1

Is Honesty Contagious?

Public Policy and Behavioural Science in anti-corruption efforts in New South Wales Local Government

TOMMASO BRISCESE

Photo: HRBestpractices.com

Master in Local Government Centre for Local Government – University of Technology Sydney

2

Table of Contents Introduction .................................................................................................................................................... 3

Definitions ....................................................................................................................................................... 5

Literature Review ............................................................................................................................................ 7

Impacts of corruption ................................................................................................................................. 7

The fight against corruption: a zero-sum game? ........................................................................................ 9

Causes of corruption .................................................................................................................................10

Corruption control systems ......................................................................................................................12

Compliance-based vs Values-based controls............................................................................................13

Organisational culture and ethics .............................................................................................................17

New Public Management and control systems ........................................................................................20

Communication ........................................................................................................................................20

Behavioural Theories ....................................................................................................................................22

The bad apple ...........................................................................................................................................24

Bad barrels ................................................................................................................................................25

The good apple: theory of ethical role model ..........................................................................................26

Ethical leadership .....................................................................................................................................27

Ethical role models ...................................................................................................................................28

Implications for practice ...........................................................................................................................30

Corruption Prevention: the case of NSW Local Government .......................................................................32

Empirical analysis ......................................................................................................................................35

Data ..........................................................................................................................................................38

Results ......................................................................................................................................................39

Discussion .................................................................................................................................................45

Management solutions: shifting the paradigm ............................................................................................47

Conclusions ...................................................................................................................................................50

References ....................................................................................................................................................53

Appendices ...................................................................................................................................................68

Appendix 1 ................................................................................................................................................68

Appendix 2 ................................................................................................................................................70

Appendix 3 ................................................................................................................................................72

Appendix 4 ................................................................................................................................................74

Appendix 5 ................................................................................................................................................76

Appendix 6 ................................................................................................................................................77

Appendix 7 ................................................................................................................................................79

3

“There must have been a time, somewhere near the beginning, when we could have said – no. But somehow we missed it”.

Rosencranz & Guildernstern are dead (Stoppard, 1966)

Introduction

In spite of almost three decades of concentrated efforts, anti-corruption activities in the New South

Wales Local Government do not seem to have been particularly effective. The sector continues to be

the target of ongoing scrutiny by the State corruption watchdog, the Independent Commission

Against Corruption, and its exposure to misconduct remains a hot topic of discussion amongst the

public and the media.

In the everlasting quest of corruption prevention, local governments place great importance on the

development and implementation of codes and policies aimed at guiding employees’ behaviour and

at inhibiting misconduct. In New South Wales (NSW), legislation requires every council to adopt a

Code of Conduct containing provisions that set the minimum requirements of behaviour for council

officials in carrying out their functions. Yet, episodes of misconduct remain a constant feature of the

Local Government landscape: in the last three years alone (2012-2014) three councils were targeted

by the NSW Independent Commission Against Corruption (ICAC) through a public inquiry, and all

three cases resulted in findings of corrupt conduct (ICAC, 2015). In addition, each year the ICAC

receives over 400 public complaints about Local Government, an amount four to five times higher

than any other key area of government in NSW. Further, the awareness of the codes amongst Local

Government employees and the confidence in their effectiveness remains low (ICAC, 2001) and the

practical implications of the Code of Conduct remain predominantly relegated to enforcement and

disciplinary aspects of organisational management.

A comprehensive research is yet to be conducted on the effectiveness of the Code of Conduct, in

other words an analysis of the direct correlation between the aims of the Code (promoting honesty,

care and diligence, and reducing misconduct and unethical behaviour) and its actual demonstrated

achievements. Although intrinsically restricted by its limited scope, this research aims at addressing

this gap. In particular, the paper intends to re-assess approaches to combat corrupt conduct and

identify alternative solutions to traditional measures, framing it in a specific NSW Local Government

context.

4

Drawing on the literature, it will initially attempt to define and assess the problem of corruption, its

multiple causes and the range of prevention solutions available. It will subsequently concentrate on

two main lines of theory around corruption prevention: compliance-based controls and behavioural-

based controls.

Applying these theoretical frameworks to the operations of a sample of NSW local governments, the

purpose of this research is twofold: firstly, it aims at challenging the effectiveness of councils’

policies (such as Codes of Conduct, Secondary Employment Policy) as a tool for promoting ethical

behaviour and corruption prevention; secondly it wants to test the currency of behavioural theories

on social conventions, with particular emphasis on the theories of constructivism and ethical role

modelling.

In essence, the project seeks to shed some light on whether laws and regulations (policy) or people

(behaviour) make the biggest difference in influencing employees’ ethical choices and, perhaps more

interestingly, what is the relationship between the two.

Of particular interest are the theories of moral development, observational learning and

conformism, typically supported by tests affirming that a bad apple can spoil the barrel. The

research undertaken for this project, however, is interested in the opposite positive question: can

honesty be contagious? In other words, do social norms apply in a similar fashion in the positive

sense, so that individuals or employees who behave honestly can influence others’ behaviour and

become ‘agents of change’? Otherwise stated, could we identify the ‘sneezers’ (Godin, 2012), those

individuals with the ability to be believed, to influence and spread change, and guide them towards a

particular kind of behaviour? Could an organisation identify workplace ethical role models and

ensure employees follow their example?

While acknowledging corruption is a multi-faceted issue that can’t be fought with a cure-all solution,

this research concludes that councils should be encouraged to harness the potential that

behavioural science provides in influencing employees’ attitudes and moral principles towards

ethical behaviour.

Finally, in an attempt to translate theoretical principles into practical organisational solutions, it

suggests a management framework centred on the recognition of employees as active social agents

within a Council, and built around the development and recognition of ethical role models. This

5

framework, it is argued, would be quick and cost effective to implement, and would contribute to

the improvement of accountability and reputation of Local Government organisations, as well as a

noticeable reduction in risk and liabilities.

Definitions

Two key words in this research need to be defined: corruption and honesty.

First, there is no one agreed definition of what constitutes corruption. The concept of corruption

itself dates back to ancient Greece and some of its prominent philosophers. Plato (400 BC) and then

Aristotle (350 BC) were particularly concerned about the ‘moral corruption’ of authoritative regimes,

which instead of being guided by the laws were in fact serving the interests of the rulers. They

identified corruption as ‘damaging impurity, some kind of intrusion or distortion that prevented

something from being as it should’ (Hindess, 2001). Often defined as ‘akrasia’, or weakness of will

(see in particular Aristotle’s Nicomachean Ethics) it described the state of mind in which someone

acts against their better judgement, due to either lack of knowledge or more empirically, due to

opinion and choice. This classic interpretation of corruption “as a disease of the body politic”

(Friedrich, 2002, 17) has persisted through the centuries, and was echoed in the works of Dante,

Machiavelli, Montesquieu and Rousseau. Over 700 years ago, Dante Alighieri (1320) placed those

guilty of treachery and bribery in the deepest and darkest circles of Hell, highlighting the medieval

rejection for corrupt behaviour (Krastev, 1998; Tanzi, 1998). Two centuries later Machiavelli (1531)

believed most men are weak, and lacking the virtue (virtu’) of good citizenship, unless guided by a

strong leader. When corruption cannot be stopped by laws, Machiavelli recommended only a

monarchy and a strong and powerful king could exercise absolute power and get rid of corrupted

individuals. Over 200 years later, the aristocrat Montesquieu (1734) studied the fall of the Roman

Empire and traced the origins of such decline in the corruption of the Romans’ moral fibre, caused

by greed for power and loss of constitutional order. Further, when corruption is widespread and

accepted, argued Rousseau (1762), the system is reversed: it is not the corruption of men that

destroys the political system, but the political system which corrupts and destroys men. The

American Constitution (1788) clearly listed bribery and treason as the two crimes that could cause

the impeachment of a U.S. president (Tanzi, 1998).

More modern literature (see for example Peters and Welch, 1978; Dolan et al., 1988) distinguishes

between ‘formal definitions’, such as the ones provided in legislation, codes of conducts, ‘public

6

interest definitions’, defining corruption as the betrayal of public trust or good, regardless of laws

and codes, and ‘social definitions’ such as community and workplace views about what is corrupt

(see for example Johnston, 1986). Anti-corruption agencies offer an instrumental description of

corruption aimed at defining their specific jurisdiction (see ICAC Act, 1988, section 7-9), and

therefore should not be considered as universal.

A dictionary definition includes synonyms such as adulteration, contamination, moral depravation,

destruction (see for example Collins English Dictionary, 2015). Euben (1990) argued that in the case

of government, then, corruption in its most general sense refers to anything that prevents

government from being what it should.

Transparency International influentially defines corruption as the ‘misuse of entrusted power for

private gain’ (Pope 1996), while the World Bank (1997: 8) refers to ‘the misuse of public office for

private gain’, both highlighting the failure to distinguish private matters from public ones.

Definitions abound, and arguments have even been made that it is unproductive to define and

theorize corruption (Johnston, 1996), on the assumption that individuals ‘know it when they see it’.

On the other hand, quite often the definition of corrupt behaviour overlaps with other notions such

as unethical behaviour, antisocial behaviour, dysfunctional deviance, organisational misbehaviour

and counterproductive misbehaviour (see for example Bennet and Robinson, 2003; Marcus and

Schuler, 2004; Treviño et al., 2006).

In the context of this research, however, it is considered more appropriate the use of the single

word ‘corruption’. As aptly argued by Ashfort et al. (2008: 671), ‘corruption’ is a “strong provocative

term, it calls attention to undesirable behaviour, and it resonates immediately with scholars and

practitioners”. In addition, the concept of corruption reflects not just the corrupt behaviour of any

single individual, but also the dangerous, virus-like infection of a group, organisation, or industry,

which is at the core of this research.

Second, for the purpose of this research the choice of the word ‘honesty’ is aimed at identifying a

value, a concept that the majority of stakeholders could relate to. It has to be taken as broadly

referring to law abidance, but also to ethical behaviour, and the more complex moral choices that

come with it, such as whistleblowing. Once again, public relatability influenced the choice of words:

as described by De Vries (2002: 309), the ethos (general principle) of honesty is a “universal value,

7

which conforms to deontological principles”. And while citizens should expect public administrators

and governing politicians to be professionally skilled to undertake their jobs (Wilding, 1979), some

might argue that they “should at least be honest” (De Vries, 2002: 309). However, this seems to be

in contrast with the general view of some citizens.

Literature Review

In an effort to provide the context of this research, and to condense the extensive literature

available on the topic of corruption prevention and control systems, this section has been divided in

three parts. The first is dedicated to the impacts of corruption, its causes and the discourse around

value and purpose of fighting corruption. The second part analyses the causes of corruption, the

systems of control and the importance of communication. Finally, the third part is dedicated to

behavioural theories and specifically to the ‘good apple’ theory of ethical role modelling.

Impacts of corruption

According to Nocera (2002: 64) interacting with government, similarly to investing in business, is an

“act of faith”: we need to trust that their “services are rendered accurately, that organisations are

being run honestly, oversight groups are playing it straight and that stakeholders are not being

deceived”. However, as Colvin (2004) aptly puts it, “trust is slowly won and quickly lost”, and every

organisation must appreciate the extent of the damage corruption can cause, and be aware that

“even if the causes of corruption are not entirely systemic, the consequences are” (Ashfort et al.,

2008: 675). Corruption is considered one of the main obstacles to sustainable economic, political

and social development by the Organisation for Economic Cooperation Development (OECD), as it

reduces efficiency and increases inequality (OECD, 2014). According to the World Bank’s Institutional

Integrity Department Director Suzanne Rich Folsom, “corruption has a devastating impact on the

capacity of governments to function properly; on the private sector to grow and create employment;

on the talents and energies of people to add value in productive ways; and ultimately on societies to

lift themselves out of poverty” (World Bank, 2007).

The mere perception of corruption plays such a critical role in citizen and customer trust that

Transparency International uses it as a measuring unit for their annual Corruption Perceptions Index.

The Index ranks countries and territories based on how corrupt their public sector is perceived to be,

based on a survey of thousands of international business leaders, risk analysts and business

journalists. A country or territory’s score indicates the perceived level of public sector corruption on

8

a scale of 0 (highly corrupt) to 100 (very clean). A country or territory's rank indicates its position

relative to the other countries and territories in the index (TI, 2015).

In 2014, the index included 175 countries and territories, and a summary of the ranking can be found

in the map in Figure 1 below.

Figure 1: Transparency International – Corruption Perceptions Index 2014

Source: Transparency International, 2014

In the graphic map that accompanies the annual report by Transparency International, countries are

‘colour-coded’ based on the score received on aspects such as accountability and transparency

frameworks, whistle-blower protection, freedom of media and clear commitment by the political

leaders, with lighter colours representing a low level of corruption perception (or “Very Clean”

ranking) and darker colours representing a “Corrupt” or “Highly Corrupt” perception score (TI, 2015).

For the year 2014, Australia ranked 11th, a drop from 9th in 2013, 7th in 2012, and 8th in 2011 (TI,

2015). At the top of the class, Denmark, New Zealand, Finland and Sweden have consistently

remained the best four countries for the past four years (TI, 2015). By contrast, North Korea,

Somalia, Sudan and Afghanistan sit at the bottom of the charts with extremely high perception of

corruption (TI, 2015). While Transparency International’s annual Index is much awaited and much

reported on every year, some researchers (see Tanzi, 1998) invite caution when analysing its

9

findings, warning against confusing these perception indexes with objective and quantitative

measurements of actual corruption.

From a monetary perspective, a 2011 worldwide report by consultancy firm

PricewaterhouseCoopers states that unethical behaviour creates trillions of dollars in financial losses

every year and is becoming increasingly commonplace. Worldwide estimates report the cost of

corruption equals more than 5% of global GDP (US$2.6 trillion, World Economic Forum, 2014) with

over US$ 1 trillion paid in bribes each year (World Bank, 2014). While calculating the costs of

corruption in monetary terms is viewed with scepticism by some researchers (for example

Transparency International, 2015), as it risks underestimating the social, professional and

reputational damage it causes, it is widely recognised that a 5% of annual budget is a relatively

reliable estimate of the costs any large organisation could face due to fraud and corruption (OECD,

2014; World Economic Forum, 2014). The impacts are equally frightening for large government

agencies as well as for smaller local governments. For example a council with an annual budget of

$50 million could suffer losses due to fraud and corruption of up to $2.5 million. During the course of

this research a NSW council revealed that an ICAC inquiry involving one of the organisation’s senior

managers attracted over $1 million in legal costs, and immeasurable losses in productivity and staff

time due to plummeting morale and increased turnover.

In summary, the monetary and reputational repercussions of corruption are equally big and long

lasting, affecting the sustainability of a country or an organisation, and damaging the trust and

support of the community. By any standards, the problem of corruption cannot be ignored.

The fight against corruption: a zero-sum game?

Often, political discourse around corruption tends to attract polarised, and perhaps populistic, views

centred on slogans such as ‘eradicating’ corruption or ‘declaring war’ on corruption (see for example

BBC, 2015; ABC, 2014; AFR, 2015; Republika Online, 2015; Economic Times, 2014). These ambitious

agendas, however, seem contradicted by continuous scandals and episodes of misconduct, leading

some researchers to declare that the future will never be quite “free of corruption” (Johnston, 1993:

3) and that “corruption can never be entirely eliminated” (Pope, 1996: vii). At the base of any

program aimed at tackling corruption, argues Tanzi (1998: 587), there needs to be an

acknowledgement that there will always be “a demand for and supply of corruption”: there are

“those who demand acts of corruption on the part of public sector employees and there are public

employees willing for a price to perform these acts”. The opinion categorises the individual as a

10

rational maximiser responding to incentives, rather than as a moral agent (Polzer, 2001: 20). These

views are particularly strong in Transparency International’s stance on corruption: the NGO’s Source

Book (2000: 1) claims “the potentially corrupt will always be with us” and adds “in every society

there are those who will try to beat the system and if the system is vulnerable, there will be more of

them” (TI, 2000: k).

Given these fatalistic approaches to the problem of corruption, should prevention efforts be

dismissed as ineffective and Don Quixotian? The answer is probably not. As aptly put by Braibanti

(1962: 372), “corruption is a terribly complex phenomenon which must be attacked in a variety of

ways, some of which are long range and subtle and some of which are practical and can have

immediate discernible effect”. Success stories are available: a number of countries, such as Hong

Kong and Singapore, have managed to reduce the incidence of corruption significantly. So, argues

Tanzi (1998: 586) “governments should not be fatalistic or passive about corruption”; with well-

focused and determined efforts, “corruption can be reduced, though not to zero” Tanzi (1998: 586).

A number of authors have pointed out that the costs of eliminating corruption altogether would be

prohibitive (Pritzl, 1997; Rose-Ackerman, 1996). It would simply not be worthwhile in economic

terms, but it might also be incompatible with the liberal traditions that influence democracies

(Galtung, 1998), as it would necessarily entail solutions such as limitation of civil rights, excessive

penalties, changes in legislation.

Hence, the aim for public administrations is to implement sustainable corruption controls, strategies

that tackle endemic corruption (Doig, 1994; Galtung, 1998) and reduce it “to levels that are both

tolerable and incidental” (Braibanti, 1962: 372). An optimal theoretical level, adds Tanzi (1998: 586)

would be reached “where the marginal costs or reducing corruption further would be equal to the

marginal social benefits from that reduction”. In conclusion, it is likely that no country is or ever will

be free of corruption.

Causes of corruption

It is important when attempting to analyse and address a complex issue such as corruption, to

identify its causes. This approach, argues Hurst (2005) is “of great practical importance if we are

interested in creating, enhancing, reinforcing, reducing or eliminating a given situation or

behaviour”.

11

There is vast literature on the causes of corruption, and the following examples should not be

considered an exhaustive sample. In an oversimplified way, a common thread can be identified in all

theories related to the causes of corruption: it is a combination of failures in the control or cultural

systems together with the presence of opportunities for misconduct, which affect the risk

assessment by an agent (individual or a group), ultimately leading them to decide that the ‘reward’

or benefit is worth the risk of being caught.

One of the most recognisable theories was developed by Reason (1990) who graphically described it

as the holes in Swiss cheese, which need to be aligned to allow the behaviour to occur. Reason

(1990) talks of corruption as the result of simultaneous failure of three main barriers (see Figure 2):

system, capability and culture.

Figure 2: James Reason’s Swiss cheese model of accident causation

Source: Reason (1990)

The ‘Swiss Cheese model’ of accident causation is a model used in risk management across a wide

range of areas, including computer security, engineering, aviation and healthcare. In the model, an

organisation's defenses against failure are modeled as a series of barriers, represented as slices of

cheese. The holes in the slices represent weaknesses in individual parts of the system and are

continually varying in size and position across the slices. The system produces failures when a hole in

each slice momentarily aligns, permitting "a trajectory of accident opportunity" (Reason, 1990), so

that a hazard passes through holes in all of the slices, leading to a failure.

