Self-disclosure and reporting processes
Require and support staff and third parties to self-disclose gifts, benefits, incidents, mistakes and real or perceived conflicts of interest.
Why this countermeasure matters
Lack of self-disclosure and reporting processes may lead to:
- staff and third parties failing to self-disclose gifts, benefits, incidents, mistakes and real or perceived conflicts of interest
- fraudulent conduct, dishonest influences or coercion
- staff and contractors being coerced to commit fraud for the benefit of another person or entity.
How you might apply this countermeasure
Some ways to implement this countermeasure include:
- requiring staff to declare conflicts of interest
- creating a process for staff to self-report accidental unauthorised accesses or disclosures
- creating a register for staff to self-report gifts and benefits
- requiring staff or contractors to self-report when their circumstances change, such as to maintain a security clearance
- immunity for self-disclosure of cartel or group conduct.
How to check if your countermeasures are effective
Here are some ways to measure the effectiveness of this type of countermeasure:
- confirm policy and guidance material exists for self-disclosure or self-reporting.
- confirm guidance material is available and easy to access.
- review guidance material to make sure it is clear and easy to understand.
- confirm guidance material and processes align with policy and legislation such as the Public Governance, Performance and Accountability Act 2013.
- ask staff about the forms, processes or systems to make sure they have a consistent understanding of how to use them.
- analyse the use of registers such as conflict of interest registers or inadvertent access registers.