapter summarises key points only.

[4]Department of Prime Minister and Cabinet (DPMC), Louder Than Words: An APS Integrity Action Plan – APS Integrity Taskforce, November 2023, hereafter DPMC, Louder than Words, pages 2–3.

[5]Department of Infrastructure, Transport, Regional Development Communications and the Arts (DITRDCA), Submission 4.3, p. 1; Australian Prudential Regulation Authority (APRA), Submission 8.2, pages [1]–[2].

[6]These standards were encompassed by the legal obligations on public servants: APS Code of Conduct, APS Values, APS Employment Principles, and Public Governance, Performance and Accountability Act (2013) (PGPA Act). DITRDCA, Submission 4.3, p. 1.

[7]DITRDCA, Submission 4.3, p. 1.

[8]Department of Health and Aged Care (Health), Submission 7.5, p. [3]; Australian Competition and Consumer Commission (ACCC), Submission 6.3, p. [1]; Australian Securities and Investments Commission (ASIC), Submission 3.2, p. 2.

[9]ACCC, Submission 6.3, p. [1].

[10]Health, Submission 7.5, p. [3].

[11]Health, Submission 7.5, p. [3]; ACCC, Submission 6.3, pages 2–3; APRA, Submission 8.2, p. [4].

[12]Health, Submission 7.5, p. [3]; ACCC, Submission 6.3, pages 2–3; DITRDCA, Submission 4.3, p. 2; APRA, Submission 8.2, pages [3]–[4].

[13]DITRDCA, Submission 4.3, p. 1; Health, Submission 7.5, p. [4]; ASIC, Submission 3.2, pages 2–3; APRA, Submission 8.2, pages [1], [5].

[14]DITRDCA, Submission 4.3, p. 2; ASIC, Submission 3.2, pages 3–4; APRA, Submission 8.2, p. [5]; Health, Submission 7.5, p. [5].

[15]Health, Submission 7.5, p. [4]; ASIC, Submission 3.2, pages 3–6.

[16]Health, Submission 7.5, p. [4]; ASIC, Submission 3.2, p. 3; ACCC, Submission 6.3, p. 3; APRA, Submission 8.2, p. [2].

[17]DPMC, Louder than Words, p. 7.

[18]Mr Andrew Podger AO, Submission 1.1, p. 2.

[19]DITRDCA, Submission 4.3, p. 1.

[20]DITRDCA, Submission 4.3, p. 2.

[21]DITRDCA, Submission 4.3, p. 2.

[22]DITRDCA, Submission 4.3, p. 3.

[23]DITRDCA, Submission 4.3, p. 3.

[24]Health, Submission 7.5, p. [5].

[25]Health, Submission 7.5, p. [6].

[26]ACCC, Submission 6.3, p. 2.

[27]ASIC, Submission 3.2, p. 7.

[28]ASIC, Submission 3.2, p. 3.

[29]APRA, Submission 8.2, p. [2].

[30]APRA, Submission 8.2, p. [3].

[31]ASIC stated it conducts ‘culture and engagement’ surveys; and APRA spoke of its annual Engagement Survey and Risk and Culture Survey. ASIC, Submission 3.2, pages 1, 7; APRA, Submission 8.2, pages 2–3.

[32]Australian Public Service Commission (APSC), ‘2023 APS Employee Census’, www.apsc.gov.au/initiatives-and-programs/workforce-information/aps-employee-census-2023, viewed 21 May 2024.

[33]PGPA Act, section 15.

[34]Public Service Act 1999 (PS Act), section 57(2).

[35]PS Act, section 57(2)(c).

[36]PS Act, section 13.

[37]ANAO, Submission 5, p. 2.

[38]Mr Andrew Podger AO, Committee Hansard, 20 November 2023, p. 16.

[39]Mr Andrew Podger AO, Submission 1.1, p. 4.

[40]APSC, Submission 12.2, p. [1].

[41]APSC, Submission 12.2, pages [2]–[3].

[42]Mr Andrew Podger AO, Committee Hansard, 20 November 2023, p. 14.

[43]Mr Andrew Podger AO, Committee Hansard, 20 November 2023, pages 15–16.

[44]ANAO, Digital Transformation Agency’s Procurement of ICT Related Services, Auditor-General Report No. 5 2022–23, pages 8–9, 12.

[45]Mr Andrew Podger AO, Submission 1.1, pages 4–5.

[46]Mr Andrew Podger AO, Committee Hansard, 20 November 2023, pages 14–15.

[47]Mr Andrew Podger AO, Committee Hansard, 20 November 2023, p. 18.

[48]Dr Rachel Bacon, Deputy Secretary, Australian Public Service Reform Office, DPMC, Committee Hansard, 20 November 2023, p. 10.

[49]Mr Andrew Podger AO, Submission 1.1, p. 2.

[50]DPMC, Louder than Words, p. 8.

[51]Mr Andrew Podger AO, Submission 1.1, p. 3.

[52]Mr Andrew Podger AO, Submission 1.1, p. 3.

[53]ANAO, Submission 5, p. 7.

[54]ANAO, Submission 5, p. 6.

[55]ANAO, Submission 5, p. 2.

[56]Mr Grant Hehir, Auditor-General, ANAO, Committee Hansard, 20 November 2023, p. 10.

[57]ANAO, Submission 5, p. 6.

[58]ANAO, Submission 5, p. 7.

[59]Mr Nathan Williamson, Deputy Secretary, Department of Finance (Finance), Committee Hansard, 20 November 2023, p. 4.

[60]Mr Nathan Williamson, Finance, Committee Hansard, 20 November 2023, p. 4.

[61]Mr Grant Hehir, ANAO, Committee Hansard, 20 November 2023, p. 10.

[62]ANAO, Submission 5, p. 6.

[63]Mr Nathan Williamson, Finance, Committee Hansard, 20 November 2023, p. 9.

[64]Australian Government Solicitor, Submission 11, p. 4.

[65]Australian Government Solicitor, Submission 11, p. 4.

[66]Mr Matthew Blunn, Australian Government Solicitor (AGS), Committee Hansard, 20 November 2023, p. 21.

[67]Mr Matthew Blunn, AGS, Committee Hansard, 20 November 2023, p. 21.