Evolving Reason’s concept, Gorta (1998) shows corruption can take place when the following occur:

Opportunity (poor systems)

Little fear of exposure

12

Lack of ethical leadership

Cultural acceptance of aberrant behaviour

Other views (see Jorna, 2014) offer a more psychological explanation to the phenomenon,

identifying the following as triggers for corruption:

Incentives (e.g. money, but also a faster approval or service provision)

Bad apple contaminating the others

Group pressure – wanting to fit in

Patronage – powerful position

Fairness – other people do the wrong thing, so it’s ok for me to do it as well

Corruption control systems

Before delving into the specific control measures available to combat corruption, it is believed

necessary to clarify that this research paper is built around the assumption that government

agencies, in particular local governments, and their leaders, have an interest in controlling

corruption.

As argued by Lange (2008) leaders would support control as a means to improve organisational

effectiveness and efficiency and, in turn, staff members would accept control systems because they

believe “the outcomes of control to potentially be beneficial to the common good”, for example in

the form of order, productivity, performance measures and rewards.

Theorists from a Marxist perspective, however, dispute these assumptions, and describe control as

exemplifying the ongoing conflict between classes in society, with the ruling class exploiting the

working class (see for example Braverman, 1974). In other words, Marxist theorists look at the

international attention to corruption as a hindrance to economic development as a “tactic, part of

the broader strategy of increasing the autonomy of state bureaucracies from local interests and

elites so as to be more hospitable to transnational capital and so as to make the policies and actions

of the state much more predictable and transparent to outsiders” (Bratsis, 2014: 108).

From another different perspective, a number of economic studies have supported the concept that

corruption can be good for growth. Heckelman and Powell (2008), for example, found that

corruption is beneficial in countries where the economic freedom is low, and Leff (1964) and

Huntington (1968) suggest that corruption could “enhance growth by allowing individuals to pay

13

bribes in order to circumvent inefficient rules and bureaucratic delays”. In other words, in some

situations corruption can oil the rusty cogs of bureaucracy.

Compliance-based vs values-based controls

Just as different diagnoses of a disease suggest different cures, different explanations for corruption

suggest different remedies (Gorta, 2001). In their ambitious publication “Corruption and anti-

corruption” (2001), Larmour and Wolanin argue most organisations opt for interventionist and

managerialist approaches to corruption control. Interventionism refers to the ‘law and order’

approach adopted by most western methods of policing: wait for a crime to be committed and then

intervene in the conduct of the offender (Larmour and Wolanin, 2001). It is assumed this system

provides a level of deterrence for the repeated offender and for others contemplating similar

conduct, but it has weaknesses, in particular in relation to corruption prevention. Larmour and

Wolanin (2001) argue that, unlike other crimes, in corruption cases “intervention is the exception

rather than the rule”, there is typically no victim at the scene of the crime (‘happy giver, happy

receiver’ situation), making the crime practically invisible. From a compliance point of view, unless

everyone is engaged in the supervision of everyone else, monitoring would be impossible to

resource and sustain.

Managerialism, also referred to as administrative or compliance controls, endorses the ‘prevention

is better than cure’ approach, whereby creating appropriate systems, procedures and protocols can

discourage or prevent possible agents from corrupt behaviour. The theory assumes that by reducing

or eliminating the opportunities one can reduce misconduct. Managerial and or compliance oriented

controls standardize work processes (Mintzberg, 1979) and include formalised rules, codes, routines,

policies, audit systems, approval systems, registers, set in hierarchical and centralized structures.

These means of control constrain the range of employees’ behaviours, make their actions

predictable, and increase the likelihood that behaviours will be consistent with organizational

objectives (Johnson & Gill, 1993). Patterns of behaviour dictated by managerial controls become

routinized and taken for granted (March and Simon, 1958; Nelson and Winter, 1982), and employees

conform to procedures because they provide the path of least resistance for accomplishing the task

at hand, or for fear of punishment.

While these formal systems can help to prevent unethical behaviour, research suggests that they can

also be easily ‘decoupled’ from the organisation’s daily life (Weaver et al., 1999). In other word,

organisations can adopt a “check-off approach: Do we have a code and do we tell everyone about it?

14

Check. Do we provide regular training? Check. And so on”, resulting in employees viewing these

methods as simple “window dressing” (Weaver et al., 1999). Similarly, Brereton and Temple (1999:

470), in commenting the 1995 Nolan Report on the characteristics of good public service in Britain,

warned against relying on “formulae” that “provide a legalistic checklist but throw little light on the

policy orientation or managerial ‘mind set’ of those engaged in the new governance”. According to

Brereton and Temple (1999) codes of conduct founded on such principles simply “define the ways in

which shortcomings and malfeasance shall be identified and presumably acted against. They do not

describe the way in which such communities now define the nature of the public interest and

identify the most appropriate means for its pursuit”.

Robert Merton, in his eminent Social Theory and Social Structure (1957), cautioned on the side

effects of rule-following behaviour in public administration: bureaucracy, he argued, can become

dysfunctional because of “obsession with procedural compliance” and “unconditional conformity

with rules and procedures, regardless of the goals of the organisation or the efficiency of the

enterprise”. According to March and Olsen (1989) bureaucracies “maximise formal procedures for

their own sake and as a form of ritual behaviour”. This results in standard operating procedures in

which the consequences of their actions are neglected. Following the rules and procedures “can

become an end in itself” (Merton, 1957) and presents a symbol of good governance but not good

governance as such.

Examples of failures in the managerial/bureaucratic/compliance system of control abound.

Famously, U.S. petroleum giant Enron had a 64-page code of ethics booklet, centred around respect,

integrity, excellence and communication and around moral and legal obligations, and yet it was

involved in one of the biggest scandals in American corporate history (New York Times, 2002;

Investopedia, 2015). Similarly, auditing giant Arthur Andersen slid from long-standing firm with

impeccable reputation to its complete demise for unethical predatory business practices in just a

few years, despite having an established code of conduct and ethics code (Toffler, 2003).

In analysing the failures of compliance oriented controls, Webley and Werner (2008) argued that

there is an “apparent gap between intention and operation”. Larmour and Wolanin (2001) identify

the main failing of this system in that it does not take into account the people, their characters and

their complexities. In a nutshell, argue the authors, “whatever regime of rules is established, it can

be subverted” (2001, p.18). The effectiveness of policies, in particular codes of conduct, has been

openly questioned in the last decade. A Harvard Business School study (2005) cautions that “a world-

15

class code is no guarantee of world-class conduct”, and Paine et al (2005) add “a code is only a tool,

and like any tool, it can be used well or poorly, or left on the shelf to be admired or to rust”. Others

define codes as a marriage licence: “unless the participants make a serious commitment, it is only a

piece of paper” (McMillan, 2012). Myers (2003) argues developing an organisation’s control system

around the “3P approach”, in which you “Print a code of conduct, Post it on the wall and Pray people

actually read it” is not the basis of an effective program.

In relation to ethics in the public service, observations have been made that “it is about aspects of

decision making where judgement has to be applied” and that “such judgements are not easy; they

simply cannot be made according to formula” (Chapman, 2011: 7). Cynicism amongst employees is

also a potential downfall of a compliance oriented model: a research conducted by Donnelly (2005)

revealed that while employees thought codes of conduct were having a positive impact in making

the organisation a better place to work, they also admitted that they thought management was

simply trying to comply with the law, and that their organisation had a code of conduct so

management can protect itself. Bibb (2010) argued it is not a “bad thing” to have a code of conduct,

but “having one does not guarantee an ethical culture”. According to Bibb (2010), the problems with

codes of conduct are twofold: “they cannot possibly cover all situations and eventualities, and

usually ethical issues are not as simple as saying ‘this is the right answer’”.

Overregulation, caused by the attempt to cover every eventuality, can also be as detrimental to an

organisation as the lack of it. Roman philosopher Tacitus wrote in 117 BC that “Corruptissima re

publica plurimae leges” (“the more corrupt a state, the more laws it will have”), warning on the

proliferation of legislation that was set to stifle the government of ancient Rome and breed

corruption. Anechiarico and Jacobs (1996) described how successive scandals in New York had led to

the proliferation of regulations and oversight mechanisms designed to prevent or eliminate

corruption, and that by doing so the municipal government was becoming increasingly ineffective,

undermining the organisation’s ability to govern. Other risks with this approach are that an excess of

rules can lead to a culture of “approval by omission”, where in the absence of a rule there is an

assumption that the behaviour is permissible (Larmour, 2001). And excessive reliance on compliance

systems can engender complacency, thinking that the mere development of policies, plans and

codes will prevent any wrongdoing.

Another vast section of literature on corruption prevention relates to reporting misconduct,

otherwise known as ‘whistle-blowing’. Particularly relevant to this research is the study conducted

16

by Somers (2001) into the relationship between codes of conduct and whistleblowing. Somers

(2001) found that neither the presence of corporate codes of ethics nor familiarity with a

professional code of ethical conduct had any influence on the decision to report observed unethical

activity in organisations. In particular, Somers (2001: 193) noted that ethical codes implemented by

organisations “serve to set guidelines for individual behaviour, thereby inhibiting wrongdoing, while

whistle-blowing, with its associated risks, might be a more personal decision, possibly seen by some

employees as outside the realm of expected behaviour”.

In conclusion, empirical studies have supported the view that corporate codes contribute to the

inhibition of unethical behaviour in organisations (Tsalikis and Fritzche, 1989; Murphy et al., 1992),

and there is overall agreement that where rules are not explicit, rules should be made (March and

Olsen, 1989; OECD, 1998). Some research also found that employees might value a compliance

oriented program, in particular when it relates to punishment for misconduct and upholding

standards of justice (Treviño, 1993). However, while people are motivated to seek justice (Lerner,

1977), a compliance model centres on monitoring and discipline and suggests distrust of employees.

In addition, rules are generally imposed from the outside, in a top-down manner, and compliance is

generated through fear of discipline, rather than identification and internalisation process.

Therefore, it is argued that from a conceptual point of view, codes of conduct and codes of ethics

merely highlight an organisation’s commitment to promoting ethical behaviour, with limited

implications on the behaviour itself. As aptly put by Erikson (1995) “we must realise that it is

impossible to eliminate corruption by making laws, if the laws are not in conformity with the public

morality”. Yet, many organisations only deal with corruption risks by relying on some interventionist

activities coupled with some measures of managerialist controls. So it appears the point to address

is the gap between the values contained in the codes and the “operational values”, in other words

“how things really work around here” (Paine et al, 2005), which Webley and Werner (2008) feel is

rooted in ineffective ethics programmes and deficiencies in corporate culture. Organisations are

therefore encouraged to explore another way, one that operates at cultural level, that establishes

and builds on social norms, that promotes solutions aimed at internalising values and promoting

integrity in all aspects of organisational decision making.

17

Organisational culture and ethics

The promotion of an organisational culture founded on ethical principles is not an easy task.

Rohr (1978) describes it as “a crossroads between the high road and the low road of ethics”. The low

road leads down the path of compliance, with a framework made of “quantifiable performance

measures” such as maintenance of registers of interest; the high road is far more ambitious, “leading

to an ethical culture that permeates throughout the organisation”. This approach is about

establishing a social norm in an organisation which accurately defines and resists corruption; it’s

connected to the notion of ethical governance, and the commitment of accountability, probity and

integrity in all activities undertaken by the organisation.

The literature presents a clear distinction between controls transmitted along social/cultural

channels and those transmitted along administrative channels (cf. Cyr & Welbourne, 1997;

Hopwood, 1974; Johnson & Gill, 1993; Ouchi, 1979 and 1980), between top-down approaches and

ones that attempt to foster shared interpretations of organizational life and the development of

common expectations and value-based norms and sanctions (Tompkins and Cheney, 1985).

On a practical level, each organisation will adopt and promote a different set of values, but the

underlying principle for the public sector must be one of serving the public interest, characterised by

O’Toole (1993) as being “…about the setting aside of personal interests…working altruistically for the

public good…it is about working with others…to promote that public good. It is about integrity in

dealing with the many and diverse problems which need solving if the public good is to be

promoted”.

Pratchett and Wingfield (1994: 9) identify a set of core values that should inform the behaviour of

local bureaucrats:

1. Accountability

2. Honesty and impartiality

3. Serving the community

4. Altruistic motivation

5. A sense of loyalty to community, profession, organisation

The aim for organisational leaders is to generate employee identification with and commitment to

collective organisational values (Etzioni, 1961; Gouldner, 1954; Weber, 1947), and to support

alignment of behaviour with organisational expectations (Weaver and Treviño, 1999), to the point

18

that employees act according to them, perhaps because they are consistent with the employee’s

own needs, goals or identity (Adler and Borys, 1996).

Larmour and Wolanin (2001) refer to “the integration of an organisation’s operational systems,

corruption control strategies and ethical standards”, so that ethical issues would be considered

together with financial, political or operational issues when making strategic decisions (Lawton and

Macaulay, 2004). Programs emphasising values, counselling, and responsible conduct, argues Paine

(1994), are also likely to have more desirable and long-lasting impacts than programs founded on

rule-compliance.

This theory resonates with Michels (2014), Ethics Officer for the United Nations Office for Project

Services (UNOPS), who provides a poignant distinction between ethics and compliance, as

summarised in the table below:

Figure 3: Michels: Ethical and Compliance approaches to corruption prevention (2014)

ETHICS COMPLIANCE

Prevention Detection

Principles Law

Values Fear

Discretionary Mandatory

Spirit of law Letter of law

Implicit Explicit

The argument offered by Michels (2014) presents on one hand the mechanistic views informing

compliance oriented systems: they might achieve results, but are likely to be short-time and reactive

in nature; on the other hand an ethics system based on constructivism principles, although less

predictable at first, might offer longer term success rate.

Along similar lines, research conducted by Somers (2001) showed that organisations that build a

supportive climate and include values emphasising integrity and ethical conduct and engender

commitment to those values, have a better chance at turning ethical conduct into a “way of life” for

their employees. When employees internalise the values associated with ethical behaviour, they are

motivated intrinsically to avoid corrupt behaviour and ethical behaviour becomes part of their

identity (Aquino & Reed, 2002), to the point that the avoidance of corrupt behaviour becomes an

inherently satisfying end in itself (Deci, 1975).

19

Another important aspect identified by the research is the psychological link created between

shared values and expectations or norms for appropriate behaviour within an organisation, which in

turn define roles for organisational members (Ashforth and Mael, 1989; Stryker, 1980; Stryker and

Serpe, 1982). According to this line of research, part of a person’s sense of self is learned through

interaction with others, so these roles constitute an element of one’s identity (Weaver and Treviño,

1999). In summary, even though an employee will have his or her specific role and values within the

organisation (e.g. a finance manager, or a community services officer) the set of shared values will

provide the employee with increased understanding of his or her identity within the total set of

organisational roles, and most importantly affect the employee’s own ethical identity.

Another line of research has been dedicated to social exchanges between organisations and their

members. Particular focus has been directed to the relationship between the sense of support from

the organisation and the level of commitment by the employees. According to Eisenberg,

Huntington, Hutchison and Sowa, 1986: 501) organisational support can be summarised as the

employees’ sense perception that their organisation “values their contribution and cares for their

wellbeing”. In turn, a perception that the organisation supports the employee’s goals creates a

sense of obligation by an employee to support the organisation’s goals in return (Eisenberg et al.,

1990). Weaver and Treviño (1990: 320) add to the theory by stating that a values-oriented ethics

program can be perceived as supporting employees: “instead of focussing solely on the detection

and discipline of offences”, argue the authors, “suggesting perhaps that employees cannot be

trusted, or are in some way ethically incompetent – a values-oriented program suggests that

employees already are committed to ethical behaviour and all have the same status when it comes

to ethics, and so the program aims at developing a set of shared ethical values”. Turning awareness

of ethical issues into an in-role behaviour is also believed to reduce tendencies toward “moral

muteness”, in which employees keep silent about ethical issues at work (Bird and Waters, 1989).

Festinger (1957) argues that given the reciprocal sense of obligation between individual and

organisation, witnessing unethical behaviour would create a “serious cognitive dissonance” in the

employee, therefore increasing the willingness on the part of the employee to deliver “bad news” to

their manager or supervisor. In addition, clarity and alignment of role expectations for the employee

will reduce the possibility of conflict between personal and organisational values, therefore reducing

stress and improving staff’s willingness to stay with an organisation (Weaver and Treviño, 1999).

20

New Public Management and control systems

Among the various theoretical frameworks analysed as part of this research, it is important to make

a brief reference to the model of New Public Management (NPM), as it presents practical

implications for organisations concerned with corruption prevention. The concept of New Public

Management (NPM) emphasises lean and purposeful administrative structures (Hood, 1991) with

private sector management thinking. The enthusiasm towards this new approach, however, was

originally met with some resistance by some researchers (see for example Pratchett and Wingfield,

1994), who felt that the push towards NPM meant a movement away from the traditional focus on

procedural integrity to concentrate more on efficiency and performance measurement, where public

service honesty is considered a given, and therefore not requiring rules, procedures or constraints.

More recent views, however, highlight that promoting efficiency should not be seen as facilitating

unethical behaviour. The NSW ICAC (Waldersee, 2013) promotes a concept of “tight operation” by

highlighting that organisational systems designed around clear goals and efficiency, with strong

project management frameworks, well designed processes with associated performance measures

and controls and clear responsibilities, authority and accountabilities can be stronger deterrents

than policies and procedures. It is the “new culture of governance” referred to by Brereton and

Temple (1999: 471), supporting a “shift in ethical focus from process to end product, and from a

professionally self-referencing definition of efficiency and effectiveness to one defined in terms of

outcomes”. The importance of clear strategic goals and accountabilities cannot be underestimated,

even in the absence of specific corruption control systems: research has shown that workers who

perceive their company’s climate as promoting responsibility for the customers and the community

are less likely to engage in unethical business practices (Barnett and Vaicys, 2000). In addition, by

facilitating, implementing and reinforcing a ‘global ethical framework’, argues Zipparo (1998) the

right decision can be inferred even if the problem was never anticipated or previously encountered,

and even if there is currently no rule to address that potential issue.

Communication

In the implementation of any ethics and corruption prevention systems, the way the message is

communicated is as important as the message itself. In both the private and public sector, some

organisations are treating ethics education in a similar fashion to running a marketing campaign

(LRN, 2006). As illustrated in the table below, it is important to utilise multiple communications

channels to raise employee awareness and disseminate organisational values, while sending a

consistent message.

21

Figure 4: Examples of creative communications and branding tools for ethics and corruption

prevention programs

Method Description / Purpose

Online training Allows staff to undertake the training at their own pace and time of choosing.

Logos Creates an identity around the ethics program.

Slogans Supports the communication of core values.

E.g. PPL Corporation developed the slogan “Be a L.E.A.D.E.R.” (Let Ethical Awareness Determine Every Response)

Movie references Grabs staff’s attention and offers opportunities for staff to speak freely.

E.g. Temple-Inland uses scenes from the movie “A few good men” to discuss why the two marines did not have the courage to come forward and disobey an order they knew was ethically wrong.

