This is the first in our three-part blog series exploring key takeaways from guidance materials released by IBAC in March this year. This opening post focuses on Culture, Conduct, and Corruption.

Organisational culture is a powerful yet often underestimated driver in reducing corruption. IBAC’s latest integrity scenarios reinforce the importance of embedding an organisation-wide culture of integrity.

• IBAC’s guidance about bullying and harassment as a driver of corruption highlights how misconduct can escalate into corruption and the importance of early intervention.
• IBAC’s guidance about improper use of confidential information for personal gain highlights  the importance of ethics training and a strong speak-up culture.
• IBAC’s guidance about gifts and benefits highlights how small influences can undermine impartial decision-making in the public sector.

When culture silences integrity

One of the strongest themes in IBAC’s guidance is the connection between bullying, harassment and corruption risks. In environments where staff feel intimidated, excluded or fearful of repercussions, individuals are far less likely to raise concerns about improper conduct.

IBAC’s scenario demonstrates how bullying can contribute to poor decision-making, reduced oversight and a breakdown in accountability. Staff may avoid escalating concerns, challenging inappropriate behaviour or questioning decisions made by senior personnel. The guidance also highlights how ineffective complaints processes and limited confidence in reporting systems can enable misconduct to continue unchecked.

Importantly, the corruption risk is not always the bullying behaviour itself. Rather, it is the culture of silence and fear that develops around it. Over time, unchecked behaviour may embolden individuals to misuse authority, manipulate decision-making processes or pressure staff into unethical conduct.

Lessons learned

The scenario highlights several practical considerations for organisations:

• Increase awareness of reporting mechanisms through regular team communications and meetings, making sure all staff understand how to report unethical behaviour.
• Educate staff to recognise behavioural indicators of potential misconduct, whether displayed by the bully or those around them, such as sudden changes in behaviour, unexplained absences, or inconsistent performance. These signs can help identify problems before they escalate.
• Regularly assess staff morale and the work environment through informal feedback mechanisms to identify and address emerging issues early.
• Organisations should regularly review whether integrity risks are being considered through a cultural lens, not solely through compliance processes.

The guidance also reinforces the importance of robust recruitment and pre-employment screening processes, including appropriate background and conduct checks.

Gifts, benefits and hospitality

IBAC discusses the slow creep that gifts, benefits, and hospitality can have on relationships and their influence over decision-making. While some gifts may appear low-risk or customary, repeated hospitality, informal benefits or preferential treatment can create perceived obligations and affect decision-making.

Importantly, corruption risks often emerge gradually through relationships and expectations, rather than through overt misconduct. The scenario serves as a reminder that integrity frameworks should address both actual and perceived conflicts.

Lessons learned

Key takeaways for organisations include:

• Create clear policies on accepting gifts, benefits and hospitality to ensure staff understand the potential influence these can have on their decisions.
• Introduce mandatory reporting and approval processes for any gifts or hospitality received to prevent conflicts of interest and maintain transparency.
• Encourage collaboration and input from multiple stakeholders when making procurement decisions to ensure balanced and well-rounded decisions.

Confidentiality and speak-up culture

IBAC’s scenario involving confidential information highlights a long-standing integrity risk. Staff  may have access to commercially sensitive information, procurement data, personal information or privileged government insights. Risks arise where that information is used improperly to benefit individuals, associates or external organisations.

The scenario demonstrates that misuse of information can occur in both obvious and subtle ways.

Lessons learned

The guidance reinforces several important principles:

• Update confidentiality policies to include specific guidelines for handling digital information and insider knowledge.
• Strengthen protections for whistleblowers to ensure that individuals feel safe and supported when reporting misconduct.
• Increase transparency in planning and other decision making processes by regularly sharing summaries of decisions and the reasons behind them to build community trust.
• Conduct regular ethics training, including surrounding misuse of information, to ensure staff are informed, prepared and empowered to report misconduct if observed.

Conclusion

Public sector integrity relies heavily on maintaining community confidence. Even where conduct is technically permissible, reputational risks may still arise.

Culture and conduct are integral to the fight against corruption. The strongest integrity systems identify risks early, encourage open dialogue, and create environments where ethical conduct is actively supported. As IBAC’s scenario demonstrate, unresolved behavioural issues can escalate into broader integrity, workforce, and reputational risks when left unaddressed.

Resources (IBAC)

• Integrity scenario: bullying and harassment as a driver of corruption
• Integrity scenario: accepting gifts and the cost to integrity
• Integrity scenario: improper use of confidential information for personal gain

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CourtHeath acknowledges the Traditional Aboriginal Owners of Country throughout Victoria and pays respect to Elders past and present, and to the ongoing living culture of Aboriginal people.

A participant in the UN Global Compact, CourtHeath seeks to raise awareness about the sustainable development goals and the principles of the Global Compact with business and government organisations in Victoria.

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