Another company uses the movie “Jaws” and the debate around the closure of the beach, to discuss the merits of sacrificing safety for profits.

Video interviews

Encourages employees to share their experiences (positive and negative) with other employees in the format of a video interview. Particularly useful in conjunction with induction programs for new staff members. It can be shared online.

Board games Allows staff to have fun while tackling complex ethical issues.

E.g. In the late 1990s Lockheed Martin developed a board game called “The Ethics Challenge”, with characters from the comic strip Dilbert.

Staff teams had to compete to find the right answers to various ethical situations.

Source: LRN, 2006

A strong indication of the style of communication will be provided by analysing who the organisation

appoints to run the ethics programs: a compliance system will likely be assigned to a lawyer, or an

employee with a law enforcement background, and the relevant documents will be phrased in legal

terms, clearly stating the sanctions for non-compliance. By contrast, a program based on shared

values will likely involve staff from human resources, marketing and operating backgrounds, and will

be focusing more on abstract core ideals such as respect and responsibility.

22

Behavioural Theories

The analysis of causes of corruption and of its possible controls necessarily leads to discussions on

behavioural psychology and on what affects social norms. Research typically distinguishes between

two types of norms, the injunctive and descriptive norms. For example, Cialdini et al. (1990) state

that, when considering normative influence on behaviour, it is crucial to discriminate between the is

(descriptive) and the ought (injunctive) meaning of social norms because each refers to a separate

source of human motivation. While rules or beliefs as to what constitutes morally approved and

disapproved conduct determine injunctive norms, observations of what other people do form

descriptive norms (Cialdini et al., 1990). This distinction is particularly relevant when analysing

ethical behaviour and the choice paths individuals follow when faced with ethical dilemmas.

On this point, one of the most authoritative voices is James Rest (1986), who describes an

individual’s ethical behaviour as an evolution across four stages: moral awareness, moral judgement,

moral motivation and moral action (see Figure5).

The first stage of the ethical decision making process is moral awareness, or the process by which an

individual recognises that a situation presents a moral problem or that a moral principle can be

applied to the circumstances. Connected to this first stage are considerations on the differences

between individuals’ ethical sensitivity. For instance, research in this field (see for example Sparks

and Hunt, 1998) has found that women tend to have greater skill at identifying ethical issues, and

have highlighted the importance of context, whereby if a situation is more imminent, probable, or

close to the person, it will more likely gain their attention and be identified as an ethical issue.

The second stage is moral judgement, and identifies the reasoning individuals undertake to

formulate moral justifications to their actions and determine choices and consequences. This stage is

typically built on Kohlberg’s (1969) cognitive moral development approach.

Drawing on a summary by Treviño and Weaver (2003), according to Kohlberg ethical reasoning

becomes more sophisticated over time and specifically this ‘evolution’ comprises six stages. At the

lowest stages (pre-conventional level) the individual decides what is right based on fear of

punishment and obedience to authority, or based on an exchange relationship (‘you scratch my

back, I scratch yours’). At the middle two stages (conventional level), moral judgement is influenced

23

by expectations of others, or rules of law. The highest levels (principled) involve autonomous

individuals forming opinions on what is right based on an analysis of principles of justice and rights.

Moral motivation explains an individual’s commitment to take the ‘moral path’, at times almost

subconsciously, “a kind of spontaneous necessity” (Blasi, 2005), a quick, unintentional and automatic

cognitive process (Haidt, 2001) that lets individuals separate between perceived good and bad.

Influences can go back to childhood or adolescence as well as to a repertoire of knowledge built over

a period of time in an organisation.

Finally, moral action or moral courage refers to an individual’s behaviour, their action in the

situation. It describes the courage and determination to follow through with the moral decision

(Lincoln and Holmes, 2011).

Figure 5: Rest’s four stages of moral behaviour (1986)

Though these steps are arranged logically, they are not in a fixed order. Rest (1994) suggested that

each component is distinct and can influence the others. Furthermore, failure at any step can result

in a failure to make an ethical decision. An individual may have strong moral judgment skills but will

not begin to use them if she or he lacks moral sensitivity and fails to recognize a moral issue.

The social psychology theory of moral reasoning, in particular the neo-Kohlbergian theory by Rest et

al. (1999), which emphasise the role of social conventions in shaping morality, have clear practical

implications for organisational management. Research has, in fact, found that most adults are at the

24

Kohlbergian ‘conventional level’, and therefore their opinion of what is right or wrong is largely

influenced by others and by rules and laws.

Further, observations in the workplace (Hollinger and Clark, 1983; Johnston, 1986) have highlighted

how co-workers can significantly influence the behaviour of other employees, regardless of what the

normative framework in place. So, argue Treviño, Weaver and Reynolds (2006), if most adults’

thinking about right and wrong is highly susceptible to external influence, then the management of

such conduct through attention to norms, peer behaviour, leadership, reward systems, climate,

culture and so on becomes particularly important.

The next two sections draw on the literature developed around the impact of social norms in the

context of corruption prevention at organisational level. A large part of the research work in this

field has centred on the negative aspects of social norms and the particular influence individuals can

exercise on others towards unethical behaviour (‘bad apple’ or ‘bad barrel’ theories). In contrast, the

last section offers a different perspective on social norms: a positive view, named “The good apple”,

aimed at converting the traditionally negative perspective on organisational behaviour to a more

optimistic view that ethical role models can become agents of change and promote honesty

amongst their colleagues.

The bad apple

The ‘bad apple’ approach recognises that the behaviour of an individual or a group of individuals in

an organisation can, through a process of social learning (Bandura, 1986) influence others to behave

unethically. If widespread, this behaviour could affect large parts of the organisation, effectively

“legitimising” (Ashfort et al., 2008), normalising and even “institutionalising” corrupt behaviour

(Ashfort and Anand, 2003; Weaver, 2006).

According to Gino et al. (2009) the unethical behaviour of other individuals can influence observers’

behaviour in at least three possible ways:

1. Individuals may change their estimate of the likelihood of being caught cheating (a cost benefit

calculation, supported by witnessing someone getting away with it) (see also Hill and

Kochendorfer, 1969; Michaels and Miethe, 1989)

25

2. Witnessing unethical behaviour might draw an individual’s attention to his or her moral

standards (Mazar et al, 2008), and interrupt the otherwise tendency of people to categorise

their own unethical actions in positive terms (Baumeister, 1998; Schweitzer and Hsee, 2002)

3. Individuals might change their understanding of social norms related to dishonesty (see also

Cialdini and Trost, 1998).

Viewing corruption as the behaviour of one individual, the ‘bad apple’, or a small faction in an

organisation, probably reflects people’s preference for attributing causes for outcomes to a

particular individual or a small group (Nisbett and Ross, 1980; Zimbardo, 2004) and for preferring

focused diagnoses that suggest the possibility of a quick fix. By concentrating on the micro-level (the

bad apple) researchers and practitioners tend to attempt to predict corrupt behaviour by identifying

demographic characteristics (for example, the notion that the typical offender is a middle-aged

white male, see Wheeler et al., 1988), psychological predispositions, such as lack of moral identity

(Aquino and Reed, 2002) or self-control (Marcus and Schuler, 2004) or medically diagnosable

psychological pathologies (Babiak and Hare, 2006).

Interesting implications of this theory can be identified in group dynamics, based on whether or not

the individual (the ‘bad apple’) is part of the group. On the basis of social identity theory (Cialdini et

al., 1990), when an in-group member is observed engaging in unethical behaviour, other group

members may make him or her the standard for the descriptive norm, and as a result engage in

increased unethical behaviour themselves. In contrast, when an out-group member engages in

unethical behaviour, the injunctive norm is likely to be salient, and non-group members may want to

distance themselves from the “bad apple” (Brewer, 1993; Tajfel and Turner, 1986). This theory was

supported through a large scale survey of Australian citizens in 2004, which found that the presence

of social norms elicited consistent behaviour, but only when respondents identified with the group

to which the norms were attributed (Wenzel, 2004).

Bad barrels

Another view on the influence of social norms on individuals’ behaviour is the one of the ‘bad

barrels’. The theory argues that organisational cultures evolve norms that guide employee practice

and behaviour (Ashfort et al., 2008). Further, when group concerns are made prominent and

noticeable, people align their personal views with group consensus (Ledgerwood et al., 2010), and

group-based morals may encourage individuals to condone corruption. In addition, people can

rationalise and justify immoral deeds committed by individuals in their group (Valdesolo and De

26

Steno, 2007), therefore normalising and even “institutionalising” corrupt behaviour (Ashfort and

Anand, 2003; Weaver, 2006). According to Stryker (1980) explicit and implicit behavioural

expectations of others can reinforce some individuals’ self-concepts, and so can attitudes and

behaviour of organisational peers and leaders, effectively building assumptions about “who we are”.

Crawshaw et al. (2013) note that as social beings we often struggle individually and culturally with

the problem of the fundamental tension between self-interest and belonging, between being the

same as others and being unique, and with coordinating and responding to the same interests and

motives in others (Brewer, 1991; Fiske, 1991), further confirming the likelihood of strong external

influences in any environment.

Moreover, the concept of ‘bad barrel’ can be related to situational context. Psychologist Philip

Zimbardo, known for the famous 1971 Stanford Prison Experiment1, argues (2006) that negative

behavioural influences are accentuated by external factors such as isolation or limited reference

groups. The implications are particularly strong for new employees in an organisation: Ashforth and

Anand (2003) refer to “initial co-optation of newcomers” to describe the negative process of

influence on new staff members leading to changes in attitudes and ultimately to unethical

behaviour.

The good apple: theory of ethical role model

Substantial evidence indicates that social norms guide human action in direct and meaningful ways

(Cialdini, Kallgren and Reno 1991; Terry and Hogg 2001). The effect is particularly noticeable in the

workplace, where the attitudes and behaviours of peers clearly affect individuals’ ethical behaviour

(Zery-Ferrell and Ferrell, 1982).

While the literature around ‘bad apple’ and ‘bad barrel’ theories (see Ashfort and Anand, 2003;

Weaver, 2006; Ledgerwood et al., 2010) offer a decisively negative view of social norms, other

researchers have concentrated on the positive drivers of human behaviour.

1 The Stanford Prison Experiment (SPE) was conducted at Stanford University between 14-20 August 1971, by a team of

researchers led by psychology professor Philip Zimbardo. Twenty-four male students were selected to take on randomly assigned roles of prisoners and guards in a mock prison situated in the basement of the Stanford psychology building. The participants adapted to their roles well beyond Zimbardo’s expectations, as the guards enforced authoritarian measures and ultimately subjected some of the prisoners to psychological torture. The entire experiment was abruptly stopped after only six days, and it is regularly cited to illustrate theories of power of authority, situational attribution of behaviour and cognitive dissonance theories.

27

Gneezy (2005), for example, argues that individuals have a preference for truthfulness; Vanberg

(2008) shows that people exhibit preferences for promise-keeping; while Paulhus (1984) identifies a

motivation amongst individuals to impress others or to live up to expectations. This research,

however, aims at identifying whether honesty and ethical behaviour can be ‘transmitted’ through

conscious or unconscious social and organisational mechanisms.

Ethical leadership

In today’s climate of high-profile business scandals, research and public opinion place great

importance on the role top executives play in setting the ethical tone of their organisation (see

Weaver et al., 2005). The ICAC (2001) and other Australian oversight agencies (see for example

Queensland’s Crime and Misconduct Commission, 2005) repeatedly remind organisational leaders

about the importance of the “tone from the top”, and a line of theory has developed around the

concept of ethical leadership.

Brown et al. (2005: 120) defined ethical leadership as “the demonstration of normatively

appropriate conduct through personal actions and interpersonal relationships, and the promotion of

such conduct to followers through two-way communication, reinforcement, and decision-making”.

The proposition is that ethical leaders influence ethical behaviour in others predominantly through

social learning (Bandura, 1986). Employees watch the leaders and the ethical standards they set (or

fail to set) and follow them, partly because leaders are figures of authority, but also because of social

norms of reciprocity (Blau, 1964). If a leader displays supportive behaviour to his or her followers,

the followers should wish to reciprocate the leader’s supportive treatment (Treviño & Brown, 2004)

with ethical behaviour. This, in turn, is associated with the followers’ willingness to report ‘bad news’

to management, as well as their dedication and satisfaction on the job (Brown et al., 2005).

However, the assumptions on ethical leadership have been called to question. The main argument

presented by critics of the ethical leadership theory is centred on observations that the influence of

peers on an individual in the workplace is strictly connected to the frequency and intensity of

interaction between the parties (see for example Zery-Ferrell and Ferrell, 1982). Therefore it can be

argued that employees are influenced most by those closest to them, the people they work with

every day, as opposed to their leaders. CEOs and top executive, add Weaver et al. (2005), are often

“faraway figures”, and while they might be promoting ethical behaviour, most employees will not

see if their actions match their verbal message. In addition, contact with executives is usually more

formalised and more mediated, and often employees have a cynical view of top management. It is

28

therefore important that management focus on the positive ethical impact that one employee can

have on another at an operational, day-to-day level.

Ethical role models

The theory of observational learning (Bandura, 1977) has been researched extensively with children

and adults alike, and even with animals (see for example Zimmerman and Rosenthal, 1974; Bova and

Phillips, 1984; Fiorito and Scotto, 1992; Heyes, 1994), confirming that individuals learn much of what

they know not through direct experience, but by observing the behaviour of others. At a

conventional level of moral reasoning individuals look to others for ethical guidance, and modelling

is a well-documented means of transmitting values, attitudes and behaviours (Brown and Treviño,

2014). In relation to ethics in the workplace, despite organizations’ efforts to highlight the

executive’s stance on conduct and behavioural principles, the role models people look up to tend to

be among those with whom they have close working relationships (see Walker et al., 1995).

Research on role modelling has found that employees tend to learn from both positive (learn what

to do) and negative (learn what not to do) role models (Gibson, 2003). Not to be confused with

mentoring, typically an intentional relationship, modelling is informal and often hidden, as the

person being observed might not be aware of others viewing them as role models (Weaver et al.,

2005). It is an informal mechanism that operates below the organisational radar screen, with ethical

role models usually on the organisation’s front lines, interacting with employees on a regular basis.

So while ethical leadership can be a top-down phenomenon, ethical role modelling appears to be

much more a “side-by-side” phenomenon (Weaver et al., 2005).

When it comes to the characteristics of typical ethical role models, research identifies common traits

such as showing care and concern for people, treating people respectfully and fairly, working hard

alongside others, communicating well with others, and showing support and defending people (see

for example Weaver et al., 2005). It can be defined, in essence, a combination of particular personal

characteristics (such as honesty, consistency, humility) and interpersonal behaviour (such as care

and support), mixed with a propensity to promote fairness and the capacity to articulate ethical

standards.

Some researchers (see Godin, 2002) have compared the phenomenon of how some individuals can

spread change within an organisation to the way in which a virus spreads. Instrumental to this

process are the ‘influencers’, those who can push other people to change their behaviour. Labelled

29

‘sneezers’ in some literature, they are the ones who are believed when they tell other people about

something (Collins et al., 2003). Every organisation has some: they are very skilled socially and good

at absorbing information and news.

As acknowledged by Brown and Treviño (2014: 591), within a work organisation role modelling is

particularly important for newcomers, as “younger employees look to models for clues on fitting in,

doing well and moving up”, but the principle applies to employees of all ages. For example, argues

Gibson (2003), middle aged employees can learn from role models on how to deal with new

responsibilities or challenges, and how to advance in their career.

A qualitative study conducted in 2005 by Weaver et al., attempted to map out the range of

behaviours and characteristics that are relevant to individuals identified as ethical role models.

Patterns in responses underlined that ethical role models demonstrated specific personal and

interpersonal qualities, integrity and respect towards others, and clear vision in relation to ethical

standards (Weaver et al., 2005). These qualities are summarised in Figure 6 below.

Figure 6: Characteristics of ethical role models

Source: Weaver et al. (2005)

Interpersonal qualities • Caring - Altruistic - Supportive

• Take responsibility - Hardworking

• Trustworthy - Personable

• Accentuate the positives

• Accept others’ failures (accept “bad news”)

• Helpful

• Humble

Personal qualities • Have high ethical expectations for

themselves (walk the talk)

• Consistent in decision making, but also between their public and private lives

• Integrity

• Honesty

• Self-sacrifice

Fairness with others • Fairness

• Respectful

• Explaining decisions

• Open to input

Ethical standards in practice • Expect ethical standards from people

who work with or for them

• Consistent ethical vision - Long-term perspective

• Communicates ethical standards

• Put ethics above personal/group interests

Frequent interaction

Widely respected within the organisation

30

According to the study, particular emphasis was placed on the ethical role model’s relationship with

others, their work attitude, the standards they set for themselves and others, and their consistent

behaviour in both private and public life (Weaver et al., 2005). Most importantly, these qualities

were underpinned by contextual factors, such as the frequent personal interaction with others, and

the fact that other people within the workforce already showed respect for the individual.

Implications for practice

A practical question arises from the analysis of the theories on modelling: can ethical role models be

identified and developed? Collins et al. (2003) argue any organisation, including governments, in

order to successfully implement change programs, should aim to identify and engage with these

protagonists. However, ethical role models are usually looked up to in part because they are humble

(Weaver et al., 2005). Organisations that are serious about fostering ethical behaviour may therefore

find it hard to identify who the ethical models are in their workforce. Weaver et al. (2005: 326) argue

organisations might be facing a paradox: “ethical role modelling seems important as a positive

influence on people, but some people do not want to adopt that role self-consciously”.

Organisations will therefore need to invent innovative ways of identifying these very influential

individuals. For example Brown and Treviño (2014) suggest use of evaluation programs (such as a

360 degree) and Weaver et al. (2005) recommend asking peers and subordinates to identify people

who have played an ethical role in their work life.

Further, recognising the behaviour of ethical role models seems an equally sensitive matter. Brekke

et al. (2002) argue that for morally identified people harmony is achieved by doing what they believe

to be right, and providing compensation or other incentives to act morally undermines that identity-

based sense of purity of motive. Some solutions involve “quietly praising” the employees “with a

letter in their files that is used to make selection/progression decisions, but is not shared publicly”

(Weaver et al., 2005: 326). Others (see Brown and Treviño, 2014: 596) suggest emphasising the

importance of their role, “without compromising their humble nature”. Models advocating for a

more ‘obvious’ recognition of ethical role models might be supported by research on the theory of

conformism. The theory is based on neo-Kohlbergian concepts by Rest et al. (1999), which

emphasise the role of social conventions in shaping morality. In particular, the research in this field,

based on reporting honesty, has identified that individuals tend to display a psychometrically-

assessed desire to conform to social norms, an “internal motivation to conform” (see Hannan et al.,

2006; Maas and van Rinsum, 2013; Huddart and Qu, 2014). According to the theory of conformism,

social pressure arises when one’s reporting behaviour is observable by others. Therefore, making

31

reporting decisions observable to others creates social pressures to conform, which indicates that

honesty is more likely to be driven by motivations to conform to social norms rather than by an

innate personal preference. This was confirmed by Huddart and Qu in 2014, with their test results

showing an increase in ‘honesty’ of approximately 19% compared to the control group when the

agent knew his behaviour could be shared publicly.

Brown and Treviño’s (2014) position about emphasising the contribution of role models within an

organisation could therefore be supported by the theory of conformism. Advertising the role

models’ ethical behaviour could lead to increases in honesty, in turn leading to more ethical

behaviour, more reporting and so on, effectively building a virtuous cycle that creates and supports

‘agents of change’ (Barr and Serra, 2008).

For decades, the private sector has applied insights from behavioural science, in fields such as

marketing and advertising, with ‘customer experience’ being placed at the forefront of service

design and business decisions by telecommunications, financial, insurance, health and hospitality

companies alike (see for example Chase and Dasu, 2001; McKinsey&Company, 2010). Governments

lagged behind the private sector in harnessing the potential of behavioural science, leading some

researchers to argue that government policy was still being developed “on the back of an

anachronistic understanding of how behaviour is influenced and what makes people change” and to

suggest “new thinking” to “move beyond the current limited policy approach” (Lewis, 2007). More

recently, however, advancements in the field of applied behavioural science in the public sector

have been promoted by the UK Government, with the introduction in 2010 of a Behavioural Insights

Team, also called the “nudge unit”, tasked with the review of some of the country’s most ‘prickly’

issues, such as unemployment, taxation and health (New York Times, 2014; Financial Times, 2014).

The promising results achieved in the UK prompted other governments to “import” this model. One

of the first international partnerships was with the NSW Government, where since 2013 Behavioural

Insights have been working alongside the Department of Premier & Cabinet tackling issues such as

payment of fines, health insurance and return to work (see NSW Government, 2015; Sydney

Morning Herald, 2014; The Mandarin, 2014). The United States followed suit in January 2014, when

the White House set up a Social and Behavioral Sciences Team to advise the Obama administration

on policy formulation (see The Psych Report, 2014).

32

The relevance of behavioural theories in the quest of corruption prevention has been recognised by

the World Bank in their annual landmark publication, the World Development Report 2015, where

the view of corruption as a social norm is promoted. Blaming such social element for the persistence

of the corruption problem worldwide, the Bank calls for innovative behavioural-based solutions to

challenge long-held mental models (World Bank, 2015: 2). Citing successful stories of innovative

solutions involving elements of social marketing and advertising, the World Bank refers to processes

involving a “mental revolution” (Economist, 2010) and cooperative behaviour (Ostrom, 2000) to

“emphasise the social norm of clean government” (World Bank, 2015: 2).

At local government level a similar initiative was recently launched by former New York City Mayor

and philanthropist Michael Bloomberg, named ‘What Works Cities’ (see Bloomberg Philanthropies,

2015; CNN, 2015). As part of this program, Bloomberg has made US$42 million available to help 100

midsize U.S. cities deliver better services and become more transparent, leveraging also on the

application of behavioural analysis and research. This approach led to cost effective interventions in

the delivery of public services informed by behavioural insights in areas such as health, to reduce

childhood obesity and help smokers quit, employment, to help job seekers find employment sooner,

and energy, to help citizens reduce their household consumption levels.

Overall, however, initiatives such as ‘What Works Cities’ remain isolated exceptions at local

government level, both in Australia and around the world. Nevertheless, behavioural applications, in

particular in the field of corruption prevention, could greatly improve outcomes of public policy for

councils: the frontline delivery of programs and the direct exposure to service clients make the

sector a particularly fertile ground for trialling behavioural-based solutions.

Corruption Prevention: the case of NSW Local Government

Over the last two decades corruption prevention in the Australian local government sector has been

the focus of increased attention. It has triggered the creation of policies, codes and agencies, and

remains a hot topic of discussion amongst the public and the media (see for example ABC News,

2001; Sydney Morning Herald, 2011; Government News, 2012; Crikey, 2008; Yahoo!News, 2015).

Since the creation of the Independent Commission Against Corruption (ICAC) in New South Wales in

1989, followed by similar corruption watchdog organisations in Queensland (Crime and Corruption

Commission, 2001), Western Australia (Corruption and Crime Commission, 2003), Tasmania

(Integrity commission, 2009), Victoria (Independent Broad-based Anti-corruption Commission, 2012)

33

and South Australia (Independent Commission Against Corruption, 2012) it quickly became apparent

that local government would be one of the main targets of investigations and inquiries into corrupt

conduct in the public service. This trend is particularly clear in NSW, with publicly reported

investigations by the ICAC into local government accounting for approximately a quarter of the total

activities for the Commission since 1989 (ICAC, 2015), as shown in Figure 7.

Figure 7: ICAC public investigations 1989-2014

Source: ICAC, 2015. Author’s calculations.

In addition, it is noted that 80% of all public investigations or inquiries into LG culminated with

findings of corrupt behaviour and 68% resulted in referral to the Office of the Director of Public

Prosecutions (DPP) for further action.

An even more polarised view is obtained when analysing the number of complaints made by the

public to the ICAC under Section 10 of the ICAC Act, about matters that concern or may concern

corrupt conduct as defined in the ICAC Act. Complaints about local government consistently account

for over 40% of the reports received annually by the ICAC (ICAC, 2014), as shown in Figure 8.

25%

15%

17%

6%

5%

10%

14%

8%

Local Government

Law and Justice

Government and FinancialservicesCommunity and humanservicesHealth

34

Figure 8 – Public complaints in the top five government sectors

Source: ICAC Annual Reports, 2008-2014. Author’s calculations.

The ICAC (2014) notes, however, that the apparent over-representation of Local Government in

complaints statistics is partly due to the fact that there are over 150 councils in NSW, and that many

people take a personal interest in the decisions of their local council. For most, argued former ICAC

Commissioner Irene Moss (2001), “dealing with councils is certainly their most significant contact

with the public sector”. Nevertheless, or in fact because of the high level of public involvement and

interaction with councils, it is essential that local government aim at operating in the most effective,

efficient and corruption-resistant way possible.

Building an internal framework to prevent, assess and investigate conduct issues raised by the public

becomes even more relevant when analysing the capacity of external oversight agencies to manage

the large volume of complaints they receive each year. The NSW ICAC (2014: 25), in their Annual

Report 2013/14, notes that “only a small number of matters with the potential to expose significant

or systemic corrupt conduct will meet the criteria for a full investigation”. In 2013/14 the

Commission only investigated 2% (43) of all matters assessed, with the majority (84%) closed

without referral or referred internally but not investigated (7%) (ICAC, 2014). Importantly, however,

7% of matters were referred externally or back to the relevant agencies to investigate (ICAC, 2014).

Admittedly then, there might be situations where misconduct is embedded in the culture of the local

35

authority and a “powerful external motivator” is required (Doig and Skelcher, 2001a: 104). However,

it is equally important for organisations to develop a strong self-regulation capacity, to be able to

handle specific matters internally.

In attempting to build internal capacity though, NSW councils appear to rely on solutions of

managerial nature, such as the development of Codes of Conduct and policies. The effectiveness of

such approach was questioned by an ICAC study conducted over 2000-2001 with a large number of

NSW councils, which revealed that all councils surveyed had a Code of Conduct in place, but one in

10 staff did not know whether or not their council had one, half reported that they never refer to

their council’s Code of Conduct, and nearly half did not know that their Code of Conduct applied to

councillors as well as staff (ICAC, 2001). The study (ICAC, 2001) seriously questioned the

effectiveness of Codes of conduct as a stand-alone solution for councils, without the promotion of

an organisational culture founded on ethics.

Empirical analysis

Based on the preliminary findings from the literature review and the data analysis presented in

previous sections, an empirical research was devised around two main hypotheses concerning the

effectiveness of compliance-based controls and behavioural solutions in tackling corruption at a

Local Government level. These hypotheses are then tested on a selected sample of NSW councils.

Hypotheses

H1: Hypothesis 1

The Councils subject to public inquiry by the NSW Independent Commission Against Corruption in the

past 15 years had in place a Code of Conduct or similar policies regulating the behaviour of their staff

at the time of the inquiry.

Government organisations are expected to comply with requirements in relation to development of

Codes of Conduct and similar policies to guide the behaviour of their employees. The presence of

such documents is seen by many as essential in the promotion of ethical behaviour in the workplace

and in the prevention of misconduct. However, the extent to which these frameworks are effective

in the prevention of corrupt conduct remains unclear. The aim of this hypothesis is to assess such

assumption in a quantitative manner. The relationship between instances of inquiries by the NSW

36

ICAC into local governments and the presence of Code of Conduct or related policies in the same

councils can be considered a good proxy for the purpose of this study.

H2: Hypothesis 2

Honesty is contagious, and organisations can promote honesty and ethics through a process of

positive behavioural influence.

An increasing number of theories place importance on understanding why human beings behave the

way they do. Of particular relevance is the finding that most adults fall within the Kohlbergian

‘conventional level’ of moral development, and therefore their opinion of what is right or wrong is

largely influenced by others and by social norms (Rest et al., 1999; Treviño et al., 2006), and that in

the workplace co-workers can significantly influence the behaviour of other employees, regardless

of the normative framework in place (Hollinger and Clark 1983; Johnston 1986). In addition, recent

tests conducted on the theory of conformism identified that social pressure towards honesty

increases when one’s behaviour is observable by others (see Huddart and Qu, 2014; Maas and van

Rinsum, 2013; Hannan et al., 2006).

As some of these studies suggest, corruption and misconduct might be considered as social and

behavioural issues (see for example Cialdini et al.,1990; Hollinger and Clark 1983; Johnston 1986;

Gneezy, 2005; Vanberg, 2008; Paulhus, 1984). As such, solutions leveraging findings around moral

development and social norms could be more successful and cost effective at preventing corruption

in the workplace. This theory will be tested through analysis of a selected sample of NSW councils

who are currently implementing training programs built around ethics and organisational culture.

The analysis of these programs will include a reference to the theories of social conventions and

behavioural influencers, with particular emphasis on the theories of conformism and ethical role

modelling.

Methodology

The research concentrates on Council staff and management, purposely postponing the analysis of

corruption prevention efforts at political level to a future research paper. Two distinct groups of

NSW councils were selected for the analysis of the two research hypotheses.

37

Test Group 1

The first test group was identified through analysis of all public inquiries into local government

conducted by the ICAC in the past 15 years, filtering for cases that only involved public officers (see

Appendix 3). Four organisations were selected, that were subject of an ICAC inquiry approximately

fifteen, ten and five years ago. The corrupt conduct investigated by the ICAC in the cases selected

ranged from soliciting bribes in return for favourable regulatory certification, to favouring

contractors in return for payments and gifts and accepting bribes to facilitate development

approvals.

Test Group 2

In selecting councils for the second test group, an effort was made to identify organisations who are

currently implementing training programs built around ethics and organisational culture. In

addition, it was considered important that the councils within this test group had not been subject

to an ICAC public inquiry directed at their employees or management in the last ten years (ICAC,

2015). It was not possible, however, to assess whether these councils, while not subject to a public

inquiry, had been investigated by ICAC on the grounds of corrupt conduct during the same period.

The details of most investigations carried out by the ICAC are in fact covered by confidentiality, and

special exemptions of the Government Information Public Access (GIPA) Act apply to the

Commission in relation to such information. Additional criteria were applied in the selection of

councils for the second test, to further narrow the group based on good financial sustainability and

consistent attention to efficient resource management and governance (see Appendix 4). These

included a Moderate/Sound financial status under the 2013 NSW Treasury Corporation Report into

the financial sustainability of NSW Local Government and the council having previously undertaken

the Office of Local Government’s Promoting Better Practice Review (OLG, 2015). In total five councils

were identified for this test group.

Consideration was given to analysing the same councils for both tests, under a “before and after”

approach, essentially to identify whether specific control tools failed and were subsequently

replaced by others, and to what level of satisfaction. However, this option was ruled out: it is, in fact,

believed the research will benefit in clarity by testing on one hand the effectiveness of compliance-

based systems on councils that experienced an ICAC inquiry, and on the other hand the

implementation of values-based systems by councils who spontaneously determined such

management approach, as opposed to being “pressured” to do so as a reaction to an inquiry

38

highlighting failures. While the initial intention to conduct extensive testing across a sample of NSW

councils was not pursued due to time and logistical restrictions, the research includes aspects of

promotion of ethics, identification of ethical role models and methods of praise and support for

ethical employees.

On a last note, it is important to highlight that given the sensitive topic of this research and the

expected reluctance of Local Government organisations about discussing corrupt conduct within

their workforce, careful consideration was given to the scope and confidentiality of the study.

Specific mitigating measures were introduced in the research, in order to gain ethics approval (see

Appendix 7).

Data

In early May 2015 the General Managers of the councils selected for the study were sent an email

requesting to participate in the research. The email contained an introduction to the researcher and

the topic of analysis (see Appendix 1 and 2), as well as a questionnaire.

Two different questionnaires were developed for the study (see Appendix 5 and 6). The first one,

forwarded to councils in Test Group 1, included questions aimed at testing whether at the time of

the public inquiry the organisation had in place a Code of Conduct or similar policies regulating the

behaviour of their staff, and whether the employees had been trained on the content of such

policies in the two years prior to the intervention by the ICAC. The second, sent to councils in Test

Group 2, included questions about the organisation’s values system, the promotion of ethics, the

identification of ethical role models and the methods utilised by the organisation to praise and

support these employees.

For both groups, the introductory information included a suggestion that the questionnaire could be

undertaken as a face-to-face interview to be conducted by the researcher. None of the participating

councils chose the interview method, opting instead to complete the questionnaire and provide the

responses to the researcher via email.

39

Results

Test Group 1

Of the four councils approached to test Hypothesis 1, three responded to the questionnaire. One

council declined to participate claiming it would be impractical for the organisation to retrieve

records relating to the ICAC inquiry subject of the questionnaire, which occurred in the late 1990’s.

The responses provided are summarised in the chart below:

Question 1

At the time of the ICAC inquiry affecting your Council, did your organisation have in place a Code of Conduct or similar policies regulating the behaviour of their staff?

Council 1 Council 2 Council 3

Yes

Code of Conduct

Internal Reporting Policy

Yes

Code of Conduct

Gifts and Benefits policy

Others

Yes

Code of Conduct

Conflict of Interest

Gifts and Benefits policy

Public Disclosure policy

Question 2

In the two years prior to the ICAC inquiry affecting your council, did your organisation promote a program of training for staff on Code of Conduct or similar policies?

Council 1 Council 2 Council 3

No Yes

Face to face training for all staff every 2 years

At induction for all new staff

Yes

Question 3

Following the ICAC inquiry, did your organisation change its policies and/or its programs on Code of Conduct?

Council 1 Council 2 Council 3

Yes

Gifts and Benefits Policy Yes

Code of Conduct training at Induction

Code of Conduct undertaken by external trainers for all staff on 2 yearly basis

Tool box Talks for contractors

ICAC training for managers and supervisors regarding corruption controls

Introduction of Audit and Risk Committee

Employment of Procurement Coordinator

Yes

Code of Ethics

Conflict of Interest

Gifts and Benefits

Secondary Employment

Hospitality policies

Yes

Online learning program

Face to face training every 2 years Targeted training for key risk areas

Yes

New Corruption Prevention Policy

Revised Public Interest Disclosure Policy

Revised Code of Conduct

Recommended Supplier Policy

Paid Overtime Policy

Confidential Information Policy

Reviewed financial approval process

Yes

More frequent training on Code of Conduct

40

The responses provided show that all three councils analysed had in place a Code of Conduct and a

range of additional policies aimed at guiding employees’ behaviour. Two councils had provided

training in the two years immediately prior to the ICAC inquiry, while the third one had done so

previously. When analysing the post-inquiry decisions, it appears all three councils opted for

additional compliance-based controls, such as the development of more policies and the

introduction of monitoring entities, such as Audit Committee or Procurement Coordinator, as well as

reinforced training on Code of Conduct. None of the three councils decided to implement an ethics-

based or values-based cultural program, with the limited exception of Council 2 that addressed the

ethical needs by developing a Code of Ethics, still considered to be a policy-focussed solution.

Test Group 2

Of the five councils approached to test Hypothesis 2, three responded to the questionnaire.

The other two councils did not respond nor declined participation. Following two courtesy

reminders, these councils were removed from the analysis. The responses provided are summarised

in the table below:

41

Question Council 1 Council 2 Council 3

Does your Council have a set of corporate values?

Yes Respect – Integrity – Teamwork – Excellence - Responsibility

Yes Respect – Integrity – Teamwork – Sustainability - Service Values developed by Council staff.

Yes Motivated – Growing –Achieving – Winning – Important

Would you consider your Council a values-driven organisation?

Yes Yes Yes

How are the corporate values implemented within the organisation?

Employees need to demonstrate they adhere to the corporate values in their annual development and performance plans.

Values and ethics are incorporated in position descriptions as an essential competency and are a core element of staff’s performance appraisals. Values are printed and placed throughout Council’s premises.

Induction, dedicated organisational culture program and annual performance assessment process.

Do you provide training on corruption and fraud prevention and Code of Conduct training to staff? If so, please specify frequency.

Yes. Monthly training programs for new staff. Ongoing mandatory training based on Organisational integrity and ethical leadership; Code of Conduct; Workplace Bullying; Fraud and Corruption prevention

Yes. Training for new staff every 90 days. 3-year training cycle for all staff. Training includes Code of Conduct and fraud and corruption prevention.

Yes. Code of Conduct training is provided via presentation and electronic assessment modules.

Is ethical behaviour promoted in the organisation?

Yes Yes Yes

What methods do you use to promote ethics?

Training. Ethical behaviour is embedded in all working practices through promotion of greater accountability and responsibility and inclusion of ethical behaviour (lack of) as one of Council’s strategic risks.

Team meetings, staff information sessions, email updates from the General Manager, staff newsletter, promotion of values. A values award system has been in place for 3 years. Staff are encouraged to nominate colleagues that exemplify the organisational values. Nominations are selected by a committee, and recognised/celebrated on a monthly, quarterly and annual basis.

Corporate culture program, corporate values and integrated into core training modules

Do you include ethics in the Annual Report and in your Integrated Planning and Reporting documents?

Ethical issues and conduct are addressed in a separate annual report which is made available to the public.

Council’s values are reflected in annual report and IPR documents. A specific goal in the Delivery Program relates to achieving a ‘socially responsible and ethical governance’.

Yes

42

The goals are implemented through a number of projects and reported on through quarterly updates.

Do you include ethics in induction material for new staff and in leadership/management courses?

Council runs a specific leadership program which covers, amongst others, issues of integrity, trust and accountability.

The induction program features a session on workplace ethics and organisational values.

Yes

Do you have a dedicated hotline or email for people to report misconduct anonymously?

Council has a complaint hotline and an online complaint form. Anonymous complaints are discouraged, unless they relate to Code of Conduct or are categorised as a Public Interest Disclosure, as they don’t allow further contact or progress reports.

Complaints are received by Customer Service and referred to Council’s Complaints Coordinator (Public Officer). Council is currently considering the introduction of a hotline and anonymous email address.

No hotline. Anonymous complaints are investigated where enough information is provided.

Do you recognise/reward ethical behaviour amongst staff? How?

Each year staff are required to demonstrate how they have adhered to Council’s values. In particular, for the value of ‘Integrity’, Council seeks to ensure that all employees ‘meet’, ‘exceed’ it or are a ‘role model’. Council operates a continuous improvement initiative, where staff are encouraged to recommend and implement improvements to their own processes to improve quality or reduce waste. A recommendation has recently been made that the initiative includes ethics and corruption prevention.

Through a values awards/recognition program. See Q6.

Through recognition award program and annual performance assessment.

Do you have ethics “champions” within the organisation and would staff know who they are?

No. Council considers all Group Managers in the Leadership Group should be ethical role models to staff in their respective divisions.

No. Yes. Governance Manager and Legal Manager.

43

Do you believe staff would seek advice from their “champion” colleagues?

Yes. This concept is currently being discussed. N/A Yes.

Do you take action against unethical behaviour and are these actions communicated to staff?

Yes, action is taken dependent on the seriousness and severity of the behaviour. Expected standards of behaviour are outlined in the Code of Conduct and communicated to staff through training.

Yes, Council investigates complaints and unethical behaviour in accordance with its Code of Conduct. Examples of unethical behaviour are captured within Council’s Code of Conduct training.

Yes, appropriate action is taken. Consequences of inappropriate behaviour are outlined as part of the training.

Why are implementing these strategies?

To ensure that Council maintains the highest level of integrity and to ensure that Council’s dealings with the community are fair, transparent and accountable.

N/A To reduce and/or eliminate unethical behaviour.

Have these measures been successful in your opinion? How?

Yes. The activity of a specialised office within the Council has been instrumental in the success, and the effectiveness of these measures is reported annually through an annual report which is made available publicly.

There is no quantitative data to confirm if the measures have been successful. However, Code of Conduct training has generated increased awareness amongst staff of their obligations.

Yes. High level of staff awareness in expectations regarding appropriate workplace behaviour, achieved through communication and training.

In summary, in your professional opinion, what strategy is more effective in building an ethical and honest organisation: a compliance driven system or an organisational culture system? Or both? Or neither? Why?

Both. Compliance-based and values-based initiatives are equally important in developing organisational integrity and it’s important to bring all aspects together in an integrated and systematic manner. The tone at the top is an essential ingredient of an ethical culture, but ethical leadership must be promoted and adhered to throughout the organisation. Ethics and integrity should be factored into every aspect of Council business, with all stakeholders recognising their place in ensuring organisational excellence.

Both. In an ethical and honest organisation both strategies work together. A compliance driven system is a more top-down approach while an organisational culture system encourages positive behaviour from within. In addition, the Local Government Act guides many of Council’s actions and sets an ethical framework by which Local Government must abide. At our Council our organisational values create a shared expectation amongst staff.

Both. Governance and compliance systems are both necessary in building an ethical and honest organisation because one provides system/process checks while the other provides culture norms that drive desired behaviour.

44

All three participating councils clearly described their organisation as values-driven, and stressed

that the values were developed by the staff. Importantly, all three organisations chose to embed the

values by incorporating them in the employees’ position descriptions and annual performance plans.

Formal training on Code of Conduct and other policies follows a consistent approach across the

three councils, with initial training provided to all new employees within 1-3 months of starting with

the organisation, and ongoing staff refresher training conducted on a 1-3 years cycle, depending on

the size of the workforce. One council highlighted the use of electronic training and assessment

modules as an additional means to reach staff more frequently.

In relation to the promotion of ethics in the workplace, the responses provided insight into two

different approaches available to Local Government. Council 1 emphasized the importance of

ethical behaviour, or lack thereof, by identifying it as a strategic corporate risk, therefore integrating

it in all working practices. Councils 2 and 3 on the other hand focussed more on cultural programs,

promoting values and recognising employees who exemplify such values through regular

celebrations/awards throughout the year. Values awards and individual performance appraisals are

the closest the councils come to actively promoting ethical behaviour, but when asked about the

presence of “ethics champions” within the organisation, one council responded negatively, while the

other two claimed either that all Group managers should be role models to their division or that

specific senior managers (Legal manager and Governance Manager) fulfil this role.

The three councils are confident that action is being taken to address unethical behaviour, but none

directly inform staff about the issues or about disciplinary or structural actions taken. Instead, all

three organisations claim that expected standards of behaviour, examples of misconduct and their

consequences are all incorporated in the Code of Conduct training program. On balance, while they

admit it might be hard to quantify success with the cultural and values-based initiatives

implemented in the organisation, all councils have confirmed an overall higher level of staff

awareness in relation to expected behaviour and obligations.

Finally, councils were asked to provide an opinion on which control system they believed was more

effective: a compliance driven system or an organisational culture system. All three organisations

responded “both systems are equally important in developing organisational integrity” and they

should be promoted together in an “integrated and systematic manner”. They acknowledge

compliance driven systems are a “more top-down approach” while an organisational culture system

45

“encourages positive behaviour from within”. One council in particular (Council 1) admits “the tone

at the top is an essential ingredient of an ethical culture, but ethical leadership must be promoted

and adhered to throughout the organisation” and highlights that all stakeholders should be

“recognising their place in ensuring organisational excellence”.

Discussion

The research conducted on the sample of NSW councils identified that the mere development and

implementation of a Code of Conduct did not prevent episodes of corrupt conduct amongst their

employees. Overall, this finding is congruent with extensive research on conduct and ethics

programs that suggests merely establishing and enforcing “the rules” is not an optimal solution for

any organisation (see for example Weaver and Treviño, 1999; Paine, 1994; Treviño et al., in press).

As described by Larmour and Wolanin (2001), the main failing of a system based solely on

managerial/bureaucratic solutions is that it does not take into account the people, their characters

and their complexities. In a nutshell, argue the authors, “whatever regime of rules is established, it

can be subverted” (2001: 18).

However, all participating councils believed that values and compliance orientations need not be

mutually exclusive. For example, a strong values-based ethics program can coexist with some

amount of rules, accountability and disciplinary mechanisms (Treviño, 1990; Weaver et al., 1999)

While a compliance orientation “will do little to generate moral imagination or commitment” (Paine,

1994: 111) it may generate behavioural conformity, and that could be considered a good initial step

in a corruption prevention framework. Therefore, the suggestion from this study is that the

differentiating factor in the success of a program is not just about having a code, nor simply what’s

in the code, but how the organisation leverages it to shape its ethical culture.

In most workplaces, there seems to be general recognition of basic behavioural drivers, such as

‘leading by example’ or ‘the bad apple’ theory. Yet, management often fails to harness the full

potential that behavioural science could contribute to a system of control. The point is confirmed by

the findings from this research. The councils reviewed are believed to be amongst the most

innovative and progressive in the State, and all have developed a set of corporate values that are, in

various ways, embedded into the operational management of the organisations. By including values

(or the lack thereof) as either a strategic risk or a key performance indicator in employees’ annual

plans, the councils actively drive the values and ethics agenda with the staff.

46

All councils in the sample under review indicated a preference for a combination of compliance and

values-based cultural controls, confirming the theory that the models are not mutually exclusive (see

Treviño, 1990; Weaver et al., in press b). In addition, this approach recognises the complexity of the

‘corruption problem’, and attempts to address it in an integrated manner. As put by Tanzi (1998:

587) “the greatest mistake that can be made is to rely on a strategy that depends excessively on

actions in a single area…, and then to expect quick results”.

When analysing the awareness and implementation of behavioural theories, the study revealed that

two of the councils related to the concept of ethical role models, but their application was limited to

two senior managers for one organisation, and the senior leadership group for the other.

Investigating opportunities to identify and engage with ethical role models at operational level might

prove the key to an even more successful program. Perhaps a more detailed survey of the rationale

behind some of the management decisions by these councils, in relation to values and ethics

implementation, could shed some light on whether theories of behavioural science are taken into

account, and whether current programs are part of an evolving plan or are considered sufficient to

address the control needs.

In conclusion, the empirical research shows that the councils analysed did not include clear and

unambiguous measures of success related to behavioural science methodologies. However, drawing

from the literature reviewed during this research, it could be argued that the study confirms the

councils placed great importance on the development and promotion of shared values, as well as on

the significance of embedding these ‘organisational principles’ into each employee’s work plan (see

for example Weaver and Treviño, 1990). In doing so, they are effectively attempting to create a set

of injunctive social norms for the workplace (see Cialdini et al, 1990), a platform of standards that

define what the organisation is about. Rewards and recognition programs reinforce these

definitions, contributing to a sense of identity amongst the employees, a sense of ‘who we are’ (cf.

for example Festinger, 1957), with the hope that over time these principles are accepted and

embodied by the employees, effectively institutionalising them (see Weaver et al, 2005; Collins et al,

2013). Hence, while some of the methodologies implemented by councils to combat the risk of

corruption might not be labelled as behavioural methods, in effect they are, and it is expected that

over time testing at practical level will be conceptualised and evolved into a more sophisticated

outcomes framework.

47

Management solutions: shifting the paradigm

The research conducted revealed that NSW councils are becoming increasingly conscious of the

responsibility to control corruption risks and to foster an ethical workplace. However, it appears that

these responsibilities are predominantly driven by the General Managers and the Executive groups

in the organisation, often following a cookie-cutter approach in relation to solutions. A level of

policy and strategic direction is naturally required, but when it comes to developing the ‘human

fabric’ of the organisation and affecting employees’ endorsement of strategic directions, the risks of

a one-way, top-down approach should not be underestimated.

For example, executive management might intend to implement a uniform ethics program across

the organisation, but that program could be interpreted in multiple ways by different people in

different places, sometime even from one department to another, therefore causing a possible

dissonance in behaviour within the organisation (see Weber, 1995). Similarly, ‘off-the-shelf’

corruption prevention solutions might not suit the context in which they are applied. Councils vary

in environmental pressures that might influence the way ethics and conduct programs are promoted

(e.g. residents’ expectations, councillor awareness). Also, each council brings to the table their own

histories and circumstances (e.g. Past experience with conduct scandals, cultural norms, relationship

with Unions etc.).

This section encourages councils to attempt a more concertive approach by building on the ‘human

capital’ already available within the organisation, and to turn the paradigm of corruption prevention

upside down: instead of the “tone from the top”, it’s “tone from the bottom”. A concertive approach

embraces an attitude of empowerment and involves a framework where organisational norms and

values are collectively debated and interpreted, and where acceptable behaviour is developed as a

“negotiated consensus” among workers (Barker, 1993: 412). Commitment is therefore promoted

through participation (O’Reilly and Chatman, 1996), with shared interpretation leading to normative

pressures and a sense of social obligation amongst employees (Barker, 1993). In turn, this approach

naturally promotes ‘horizontal surveillance’ (Sewell, 1998), by which individual autonomy is

restricted as co-workers actively monitor established behavioural norms. The approach does not

recommend doing away with long-term aspirational visions developed by councils with their

community under the Integrated Planning and Reporting framework; nor does it recommend

replacing formal performance management and disciplinary frameworks with a staff self-regulation

system. However, it does encourage placing a level of responsibility on the employees in deciding

48

how the community vision will be delivered, in assessing what motivates staff, in determining how

the organisation will deal with customers, suppliers, contractors, volunteers, how employees will

behave with each other, and finally how the organisation will react to risks or instances of corrupt

conduct.

A management framework built on these principles and on the awareness of behavioural drivers

(see Figure 9) will offer a Council the opportunity to harness the potential already available within its

workforce, take an active role in shaping its future performance by promoting specific values and

behaviours, and develop the capacity to review its assumptions and adjust its trajectory.

Figure 9: A new model for promotion of values and ethical behaviour in an organisation

First, councils should initiate a program of development or review of corporate values, ensuring staff

are involved throughout the whole program, from inception to conclusion. It is essential that the

conversation around values involve ethics and ethical behaviour. Subsequently, a marketing and

communications strategy should be implemented, followed by a succinct and creative training

program, which must include reference to legislative frameworks and compliance controls so as to

ensure all elements are integrated. Ideally, the training program would involve relevant staff sharing

their experiences and views on particular topics such as ethical behaviour and accountability.

Develop/Review corporate values

Marketing and Communications

Training

Recruitment process

Reference checks

Induction

Staff 'guides'

Explain decisions

Promote shared interpretation of events

Advertise actions taken against misconduct

Identify "ethics champions"

Recognise and promote ethical behaviour

Research best practice

Review control frameworks

49

Following the development of a clear set of values and behavioural expectations, it is critical that the

Council maintains a rigorous and uncompromising discipline in its recruitment processes: a

requirement of employment will be that potential staff genuinely endorse the organisation’s values,

and that reference checks involve questions aimed at probing the applicants’ attitude towards

ethical behaviour and accountability. As a natural progression, initial induction and training

programs will reinforce the values framework to new employees, and will provide details of key staff

members within their department/unit able to offer guidance both on procedural and behavioural

level.

Third, open communication is promoted and implemented from management and staff and vice-

versa. More importantly, events and decisions are explained and clearly interpreted, so as to

promote shared views and avoid misunderstandings. This includes sending unambiguous signals

when the organisation takes disciplinary action against staff members for misconduct or unethical

behaviour.

Fourth, over time councils should identify ‘ethics champions’ within each department, individuals

whose behaviour regularly exemplify organisational values, who are known for not compromising

their ethical principles, who regularly report wrongdoing and who are highly respected by their

peers and colleagues. This can be achieved through regular evaluation programs and peer-reviews

(such as 360 degree reviews), and it needs to be connected to a program of recognition and

celebration publicised amongst the organisation, or as a minimum at departmental level. It is not

recommended that the recognition involve a reward, especially of monetary-like value; instead it

would be ideal that the staff member be thanked directly and personally by his supervisor, manager,

Executive member and General Manager, and that a positive note be placed in their personnel file.

This process will positively reinforce behaviour and attitude that aligns with organisational values.

At the fifth stage, management should promote a process of regular reviews. Taking into account

that councils are evolving entities, each with their past experiences and their visions for the future, it

is essential that management build a capacity to review the council’s processes and assumptions in

relation to control frameworks. Over time, in fact, analysis of corruption prevention programs might

reveal that certain controls rely on outdated assumptions (O’Reilly and Chatman, 1996), and that it

might be necessary to “break or revise scripts” (Gioia, 1992). A cyclical review framework based on

research of best practice will provide such opportunity, and if staff are once again given an active

50

role in the process, the organisation could be confident in implementing up to date and effective

programs.

As with most programs that aim at influencing behaviour and attitudes, the one suggested above

assumes prolonged employee contact with the Council, and intense activity by the organisation.

However, these two elements should not deter management from implementing the program: local

government is in fact characterised by a relatively low turnover of employees (see PWC & LGMA,

2013), and most of the suggested actions can be implemented in a very cost effective manner.

Lastly, in the NSW Local Government context, a particularly current reflection is that programs

aimed at developing a normative order and promote changes in behaviour have been proven to be

more effective in small organisations (see Weaver et al., 2005). Further, research (see Gilman, 1996)

has shown that administrative reforms including downsizing and privatisation can lead to staff

insecurity and lower morale, which in turn can have to possible impacts on diminishing ethical

behaviour (OECD, 1998).

These views will need to be taken into account when assessing the current reform agenda being

promoted by the NSW Government for the State’s Local Government sector: under the theme “Fit

for the Future” (NSW Office of Local Government, 2015), the reform package suggest that improved

efficiency might be gained if councils merge into bigger entities. Without reducing the reform

package to just the suggestion of mergers, and without oversimplifying the context to just

corruption prevention, it is nevertheless important to highlight the risk that a process of merging

organisations into much bigger corporate bodies might have on checks and balances, surely cutting

red tape, but also institutional controls.

Conclusions

Awareness of the ‘corruption issue’ is becoming increasingly ‘front of mind’ for the Australian public.

Extensive media coverage of investigations and inquiries contributes to widespread awareness of

individuals’ conduct, with particularly strong attention dedicated to public sector scandals. The

impacts of corruption and the public outcry that typically ensue are vast by any standard, not just for

the individuals involved, but for those associated with them, and for the organisation they belong to,

who will need to deal with substantial collateral reputational damage, often lasting for years.

51

As identified in this study, the NSW Local Government sector is far from being immune to the

phenomenon, consistently ranking at the top of the ICAC charts for number of complaints and public

investigations. Arguably, the apparent over-representation of local government in complaints and

inquiry statistics is due to the high level of public involvement and interaction with councils, as well

as the diversity of front-line services provided to the community. For precisely the same reasons,

however, it is essential that local government aim at operating in the most effective, efficient and

corruption-resistant way possible.

Building on the premise that corruption can be reduced but not entirely eliminated, this research

analysed the effectiveness of corruption prevention methodologies, juxtaposing two of the most

relevant and researched control systems: the compliance model and the organisational values

model.

While more recent research and literature tend to favour values-based methods to compliance

controls, this study concludes that the two orientations cannot be considered mutually exclusive,

and most importantly, they are not substitutes for each other. The message of trust and support

conveyed by a values orientation might be required to understand the purpose of compliance

activities. When a values orientation is strong, compliance activities can be perceived as part of an

overall system of support for ethical behaviour.

From a conceptual and sociological perspective, however, this paper encourages a shift in

orientation when analysing human behaviour and its drivers, in particular in relation to corruption

prevention. Emphasis is often placed on a mechanistic view of human behaviour, characterising

individuals as selfish and rational beings, driven by external incentives. Under this conception, values

and morals would not play any part in corruption prevention efforts, and the only solution would be

to promote oversight and control, rules, punishments. As described by Gebel (2012: 109), such

views would expect people to “run after their narrow material self-interest” like “a donkey that runs

after the carrots”, and to be equally “controllable by sanctions like the donkey by sticks”. However,

argues Gebel (2012), animal nature is not as simple as that, let alone human nature.

By concentrating on institutional response and oversight, there is a risk of ignoring the social and

moral norms that form part of human behaviour, and the multitude of personal and socio-cultural

drivers that can affect such norms (see Blaug, 2010; Searle, 1995; Williams, 1999). Practical

implications of constructivism and behavioural science can be easily identified, as demonstrated in

52

the analysis of the ethical role model theory: knowledge of such principles is relevant to key aspects

of organisational management such as selecting individuals for leadership position, and in decisions

around training and developing employees to be people that others will view as ethical role models.

Only by accepting that corruption can be viewed as a social act, that individuals are not just rational

and self-interested isolated cells, and that they follow, and contribute to, continually evolving social

norms, will organisations be in an advantageous position to promote integrity and ethics, and to

explore the true meaning of prevention, as opposed to mere control.

Acknowledgments

I would like to thank Dr Bligh Grant for sharing his insights on theoretical frameworks; Ron Woods

and Dr Jessie Lymn for their guidance and patience throughout this project; Michael McMahon for

his support and understanding. Special thanks to Gully for the endless debates on the topic of

behavioural science.

And to Kate, for being you, and for being there, always.

53

References

ABC News 2011, ICAC probe told of 'pervasive web of corruption, viewed 15 March 2015, <http://www.abc.net.au/news/2011-10-04/icac-hears-of-nsw-council-corruption/3208446>.

ABC, 14 March 2014, Royal commission into union corruption: Abbott says ‘good’ unions have nothing to fear, viewed 3 June 2015, <http://www.abc.net.au/news/2014-03-14/abbott-denies-war-against-unions-in-royal-commission/5320414>.

Adler, P. S. & Borys, B. 1996, ‘Two types of bureaucracy, enabling and coercive’, Administrative Science Quarterly, vol. 41, no.1, pp. 61-90.

Alighieri, D. 1840, ‘La divina commedia’.

Anechiarico, F. & Jacobs, J.B. 1996, The pursuit of absolute integrity: how corruption control makes government ineffective, University of Chicago Press, Chicago.

Aquino, K. & Reed, A. 2002, ‘The self-importance of moral identity’, Journal of Personality and Social Psychology, vol. 83, no. 6, pp. 1423–1440.

Ashforth, B.E. & Anand, V. 2003, ‘The normalisation of corruption in organisations’, Research in Organisational Behaviour, vol. 25, pp. 1-52.

Ashforth, B.E., Gioia, D.A., Robinson, S.L. & Treviño, L.K. 2008, ‘Re-viewing organisational corruption’, Academy of Management Review, vol. 33, no. 3, pp. 670-684.

Ashforth, B. E. & Mael, F. 1989, Social identity theory and the organization. Academy of Management Review, vol. 14, no. 1, pp. 20-39.

Australian Financial Review, 1 April 2015, Chinese expatriate feels heat of Beijing corruption scandal, viewed 1 June 2015, <http://www.afr.com/news/world/chinese-expatriate-feels-heat-of-beijing-corruption-scandal-20150401-1mcuqt>.

Babiak, P. & Hare, R.D. 2006, Snakes in suits: when psychopaths go to work, Harper Collins, New York.

Bandura, A. 1977, Social Learning Theory, Prentice Hall, Englewood Cliffs, NJ.

Bandura, A. 1986, Social foundations of thought and action: a social cognitive theory, Prentice Hall, Englewood Cliffs, NJ.

Bandura, A. 1999, ‘Moral disengagement in the perpetration of inhumanities’, Personality and Social Psychology Review, vol. 3, no. 3, pp. 193–209.

Barker, J. R. 1993, ‘Tightening the iron cage: concertive control in self-managing teams’, Administrative Science Quarterly, vol. 38, no. 3, pp. 408–437.

54

Barnett, T. & Vaicys, C. 2000, ‘The moderating effect of individuals’ perceptions of ethical work climate on ethical judgements and behavioural intentions’, Journal of Business Ethics, vol. 27, no. 4, pp. 351-162.

Barr, A. & Serra, D. 2008, Corruption and culture: an experimental analysis, University of Oxford, Oxford.

Baumeister, R.F. 1998, ‘The self’, in Gilbert, D.T., Fiske S.T. & Lindzey, G (4th edn), Handbook of social psychology, McGraw-Hill, New York, pp. 680-740.

BBC News 2015, David Cameron: FIFA scandal must prompt corruption purge, viewed 6 June 2015, <http://www.bbc.com/news/uk-politics-33025225>.

Bennet, R.J. & Robinson, S.L. 2003, ‘The past, present, and future of workplace deviance research’, in Greenberg, J (ed.), Organisational behaviour: the state of the science, Lawrence Erlbaum Associates, NJ, pp. 247-281.

Bibb, S. 2010, Beyond the code of conduct – eight steps to building an ethical organisational culture, viewed 15 March 2015, <http://sallybibb.com/articles/>.

Bird, F. & Waters, J. 1989, ‘The moral muteness of managers’, California Management Review, vol. 32, no. 1, pp. 73—88.

Blair, T. 1998, Leading the way: a new vision for local government, Institute for Public Policy Research, London.

Blasi, A. 2005, ‘Moral character: A psychological approach’, in Lapsley D.K. & Power F.C (Eds.), Character psychology and character education, University of Notre Dame Press, Notre Dame, pp. 67-100.

Blau, P. 1964, Exchange and power in social life, John Wiley, New York.

Blaug, R. 2010, How power corrupts: cognition and democracy in organisations, Plagrave Macmillan, London.

Bloomberg Philanthropies, 2015, What Works Cities - Government Innovation, viewed 1 June 2015, <http://www.bloomberg.org/program/government-innovation/what-works-cities/>.

Bova, B.M. & Phillips, R.R. 1984, ‘Mentoring as a learning experience for adults’, Journal of Teacher Education, vol. 35, no. 3, pp. 16-20.

Braibanti, R. 1962, ‘Reflections on bureaucratic corruption’, Public Administration, vol. 40, no. 4, pp. 357-372.

Bratsis, P. 2014, ‘Political corruption in the age of transnational capitalism’, Historical Materialism Vol. 22.1, p. 105-128, viewed 1 June 2015, <http://www.academia.edu/5949120/Political_Corruption_in_the_Age_of_Transnational_Capitalism_From_the_Relative_Autonomy_of_the_State_to_the_White_Mans_Burden>.

Braverman, H. 1974, Labor and monopoly capital: the degradation of work in the twentieth century, Monthly Review Press, New York.

55

Brekke, A.K., Kverndokk, S. & Nyborg, K. 2003, ‘An economic model of moral motivation’, Journal of Public Economics, vol. 87, pp. 1967-1983.

Brereton, M. & Temple, M. 1999, ‘The new public service ethos: an ethical environment for governance’, Public Administration, vol. 77, no.3, pp. 455-474.

Brewer, M. 1993, ‘The role of distinctiveness in social identity and group behavior’, in Hogg M.A. & Abrams, D (Eds.), Group motivation: social psychological perspectives, Harvester Wheatsheaf, England, pp. 1-16.

Brewer, M.B. 1991, ‘The social self: on being the same and different at the same time’, Personality and Social Psychology Bulletin, vol. 17, no. 5, pp. 475–482.

Brown, M., Treviño, L.K. & Harrison, D. 2005, ‘Ethical leadership: A social learning perspective for construct development and testing’, Organizational Behavior and Human Decision Processes, vol. 97, pp. 117-134.

Brown, M.E. & Treviño, L.K. 2014, ‘Do role models matter? An investigation of role modelling as an antecedent of perceived ethical leadership’, Journal of Business Ethics, vol. 122, no. 4, pp. 587-598.

Cameron, K.S., Dutton, J.E. & Quinn, R.E. 2003, Positive organizational scholarship: Foundations of a new discipline, Berrett-Koehler, San Francisco, CA.

Cardinal, L.B. 2001, ‘Technological innovation in the pharmaceutical industry: the use of organizational control in managing research and development’, Organization Science, vol. 12, no. 1, pp. 19–36.

Cavanagh, G.F. & Moberg, D.J. 1999, ‘The virtue of courage within the organization’, Research in ethical issues in organizations, vol. 1, pp. 1-25.

Chapman, R. 2001, ‘Ethics in the public service for the new millennium’, Public Money & Management, vol. 21, no. 1, pp.6–7.

Chase, R.B. & Dasu, S. 2001, ‘Want to perfect your company’s service? Use behavioral science’, Harvard Business Review, vol. 79, no. 6, pp. 78–84.

Cialdini, R.B. & Trost, M.R. 1998, ‘Social influence: social norm, conformity, and compliance’, in Gilbert, D.T., Fiske S.T. & Lindzey, G (Eds.), Handbook of social psychology, vol. 2, McGraw-Hill, New York, pp. 151–192.

Cialdini, R.B., Reno, R.R. & Kallgren, C.A. 1990, ‘A focus theory of normative conduct: recycling the concept of norms to reduce littering in public places’, Journal of Personality and Social Psychology, vol. 58, no. 6, pp. 1015–1026.

CNN, 2015, One sentence can make you pay all your taxes, viewed 6 June 2015, <http://money.cnn.com/2015/05/29/news/economy/bloomberg-taxes/>.

Collins English Dictionary, 2015, Definition of word ‘corruption’, viewed 20 April 2015, <http://www.collinsdictionary.com/dictionary/english/corruption>.

56

Collins, J., Thomas, G., Willis, R., & Wilsdon, J. 2003, ‘Carrots, Sticks and Sermons’, London, Demos/Green Alliance.

Colvin, G. 2004, The verdict on business: presumed guilty, Fortune Magazine, viewed 15 May 2015, <http://archive.fortune.com/magazines/fortune/fortune_archive/2004/11/15/8191102/index.htm.

Crawshaw, J.R., Cropanzano, R., Bell, C.M. & Nadisic, T. 2013, ‘Organisational justice: new insights from behavioural ethics’, Human Relations, vol. 66, no. 7, pp. 885-904.

Crikey, 4 March 2008, Australia’s dodgiest local councils, viewed 12 March 2015, <http://www.crikey.com.au/2008/03/04/australias-dodgiest-local-councils-a-crikey-list/>.

Cyr, L. A. & Welbourne, T. M. 1997, ‘Human resource management in initial public offering firms: validation of a control orientation typology’, Advances in Entrepreneurship, Firm Emergence and Growth, vol. 3, pp.249–296.

De Vries, M.S. 2002, ‘Can you afford honesty?’, Administration & Society, vol. 34, no. 3, pp. 309-334.

Doig, A. 1994, ‘Sustainable Anti-Corruption strategies: the role of independent agencies’, unpublished paper, University of London, as cited in Galtung, F., 1998 ‘Criteria for sustainable corruption’, The European Journal of Development Research, Vol. 10, Issue 1, 105-128.

Doig, R.A. & Skelcher, C. 2001a, ‘Ethics in Local Government: evaluating self-regulation in England and Wales’, Local Government Studies, vol. 27, no. 1, pp. 87–108.

Dolan, K., McKeown, B., & Carlson, J. M. 1988, ‘Popular conceptions of political corruption: implications for the empirical study of political ethics’, Corruption and Reform, vol. 3, No.1, pp. 3-24.

Donnelly, G. 2005, Beyond the code: benchmarking ethics, compliance programs, Compliance Week, viewed 14 June 2015, < https://www.complianceweek.com/news/news-article/beyond-the-code-benchmarking-ethics-and-compliance#.VXUke_mUdqU>.

Dungan, J., Waytz, A. & Young, L. 2014, ‘Corruption in the context of moral trade-offs’, Journal of Interdisciplinary Economics, vol. 26, no. 1-2, pp. 97-118.

Economic Times, 12 August 2014, Ending corruption only way to remove poverty: Prime Minister Narendra Modi, viewed 1 June 2015, <http://economictimes.indiatimes.com/news/politics-and-nation/ending-corruption-only-way-to-remove-poverty-prime-minister-narendra-modi/articleshow/40128446.cms>.

Economist 2010, ‘Georgia’s mental revolution’, August 19.

Eisenberger, R., Fasolo, P. & Davis-LaMastro, V. 1990, ‘Perceived organizational support and employee diligence, commitment, and innovation’, Journal of Applied Psychology, vol. 75, no. 1, pp. 51-59.

Eisenberger, R., Huntington, R., Hutchison, S. & Sowa, D. 1986. ‘Perceived organizational support’, Journal of Applied Psychology, vol. 71, pp. 500-507.

57

Eriksson, B. 1995, ‘Speech by the President of the ICPO-Interpol at the opening ceremony of the Seventh International Anti-corruption Conference’, paper presented at the Seventh International Anti-corruption Conference, Beijing, 6-10 October 1995.

Etzioni, A. 1961, A comparative analysis of complex organizations, Free Press, New York.

Euben, J. P. 1990, The tragedy of political theory: The road not taken, Princeton University Press, Princeton, NJ.

Festinger, L.A. 1957, A theory of cognitive dissonance, Stanford University Press, Stanford, CA.

Financial Times, 5 February 2014, UK Cabinet office ‘nudge team’ to be spun off into private group, viewed 15 May 2015, <http://www.ft.com/cms/s/0/571eef16-8d99-11e3-9dbb-00144feab7de.html#axzz3cHVVlR66>.

Fiorito, G. & Scotto, P. 1992, ‘Observational learning in Octopus vulgaris’, Science, vol. 256, no. 5056, pp. 545-547.

Fiske, A.P. 1991, Structures of social life: the four elementary forms of human relations, Free Press, New York.

Friederich, C.J. 2002, ‘Corruption concepts in historical perspective’, in A. Heidenheimer & M. Johnston (eds), Political Corruption – Concepts and Contexts, pp. 15-23.

Galtung, F. 1998, ‘Criteria for sustainable corruption’, European Journal of Development Research, vol. 10, no. 1, pp. 105-128.

Gebel, A.C. 2012, ‘Human Nature and morality in the anti-corruption discourse of Transparency International’, Public Administration and Development, vol. 32, no. 1, pp. 109-128.

Gibson, D.E. 2003, ‘Developing the professional self-concept: role model construals in early, middle and late career stages’, Organisational Science, vol. 14, viewed 10 May 2015, < http://pubsonline. informs.org/doi/abs/10.1287/orsc.14.5.591.16767>.

Gilman, S. C. & Lewis, C.W. 1996, Public service ethics: a global dialogue. Public Administration Review, vol. 56, no. 6, pp. 517-524.

Gino, F., Ayal, S. & Ariely, D. 2009, ‘Contagion and differentiation in unethical behaviour – the effect of one bad apple on the barrel’, Psychological Science, vol. 20, no. 3, pp. 393-398.

Gioia, D.A. 1992, ‘Pinto fires and personal ethics: a script analysis of missed opportunities’, Journal of Business Ethics, vol. 11, no. 5-6, pp. 379–389.

Gneezy, U. 2005, ‘Deception: the role of consequences’, American Economic Review, vol. 95, no. 1, pp. 384-394.

Godin, S. 2002, ‘Unleashing the Idea Virus’, cited in Collins, J. et al, Carrots, Sticks and Sermons, p. 17.

Gorta, A. 1998, Minimising Corruption: some lessons from the literature, NSW ICAC.

58

Gorta, A. & Forell, S. 1995, ‘Layers of decision: linking social definitions of corruption and willingness to take action’, Crime, Law & Social Change, vol. 23, no. 4, pp. 315-343.

Gouldner, A.W. 1954, Patterns of industrial bureaucracy, Free Press, New York.

Government News, 29 October 2012, New corruption scandal hits 14 NSW Councils, viewed 15 March 2015, <http://www.governmentnews.com.au/2012/10/new-corruption-scandal-hits-14-nsw-councils/>.

Haidt, J. 2001, ‘The emotional dog and its rational tail: a social intuitionist approach to moral judgment’, Psychological Review, vol. 108, no. 4, pp. 814-834.

Hannan, R. L., Rankin, F. W., & Towry, K. L. 2006, ‘The effect of information systems on honesty in managerial reporting: A behavioral perspective’, Contemporary Accounting Research, vol. 23, no. 4, pp. 885-918.

Heckleman, J.C. & Powell, B. 2010, ‘Corruption and the institutional environment for growth, Research Working Paper’, Comparative Economic Studies, vol. 52, no. 3, pp.351-378.

Heyes, C.M. 1994, ‘Social learning in animals: categories and mechanisms’, Biological Reviews, vol. 69, no. 2, pp. 207–231.

Hill, J. & Kochendorfer, R.A. 1969, ‘Knowledge of peer success and risk of detection as determinants of cheating’, Developmental Psychology, vol. 1, no. 3, pp. 231–238.

Hindess, B. 2001, ‘Good government and corruption’, Corruption and Anticorruption Canberra; Asia Pacific Press and Australian Institute of Criminology, pp. 1-10.

Hollinger, R.C. & Clark, J.P. 1983, Theft by Employees, New York.

Hood, C. 1991, ‘A public management for all seasons?’, Public Administration, vol. 69, no. 1, pp. 3-19.

Hopwood, A. 1974, Accounting and human behaviour, Prentice Hall, Englewood Cliffs, NJ.

Huddart, S. J., & Qu, H. 2013, ‘Rotten apples and sterling examples: Moral reasoning and peer influences on honesty in managerial reporting’, AAA.

Huntington, S. 1968, Political order in changing societies, Yale University Press, New Haven.

International Labour Organization, Corporate Codes of Conduct, viewed 20 May 2015, <www.itcilo.it/english/actrav/telearn/global/ilo/code/main.htm>.

Johnson, P. & Gill, J. 1993, Management control and organizational behaviour, Paul Chapman, London.

Johnston, M. 1986, ‘Right and wrong in American politics: popular conceptions of Corruption’, Polity, vol. 18, no. 3, pp. 367-391.

Johnston, M. 1993, Social Development as an Anti-Corruption strategy, VIth International Anti-Corruption Conference, Cancun, Mexico.

59

Johnston, M. 1996, ‘The search for definitions: the vitality of politics and the issues of corruption’, International Social Science Journal, vol. 48, no. 149, pp. 321–336.

Jorna, P. 2014, Transitional and Organised crime program, Australian institute of Criminology, presentation at Corruption Prevention Network forum, 11 November 2014, Sydney, <http://www.corruptionprevention.net/assets/Resources/Penny-Jorna-Corruption-trends-and-complexities-in-Australian-government-agencies.pdf>.

Kohlberg, L. 1969, ‘Stage and sequence. The cognitive developmental approach to socialization’, in D.A. Goslin (Ed.), Handbook of socialization theory, Rand McNally, Chicago, pp. 347-480.

Krastev, I. 1998, ‘Dancing with anticorruption’, E. Eur. Const. Rev., vol. 7, p. 56.

Lange, D. 2008, ‘A multidimensional conceptualisation of organisational corruption control’, Academy of Management Review, vol. 33, no. 3, pp. 710-729.

Larmour P. & Wolanin, N. 2011, Corruption and anti-corruption. Asia Pacific Press, ACT

Lawton, A. & Macaulay, M. 2004, ‘Ethics at the crossroads? Developments in the ethical framework for Local Government’, Local Government Studies, vol. 30, no. 4, pp. 624-638.

Ledgerwood, A., Trope, Y. & Chaiken, S. 2010, ‘Flexibility now, consistency later: Psychological distance and construal shape evaluative responding’, Journal of Personality and Social Psychology, vol. 99, no. 1, pp. 32–51.

Leff, N. 1964, ‘Economic development through bureaucratic corruption’, American Behavioral Scientist, vol. 8, no. 3, pp. 8-14.

Lerner, M. J. 1977, ‘The justice motive: Some hypotheses as to its origins and forms1’, Journal of personality, vol. 45, no 1, pp. 1-52.

Lewis, M. 2007), States of Reason, Institute for Public Policy Research.

Lincoln, S.H. & Holmes, E.K. 2011, ‘Ethical decision making: a process influenced by moral intensity’, Journal of healthcare, science and humanities, vol. 1, no. 1, pp. 55-69.

LRN, 2006, The impact of codes of conduct on corporate culture – measuring the immeasurable, viewed 2 April 2015, <www.lrn.com>.

Maas, V. S., & Van Rinsum, M. 2010, ‘How Monetary and Non-Monetary Incentives Influence Performance Misreporting: An Experiment’, Working Paper, University of Amsterdam.

Machiavelli, N. 1531, Discourses on the First Ten Books of Titus Livy.

March, J.G. & Simon, H.A. 1958, Organization, Wiley, New York.

March, J.G. & Olsen, J.P. 1989, Rediscovering institutions: the organizational basis of politics, Free Press, New York.

Marcus, B. & Schuler, H. 2004, ‘Antecedents of counterproductive behaviour at work: a general perspective’, Journal of Applied Psychology, vol. 89, no. 4, pp. 647-660.

60

Mazar, N., Amir, O. & Ariely, D. 2008, ‘The dishonesty of honest people: a theory of self-concept maintenance’, Journal of Marketing Research, vol. 45, no. 6, pp. 633–644.

McKinsey & Company, 2010, ‘Using behavioral science to improve the customer experience’, McKinsey Quarterly, viewed 6 May 2015, http://www.mckinsey.com/insights/operations/using_behavioral_science_to_improve_the_customer_experience>.

McMillan, M. 2012, ‘Codes of Ethics: if you adopt one, will they behave?’, CFA Institute blog, viewed 18 April 2015, <http://blogs.cfainstitute.org/investor/2012/02/20/codes-of-ethics-if-you-adopt-one-will-they-behave/>.

Merton, R. K. (1957). Social theory and social structure (rev.)

Michaels, J.W. & Miethe, T.D. 1989, ‘Applying theories of deviance to academic cheating’, Social Science Quarterly, vol. 70, no. 4, pp. 870–885.

Michels, D. 2014, The role and work of an Ethic Officer at the UN, presentation at the Corruption Prevention Network forum, 11 November 2014, Sydney. <http://www.corruptionprevention.net/assets/Resources/David-Mitchels-The-role-and-work-of-an-Ethics-Officer-in-the-UN.pdf>.

Mikhail, J. 2007, ‘Universal moral grammar: theory, evidence, and the future’, Trends in Cognitive Sciences, vol. 11, no. 4, pp. 143–152.

Mintzberg, H. 1979, The structuring of organizations, Prentice Hall, Englewood Cliffs, NJ.

Moberg, D.J. 2000, ‘Role models and moral exemplars: how do employees acquire virtues by observing others?’, Business Ethics Quarterly, vol. 10, no. 3, pp. 675-696.

Montesquieu, C.L. 1734, Considerations on the Causes of the Grandeur and Decadence of the Romans

Moss, I. 2001, ‘Foreword’, in ICAC, Corruption resistance Strategies – Researching risks in local government.

Murphy, P.E., Smith, J.E. & Daley, J.M. 1992, ‘Executive attitudes, organizational size and ethical issues: perspectives on a service industry’, Journal of Business Ethics, vol. 11, no. 1, pp. 11–19.

Myers, R. 2003, ‘Ensuring ethical effectiveness’, Journal of Accountancy, New York.

Nelson, R.R. & Winter, S.G. 1982, An evolutionary theory of economic change, Belknap Press of Harvard University Press, Cambridge, MA.

New York Times, 7 December 2014, Britain’s Ministry of Nudges, viewed 6 June 2015, <http://www.nytimes.com/2013/12/08/business/international/britains-ministry-of-nudges.html?_r=0>.

Nisbett, R. & Ross, L. 1980, Human inference: strategies and shortcomings of social judgement, Prentice Hall, Englewood Cliffs, NJ.

61

Nocera, J. 2002, ‘System failure’, Fortune, vol. 145, no. 13, pp. 62-66.

Nolan Report 1995, Standards in public life: first report of the committee on standards in public life.

NSW Government, Department of Premier & Cabinet, 2015, Behavioural Insights community of practice, viewed 20 May 2015, <http://bi.dpc.nsw.gov.au/>.

NSW Independent Commission Against Corruption 2001, The first four steps: building organisational integrity.

New South Wales Independent Commission Against Corruption, Annual Reports 2008-2014, viewed 25 April 2015, <www.icac.nsw.gov.au>.

NSW Office of Local Government, 2015, Promoting Better Practice Review reports, viewed 15 March 2015, <https://www.olg.nsw.gov.au/content/promoting-better-practice-review-reports>.

NSW Treasury Corporation, 2013, Financial Sustainability of the NSW Local Government Sector Report, viewed 15 March 2015, <http://www.olg.nsw.gov.au/sites/default/files/TCorp-Report-Financial-Sustainability-of-the-New-South-Wales-Local-Government-Sector-April-2013.pdf>.

O’Reilly, C. A., III, & Chatman, J. 1996, ‘Culture as social control: corporations, cults, and commitment’, Research in Organizational Behavior, vol. 18, pp. 157–200.

Ostrom, E. 2000, ‘Collective action and the evolution of social norms’, Journal of Economic Perspective, vol. 14, no. 3, pp. 137-158.

O’Toole, B.J. 1993, ‘The loss of purity: the corruption of public service in Britain’, Public Policy and Administration, vol. 8, no. 2, pp. 1-6.

Oppel Jr., R.A. & Eichenwald, K. 2002, ‘Enron’s collapse: the overview’, The New York Times, viewed 2 May 2015, <http://www.nytimes.com/2002/01/16/business/enron-s-collapse-overview-arthur-andersen-fires-executive-for-enron-orders.html>.

Organization for Economic Cooperation and Development, 1998, Managing ethics in the public sector (Puma Policy Brief), Paris.

Ouchi, W.G. 1978, ‘The transmission of control through organizational hierarchy’, Academy of Management Journal, vol. 21, no. 2, pp. 173–192.

Ouchi, W.G. 1980, ‘Markets, bureaucracies, and clans’, Administrative Science Quarterly, vol. 25, no. 1, pp. 129–141.

Paine, L.S. 1994, ‘Managing for organizational integrity’, Harvard Business Review, vol. 72, no. 2, pp. 106-117.

Paine, L., Deshpande, R., Margolis, J.D. & Bettcher, K.E. 2005, ‘Up to code: does your company’s conduct meet world-class standards?’, Harvard Business Review, pp. 1-12.

Pakaluk, M. 2005, Aristotle's Nicomachean Ethics: introduction, University of Chicago Press, Chicago.

62

Paulhus, D. 1984, ‘Two-component models of socially desirable responding’, Journal of personality and social psychology, vol. 46, no.3, pp. 598-609.

Peters, J.G. & Welch, S. 1978, ‘Political Corruption in America: A search for definitions and a theory, or if political corruption is in the mainstream of American politics why is it not in the mainstream of American politics research?’, American Political Science Review, vol. 72, no. 3, pp. 974-984.

Plato 380BC, ‘Protagoras’.

Polzer, T. 2001, Corruption: deconstructing the World Bank discourse, LSE Destin Working Paper Series, 1(18).

Pope, J. 1996, National Integrity System: The TI Source Book, Washington, DC: TI and EDI.

Power, M. 1997, The audit society: rituals of verification, Oxford University Press, Oxford.

Pratchett, L. & Wingield, M. 1994, ‘The public service ethos in local government: a research report’, Commission for Local Democracy, London.

Pratt, M. G. 1998, ‘To be or not to be: central questions in organizational identification’, in D.A. Whetten & P.C. Godfrey (Eds.), Identity in organizations: building theory through conversations, Thousand Oaks, CA, pp. 171-207.

PricewaterhouseCoopers 2011, Cybercrime: protecting against the growing threat, Global Economic Crime Survey, viewed 20 April 2015, <https://www.pwc.com/en_GX/gx/economiccrime-survey/assets/GECS_GLOBAL_REPORT.pdf>.

PricewaterhouseCoopers & Local Government Managers Australia 2013, NSW Local Government operational effectiveness self assessment pilot survey report, p.9

Pritzl, R.F.J. 1997, Korruption und Rent-Seeking in Lateinamerika, Baden-Baden, Nomos.

Queensland Crime and Misconduct Commission 2005, Fraud and Corruption Control.

Queensland Government, 2001, Crime and Misconduct Act.

Reason, J. 1990, Human Error, Cambridge University Press, UK.

Republika Online, 13 May 2015, President issues instruction to eradicate corruption, viewed 1 June 2015, <http://www.republika.co.id/berita/en/national-politics/15/05/13/noa1g0-president-issues-instruction-to-eradicate-corruption>.

Rest, J.R. 1986, Moral development: advances in research and theory, Praeger, New York.

Rest, J. R. 1994, ‘Moral development in the professions: Psychology and applied ethics’, Psychology Press.

Rest, J. R., Bebeau, M. J., & Thoma, S. J. 1999, ‘Postconventional moral thinking: A neo-Kohlbergian approach’, Psychology Press.

63

Robinson, S. & Greenberg, J. 1998, ‘Employees behaving badly: dimensions, determinants and dilemmas in the study of workplace deviance’, Journal of Organizational Behavior, vol. 5, pp. 1-30.

Robinson, S. & O’Leary-Kelly, A. 1998, ‘Monkey see, monkey do: the influence of work groups on antisocial behavior of employees’, Academy of Management Journal, vol. 41, no. 6, pp. 658-672.

Rohr, J.A. 1978, Ethics for bureaucrats: an essay on law and values, Dekker, New York.

Rose-Ackerman, S. 1996, ‘The political economy of corruption: causes and consequences’, Viewpoint, No. 74.

Rousseau, J. 1762, Social Contract.

Schulman, M. 2005, ‘How we become moral: the sources of moral motivation’, in C.R. Snyder & S.J. Lopez (Eds.), Handbook of positive psychology, Oxford University Press, New York, pp. 499-514.

Schweitzer, M.E. & Hsee, C.K. 2002, ‘Stretching the truth: Elastic justification and motivated communication of uncertain information’, Journal of Risk and Uncertainty, vol. 25, no. 2, pp. 185–201.

Seabury, C. Enron: the fall of a Wall Street darling, Investopedia, viewed on 2 May 2015, <http://www.investopedia.com/articles/stocks/09/enron-collapse.asp>.

Searle, J.R. 1995, The construction of social reality, The Free Press, New York.

Sewell, G. 1998, ‘The discipline of teams: the control of team-based industrial work through electronic and peer surveillance’, Administrative Science Quarterly, vol. 43, no. 2, pp. 397–428.

Somers, M.J. & Casal, J.C. 1994, ‘Organizational commitment and whistle-blowing: a test of the reformer and the organization man hypotheses’, Group and Organization Management, vol. 19, pp. 270–284.

Somers, M.J. 2001, ‘Ethical codes of conduct and organisational context: a study of the relationship between codes of conduct, employee behaviour and organisational values’, Journal of Business Ethics, vol. 30, no. 2, pp. 185-195.

Sparks, J. R. & Hunt, S.D. 1998, ‘Marketing researcher ethical sensitivity: conceptualization, measurement, and exploratory investigation’, Journal of Marketing, vol. 62, no. 2, pp. 92-109.

Stryker, S. & Serpe. R.T. 1982, ‘Commitment, identity salience, and role behavior: theory and research example’, in W. Ickes & E. S. Ktiowles (Eds.), Personality, roles and social behaviour, Springer-Verlag, New York, pp. 199-218.

Stryker, S. 1980, Symbolic interactionism: a social structural version, Benjamin & Cummings, Menlo Park, CA.

Sydney Morning Herald, 7 June 2014, Politics of pushing: behavioural economics a revenue game changer, viewed 6 June 2015, <http://www.smh.com.au/nsw/politics-of-pushing-behavioural-economics-a-revenue-gamechanger-20140606-39ofw.html>.

Sydney Morning Herald, 4 October 2011, Great council corruption ripoff, viewed 15 March 2015,

64

<http://www.smh.com.au/nsw/great-council-corruption-ripoff-inquiry-hears-how-fencing-goods-takes-on-a-whole-new-meaning-20111004-1l6gc.html>.

Tacitus, Annals, 117 BC

Tajfel, H. & Turner, J.C. 1986, ‘The social identity theory of intergroup behavior’, in S. Worchel & W.G. Austin (Eds.), Psychology of intergroup relations, Nelson-Hall, Chicago, pp. 7-24.

Tanzi, V. 1998, ‘Corruption around the world: causes, consequences, scope, and cures’, Staff Papers (International Monetary Fund), vol. 45, no. 4, pp. 559-594.

Tasmanian Government 2009, Integrity Commission Act.

Terry, D.J. & Hogg, M.A. 2001, ‘Attitudes, behaviour and social context: the role of norms and group membership in social influences processes’, Social influence: direct and indirect processes, Lawrence Erlbaum Associates, NJ.

The Mandarin, 22 July 2014, When push comes to shove: inside the NSW nudge unit, viewed 25 May 2015, <http://www.themandarin.com.au/874-nudge-unit/?pgnc=1>.

The Psych Report, 13 July 2014, Head of White House “Nudge Unit” Maya Shankar Speaks about Newly Formed Social and Behavioral Sciences Team, viewed 14 May 2015, <http://thepsychreport.com/current-events/head-of-white-house-nudge-unit-maya-shankar-speaks-about-newly-formed-us-social-and-behavioral-sciences-team/>.

Toffler, B.L. & Reingold, J. 2003, Final accounting: Ambition, greed and the fall of Arthur Andersen, Broadway Books, New York.

Tompkins, P. K. & Cheney, G. 1985, ‘Communication and unobtrusive control in contemporary organizations’, in R.D. McPhee & P.K. Tompkins (Eds.), Organizational communication: traditional themes and new directions, Newbury Park, CA, pp. 179-210.

Transparency International 2015, Corruption Perceptions Index 2014.

Transparency International 2000, Confronting Corruption: the elements of a national integrity system (TI Source Book), Transparency International, Berlin.

Transparency International, Frequently asked questions about corruption, viewed 3 June 2015, <https://www.transparency.org/whoweare/organisation/faqs_on_corruption/2/>.

Treviño, L.K. & Brown, M.E. 2004, ‘Managing to be ethical: Debunking five business ethics myths’, Academy of Management Executive, vol. 18, no. 2, pp. 69-83.

Treviño, L.K. & Weaver, G.R. 2003, Managing ethics in business organizations, Stanford Business Books, Stanford, CA.

Treviño, L.K. 1993, ‘The social effects of punishment: a justice perspective’, Academy of Management Review, vol. 17, no. 4, pp. 647—676.

65

Treviño, L.K., Brown, M. & Pincus-Hartman, L. 2003, ‘A qualitative investigation of perceived executive ethical leadership: perceptions from inside and outside the executive suite’, Human Relations, vol. 56, no. 1, pp. 5-37.

Treviño, L.K., Hartman, L.P. & Brown, M. 2000, ‘Moral person and moral manager: how executives develop a reputation for ethical leadership’, California Management Review, vol. 42, no. 4, pp. 128-142.

Treviño, L.K., Weaver, G.R., Gibson, D.G. & Toffler, B.L. 1999, ‘Managing ethics and legal compliance: what works and what hurts’, California Management Review, vol. 41, no. 2, pp. 131-151.

Treviño, L.K., Weaver, G.R. & Reynolds, S.J. 2006, ‘Behavioral ethics in organisations: a review’, Journal of Management, vol. 32, no. 6, pp. 951-990.

Tskalikis, J. & Fritche, D. 1989, ‘Business ethics: a literature review with a focus on marketing ethics’, Journal of Business Ethics, vol. 8, no. 9, pp. 695–743.

Tyler, K. 2005, ‘Do the right thing: ethics education programs help employees deal with ethical dilemmas’, HR Magazine, vol. 50, no. 2.

Valdesolo, P. & DeSteno, D. (2007). ‘Moral hypocrisy: social groups and the flexibility of virtue’, Psychological Science, vol. 18, no. 8, pp. 689–690.

Vanberg, C. 2008, ‘Why do people keep their promises? An experimental test of tow explanations’, Econometrica, vol. 76, no. 6, pp. 1467-1480.

Victoria Government 2011, Independent Broad-based Anti-corruption Commission Act.

Waldersee, R. 2013, Efficiency and Effectiveness as an anti-corruption control, presentation to the 2013 Australian Public Sector Anti-Corruption Conference, Sydney, viewed on 6 May 2015, <https://www2.iceaustralia.com/ei/images/APSACC13/ppt/Dr%20Robert%20Waldersee.pdf>.

Walker, L.J., Pitts, R.C., Hennig, K.H. & Matsuba, M.K. 1995, ‘Reasoning about morality and real-life moral problems’, in M. Killen & D. Hart (Eds.), Morality in everyday life: developmental perspectives, Cambridge University Press, UK, pp. 371-407.

Warburton, J. & Baker, G. 2005, ‘Integrity systems and local government’, Australian Journal of Public Administration, vol. 64, no. 2, pp. 62–68.

Weaver, G.R. & Treviño, L.K. 1999, ‘Compliance and values oriented ethics programs: influences on employees’ attitudes and behavior’, Business Ethics Quarterly, vol. 9, no. 2, pp. 315-337.

Weaver, G.R., Treviño, L.K. & Agle, B.R. 2005, ‘Somebody I look up to: ethical role modeling in organizations’, Organizational Dynamics, vol. 34, pp. 313-330.

Weaver, G.R., Treviño, L.K. & Cochran, P.L. 1999b, ‘Corporate ethics programs as control systems: Influences of executive commitment and environmental factors’, Academy of Management Journal, vol. 42, no. 1, pp. 539-552.

Weaver, G.R. & Treviño, L.K. 1999, ‘Compliance and values oriented ethics programs: influences on employees’ attitudes and behaviour’, Business Ethics Quarterly, vol. 9, no. 2, pp. 315-335.

66

Weaver, G.R. 2006, ‘Virtue in organisations: moral identity as a foundation for moral agency’, Organisation Studies, vol. 27, no. 3, pp. 341-368.

Weaver, G.R., Treviño, L.K. & Agle, B. 2005, ‘Somebody I look up to: ethical role models in organisations’, Organisation Dynamics, vol. 34, no. 4, pp. 313-330.

Weaver, G.R., Treviño, L.K. & Cochrane, P.L. 1999, ‘Integrated and decoupled corporate social performance: management commitments, external pressures and corporate ethics practices’, Academy of Management Journal, vol. 42, no. 1, pp. 41-57.

Weber, M. 1947, The theory of social and economic organization, Free Press, Glencoe.

Weber, J. 1995, ‘Influences upon organizational ethical subclimates: a multidepartmental analysis of a single firm’, Organization Science, vol. 6, no. 5, pp. 509-523.

Webley, S. & Werner, A. 2008, ‘Corporate codes of ethics: necessary but not sufficient’, Business Ethics European Review, vol. 17, no. 4, pp. 405-415.

Wenzel, M. 2004, ‘The social side of sanctions: personal and social norms as moderators of deterrence’, Law and Human Behavior, vol. 28, no 5, p. 547.

Western Australia Government 2003, Corruption and Crime Commission Act.

Wheeler, S., Weisburd, D., Waring, E. & Bode, N. 1988, ‘White collar crimes and criminals’, American Criminal Law Review, vol. 25, pp. 331-357.

Wilding, R.W.L. 1979, ‘The professional ethic of the administrator’, Management Services in Government, vol. 34, no. 4, pp. 181-186.

Williams, D. 1999, ‘Constructing the economics space: the World Bank and the making of homo oeconomicus’, Millennium: Journal of International Studies, vol. 28, no. 1, pp. 79-99.

World Bank 2015, ‘When corruption is the norm’, World Development Report 2015

World Bank 1997, Helping countries combat corruption: the role of the World Bank, p.8.

World Bank, 6 February 2007, World Bank Continues Leadership In Fight Against Corruption, Report Shows, Media Release, viewed 6 May 2015, <http://web.worldbank.org/WBSITE/EXTERNAL/TOPICS/EXTGOVANTICORR/0,,contentMDK:21205078~isCURL:Y~menuPK:3036107~pagePK:64020865~piPK:149114~theSitePK:3035864,00.html>.

World Economic Forum 2014, Clean business is good business, in partnership with Transparency International, United Nations Global Compact, International Chamber of Commerce, viewed 6 March 2015, <http://www.weforum.org/pdf/paci/BusinessCaseAgainstCorruption.pdf>.

Wright, B.M. & Barker, J.R. 2000, ‘Assessing concertive control in the team environment’, Journal of Occupational and Organizational Psychology, vol. 73, no. 3, pp. 345–361.

Yahoo! News, 27 February 2015, CCC warns of council corruption, viewed 10 March 2015, <https://au.news.yahoo.com/thewest/a/26450196/ccc-warns-of-council-corruption/>.

67

Zey-Ferrell, M. & Ferrell, O.C. 1982, ‘Role-set configuration and opportunity as predictors of unethical behaviour in organizations’, Human Relations, vol. 35, no. 7, pp. 587-604.

Zimbardo, P.G. 2006, The Lucifer Effect: Understanding how good people turn evil, viewed on 9 May 2015, <http://www.lucifereffect.com/about_synopsis.htm>.

Zimbardo, P.G. 2004, ‘A situationist perspective on the psychology of evil: understanding how good people are transformed into perpetrators’, in A.G. Miller (Ed.), The social psychology and good and evil, Guildford Press, New York, pp. 21-50.

Zimmerman, B.J. & Rosenthal, T.L. 1974, ‘Observational learning of rule-governed behavior by children’, Psychological Bulletin, vol. 81, no. 1, pp. 29-42.

Zipparo, L. 1998, Ethics: the key to good management, NSW Independent Commission Against Corruption Research Report, NSW Independent Commission Against Corruption.

68

Appendices

Appendix 1

PROJECT INFORMATION SHEET – TEST GROUP 1

Project Information Sheet

You are invited to participate in the research project: Is Honesty Contagious? Public Policy versus

Behavioural Science in anti-corruption efforts in New South Wales Local Government being

conducted by the Centre for Local Government of the University of Technology, Sydney.

Purpose of Research

The purpose of the research is to assess whether Codes of Conduct and other policies aimed at

influencing staff behaviour have been effective and to analyse the experience of Councils in

implementing alternative and additional values-based training solutions concentrating on

organisational culture.

In essence, the project seeks to shed some light on whether laws and regulations (policy) OR people

(behaviour) make the biggest difference in influencing employees’ ethical choices and (perhaps

more interestingly) what is the relationship between the two?

This is an independent research study, and as such, the findings will be used to inform policy and

regulatory design and will NOT be used for any legal or investigative purposes.

Please note this research only concentrates on Council staff and does not involve elected members.

Researcher

My name is Tommaso Briscese and I am a student in the Master of Local Government at the Centre

for Local Government of the University of Technology, Sydney.

For the purpose of integrity, I wish to disclose that I am also a full-time employee of a Council in New

South Wales, where I am employed in the capacity of Executive Manager / Internal Ombudsman.

69

The Council in which I currently work is specifically excluded from the sample of councils chosen for

this research to avoid any potential bias.

Your participation

Your participation will involve a written response to the following questions:

1. At the time of the ICAC inquiry affecting your Council in [date], did your organisation have in

place a Code of Conduct or similar policies regulating the behaviour of their staff [list: e.g.

Secondary employment policy, internal reporting policy etc.]?

2. In the two years prior to the ICAC inquiry affecting your council in [date], did you

organisation promote a program of training for staff on Code of Conduct or similar policies?

3. Following the ICAC inquiry, did your organisation:

Change its policies? (new ones, reviewed existing ones etc.)

Changed its training programs on Code of Conduct?

Introduced ethics training?

Other

Responses to the above questions can be provided via email to the researcher.

You can contact me via email on tom.briscese@gmail.com or 0411 017 383 if you have any concerns

about the research or questions about the project. You are also free to withdraw your participation

from this research project at any time without giving a reason.

Anonymity

The research data gathered from this project may be published in a form that does not identify

participants in any way.

Note: Studies undertaken by the Centre for Local Government and Australian Centre of Excellence for Local Government have been granted program approval by the University of Technology, Sydney, Human Research Ethics Committee. If you have any complaints or reservations about any aspect of your participation in this research you may contact the lead researcher, Mr Tommaso Briscese: tom.briscese@gmail.com (0411017383), the research coordinator, Dr Bligh Grant: bligh.grant@uts.edu.au (9514 4901) or the UTS Ethics Committee through the Research Ethics Officer (tel: 02 9514-9772). Any complaint you make will be treated in confidence and investigated fully and you will be informed of the outcome.

70

Appendix 2

PROJECT INFORMATION SHEET – TEST GROUP 2

Project Information Sheet

You are invited to participate in the research project: Is Honesty Contagious? Public Policy versus

Behavioural Science in anti-corruption efforts in New South Wales Local Government being

conducted by the Centre for Local Government of the University of Technology, Sydney.

Purpose of Research

The purpose of the research is to assess whether Codes of Conduct and other policies aimed at

influencing staff behaviour have been effective and to analyse the experience of Councils in

implementing alternative and additional values-based training solutions concentrating on

organisational culture.

In essence, the project seeks to shed some light on whether laws and regulations (policy) OR people

(behaviour) make the biggest difference in influencing employees’ ethical choices and (perhaps

more interestingly) what is the relationship between the two?

This is an independent research study, and as such, the findings will be used to inform policy and

regulatory design and will NOT be used for any legal or investigative purposes.

Please note this research only concentrates on Council staff and does not involve elected members.

Researcher

My name is Tommaso Briscese and I am a student in the Master of Local Government at the Centre

for Local Government of the University of Technology, Sydney.

For the purpose of integrity, I wish to disclose that I am also a full-time employee of a Council in New

South Wales, where I am employed in the capacity of Executive Manager / Internal Ombudsman.

The Council in which I currently work is specifically excluded from the sample of councils chosen for

this research to avoid any potential bias.

71

Your participation

Your participation will involve responding to a questionnaire either through a face-to-face interview

or via email, regarding the following topics:

1. Experience of your council with implementation of organisational culture and ethics

programs

2. Values-based staff training programs

3. Measuring the success of ethics and cultural programs

It is expected that the interview/questionnaire will take approximately 30 minutes to complete.

You can contact me via email on tom.briscese@gmail.com or on 0411 017 383 if you have any

concerns about the research or questions about the project. You are also free to withdraw your

participation from this research project at any time without giving a reason.

Anonymity

The research data gathered from this project may be published in a form that does not identify

participants in any way.

Note: Studies undertaken by the Centre for Local Government and Australian Centre of Excellence for Local Government have been granted program approval by the University of Technology, Sydney, Human Research Ethics Committee. If you have any complaints or reservations about any aspect of your participation in this research you may contact the lead researcher, Mr Tommaso Briscese: tom.briscese@gmail.com (0411017383), the research coordinator, Dr Bligh Grant: bligh.grant@uts.edu.au (9514 4901) or the UTS Ethics Committee through the Research Ethics Officer (tel: 02 9514-9772). Any complaint you make will be treated in confidence and investigated fully and you will be informed of the outcome.

72

Appendix 3

ICAC: PUBLIC INVESTIGATIONS AND INQUIRIES INTO LOCAL GOVERNMENT (1989-2014)

Local Government Investigation Investigation

Date Subject

Ryde City Council Allegations concerning the City of Ryde Mayor, Councillor Ivan Petch (Operation Cavill)

2014 Politician

Auburn City Council Allegations concerning councillor and developer (Operation Barrow)

2012 Politician

Willoughby City Council Alleged corrupt conduct of Council employee (Operation Churchill)

2011 Officer

Strathfield Council Allegation of corrupt conduct involving Community Services Manager (Operation Danby)

2011 Officer

Burwood Council Allegations of corrupt conduct involving the General Manager and other staff (Operation Magnus)

2011 Officer

Canada Bay City Council Allegations of corrupt conduct concerning City Services Manager (Operation Challenger)

2010 Officer

Woollahra Municipal Council Allegations of corrupt conduct involving offer of payment to the Council (Operation Avoca)

2010 Officer

Strathfield Council Offer of a corrupt payment to a Council officer (Operation Centurion)

2010 Officer

Warringah Council Attempts to improperly influence building inspection approval (Operation Bauer)

2009 Officer

Ku-ring-gai Council Attempts to improperly influence a council officer (Operation Capella)

2009 Officer

Wollongong City Council Allegations of corrupt conduct in relation to development applications, approvals and other matters (Operation Atlas)

2008 Officer

Wollongong City Council Allegations of bribery (Operation Berna) 2007 Officer

Bankstown & Strathfield Councils

Corrupt manipulation of contract procurement (Operation Torrens)

2007 Officer

Parramatta City Council Corrupt conduct associated with regulation of brothels (Operation Pelion)

2007 Officer

Burwood Council Conduct of two Burwood councillors (Operation Odin)

2006 Politician

Liverpool City Council / NSW Parliament

Orange Grove Centre (Operation Sirius) 2005 Politician

Strathfield Municipal Council Allegations of bribery (Operation Cordoba) 2005 Politician

73

Local Government Investigation Investigation

Date Subject

Liverpool City Council Proposed development at Woodward Park 2003 Officer

Rockdale City Council Corrupt conduct associated with development proposals

2002 Politician

Liverpool City Council Conduct of garbage contractors 2001 Officer

South Sydney Council Administration and auditing of cleaning contracts

2000 Officer

Liverpool City Council Conduct of former purchasing officer 1999 Officer

Sydney City Council Bribery in relation to the use of weighbridges at St Peters and elsewhere

1999 Officer

Fairfield City Council Conduct of an Alderman in relation to development applications

1998 Politician

Lane Cove Council, Holroyd City Council and Fairfield City Council

Conduct of council officers and others in relation to property developments

1997 Officer

Byron Shire Council Circumstances surrounding the adoption of the 1993 Byron Residential Development Strategy and other matters

1997 Officer

Randwick City Council Development control decisions and relationships between councillors, council officers and developers

1995 Politician

Coffs Harbour City Council Dealings of an Alderman with developers 1993 Politician

Maitland City Council Former Council member's dealings with a property developer

1992 Politician

South Sydney Council Development and building applications, referrals and work for private clients

1991 Officer

Waverley Council Employee's relationship with Dainford Ltd and associated companies

1991 Officer

Tweed Shire Council North Coast land development 1990 Politician

Sydney City Council Alleged bribery to facilitate development approval for Park Plaza site

1989 Politician

74

Appendix 4

ADITIONAL SELECTION CRITERIA FOR TEST GROUP 2 Promoting Better Practice The NSW Office of Local Government’s Promoting Better Practice program aims to assist in

strengthening the local government sector by assessing council performance, promoting continuous

improvement, facilitating self-assessment, and sharing better practice.

Promoting better practice includes:

working with councils to identify, share and promote better practice with an emphasis on:

- strategic community planning

- efficient and effective service delivery

- quality governance and ethical conduct

- financial sustainability.

working cooperatively with councils to promote strong relationships within the sector.

providing councils with feedback on areas requiring improvement or further development, and

assisting them in developing solutions.

identifying trends and issues arising from council reviews to support policy and legislative

changes for the local government sector.

encouraging and facilitating innovation by responding creatively to identified trends and

issues.

The three councils analysed in this study participated in a Promoting Better Practice Review as

follows:

Council 1 Council 2 Council 3

Promoting Better

Practice Review

2013

2007

2013

Source: NSW Office of Local Government (2015)

T-Corp’s assessment of NSW Local Government’s sustainability (2013)

The NSW Treasury Corporation (known as TCorp) is the central borrowing authority for the State of

New South Wales. TCorp's principal objective is to provide financial services for, or for the benefit of,

75

the NSW government and NSW public authorities. In December 2011, the Office of Local

Government appointed TCorp to undertake a financial assessment for each council seeking

assistance under the Local Infrastructure Renewal Scheme. Following the announcement by the

Minister for Local Government in March 2012 of the establishment of the Independent Local

Government Review Panel, the scope of TCorp's work was expanded to include a financial

sustainability and benchmarking assessment of all 152 NSW general purpose councils. The report

was released in April 2013.

The report included a Financial Sustainability Rating (FSR) for each Council, ranging from Very Strong

to Distressed. Tcorp described an FSR level of Moderate or higher as exceeding the benchmark and

acceptable in terms of sustainability. The three councils analysed in this study were rated as follows:

Council 1 Council 2 Council 3

T-Corp Financial Status

(2013)

Sound Moderate Sound

Source: NSW Office of Local Government (2015)

76

Appendix 5

QUESTIONNAIRE - TEST GROUP 1

Research Questions

Is Honesty Contagious? Public Policy versus Behavioural Science in anti-corruption efforts in New

South Wales Local Government

Research project by Tommaso Briscese, for University of Technology Sydney, Centre for Local

Government

4. At the time of the ICAC inquiry affecting your Council in [date], did your organisation have in place a Code of Conduct or similar policies regulating the behaviour of their staff [list: e.g. Secondary employment policy, internal reporting policy or similar. Please list]?

5. In the two years prior to the ICAC inquiry affecting your council in [date], did your organisation promote a program of training for staff on Code of Conduct or similar policies?

6. Following the ICAC inquiry, did your organisation:

Change its policies? (new ones, reviewed existing ones etc.)

Changed its training programs on Code of Conduct?

Introduced ethics training?

Other

Responses to the above questions can be provided via email to the researcher.

You can contact me via email on tom.briscese@gmail.com or on 0411 017 383 if you have any

concerns about the research or questions about the project. You are also free to withdraw your

participation from this research project at any time without giving a reason.

Anonymity

The research data gathered from this project may be published in a form that does not identify

participants in any way.

Note: Studies undertaken by the Centre for Local Government and Australian Centre of Excellence for Local Government have been granted program approval by the University of Technology, Sydney, Human Research Ethics Committee. If you have any complaints or reservations about any aspect of your participation in this research you may contact the lead researcher, Mr Tommaso Briscese: tom.briscese@gmail.com (0411017383), the research coordinator, Dr Bligh Grant: bligh.grant@uts.edu.au (9514 4901) or the UTS Ethics Committee through the Research Ethics Officer (tel: 02 9514-9772). Any complaint you make will be treated in confidence and investigated fully and you will be informed of the outcome.

77

Appendix 6

QUESTIONNAIRE - TEST GROUP 2

Research Questions Is Honesty Contagious? Public Policy versus Behavioural Science in anti-corruption efforts in New

South Wales Local Government

Research project by Tommaso Briscese, for University of Technology Sydney, Centre for Local

Government

1. Does your Council have a set of corporate values?

2. Would you consider your Council a values-driven organisation?

3. How are the corporate values implemented within the organisation?

4. Do you provide training on corruption and fraud prevention and Code of Conduct training to staff? If yes, please specify frequency

5. Is ethical behaviour promoted in the organisation?

6. What methods do you use to promote ethics?

7. Do you include ethics in the annual report and in your IPR documents?

8. Do you include ethics in induction material for new staff and in leadership/management

courses?

9. Do you have a dedicated hotline or email for people to report misconduct anonymously?

10. Do you recognise / reward ethical behaviour amongst staff? How?

11. Do you have ethics “champions” within the organisation and would staff know who they are?

12. Do you believe staff would seek advice from their “champion” colleagues?

13. Do you take action against unethical behaviour and are these actions communicated to staff?

14. Why are you implementing these strategies?

15. Have these measures been successful in your opinion? How?

16. In summary, in your professional opinion, what strategy is more effective in building an ethical and honest organisation: a compliance driven system or an organisational culture system? Or both? Or neither? Why?

78

Responses to the above questions can be provided via email to the researcher.

You can contact me via email on tom.briscese@gmail.com or on 0411 017 383 if you have any

concerns about the research or questions about the project. You are also free to withdraw your

participation from this research project at any time without giving a reason.

Anonymity

The research data gathered from this project may be published in a form that does not identify

participants in any way.

Note: Studies undertaken by the Centre for Local Government and Australian Centre of Excellence for Local Government have been granted program approval by the University of Technology, Sydney, Human Research Ethics Committee. If you have any complaints or reservations about any aspect of your participation in this research you may contact the lead researcher, Mr Tommaso Briscese: tom.briscese@gmail.com (0411017383), the research coordinator, Dr Bligh Grant: bligh.grant@uts.edu.au (9514 4901) or the UTS Ethics Committee through the Research Ethics Officer (tel: 02 9514-9772). Any complaint you make will be treated in confidence and investigated fully and you will be informed of the outcome.

79

Appendix 7

ETHICS APPROVAL

Given the sensitive topic of this research and the expected reluctance of local government

organisations about discussing corrupt conduct within their workforce, careful consideration was

given to the scope and confidentiality of the study.

Firstly, it was agreed that the research would only concentrate on Council staff and not involve

elected members. It would also be based on data about ICAC inquiries and investigations made

available to the public, therefore mitigating the potentially sensitive issues relating to sharing

confidential information.

Secondly, it would be clearly presented as an independent research study, and as such, the findings

will be used to inform policy and regulatory design and will not be used for any legal or investigative

purposes (see Appendices 1 and 2) for Information Sheets distributed to participating councils).

In addition, it was believed necessary that the research data gathered from this project will be

collated in a form that does not identify participants in any way, so as to avoid labelling and

stereotyping that might flow from the unpredictable nature of the findings.

In order to respect internal processes of enquiry on such a sensitive topic, the approach to selected

councils was undertaken by writing directly to the General Managers, and offered the opportunity to

discuss the scope and the implications of the study with the researcher.

Further, the researcher disclosed his employment at a Council in New South Wales in the capacity of

Executive Manager / Internal Ombudsman, and it was agreed that the Council in which he works be

specifically excluded from the sample of councils chosen for the research to avoid any potential bias.

Having addressed all the above considerations, a final research proposal complete with information

sheets and consent forms was submitted to the UTS-CLG Ethics Officer and the Research

Coordinator for review, with approval granted on 17 April 2015.