Integrity

Our Values and Code of Conduct

Our well-established Code of Conduct guides the way we work and establishes our responsibilities and standards of workplace behaviour. The Code builds upon the fundamental principles contained in the Public Sector Management Act 1994 and the Public Sector Commission, Commissioner’s Instruction No.7 – Code of Ethics which binds all Western Australian public sector employees. All of our employees are responsible for their own conduct and for their interactions with our customers, stakeholders, the community and with each other. Our Guiding Principles reflect our values and underpin the delivery of Keeping WA Moving. They look at how we operate as we work towards achieving our future direction.

Ethical and Responsible Decision-Making

To support ethical and responsible decision-making, Corporate Executive receives appropriate and timely information before meetings. This information includes status reports for each directorate, a Safety, Health and Wellbeing Status Report, financial management information and Quarterly Standing Reports for each sub-committee.

Each Directorate’s business plan is linked to the Corporate Business Plan and Keeping WA Moving. This coordinates our activities and aligns activities with our strategy. We report risk identification and management data quarterly and organisational performance information in a monthly KPI Scorecard. The Managing Director enters into a performance agreement with the Commissioner, and each member of Corporate Executive has an Individual Performance Agreement with the Managing Director, ensuring individual responsibility and accountability.

The Accountable and Ethical Decision-Making training course is compulsory for all new employees and is delivered via e-learning.

Corruption Prevention

Our strategies to prevent the misappropriation of funds and inappropriate use of public property include a comprehensive Annual Audit Plan that balances financial, operational and information technology audits. In addition, we consider Risk Management an integral part of annual business planning and manage and monitor risks at all levels.

Our Fraud and Corruption Control Plan and a Fraud and Corruption Policy set out the relevant policies and obligations for all employees with respect to preventing, mitigating and reporting instances of fraud and corruption within Main Roads. These documents are available to all employees on our intranet.

A current granular level assessment of all Main Roads business units will identify existing and potential risks of fraud and corruption and the controls in place, and will rate risks against an established risk matrix. Results will lead to a Fraud and Corruption Detection Program for implementation across the agency.

Conflicts of Interest

Our Code of Conduct requires all employees to ensure personal, financial and political interests do not conflict with performance or the ability to perform impartially. Any conflict of interest must be resolved in favour of the public interest rather than personal interest.

Our Conflict of Interest Policy and Register is maintained by the Manager Legal and Insurance Services. We consider a situation to reflect conflicts of interest when:

• decisions are biased as a result of outside activities or private employment
• outside activities result in a less than satisfactory work performance or breach standards such as those relating to occupational safety and health
• information gained from official employment is used for private gain
• Government resources are used for private gain
• Government time is used to pursue private interests
• gift or benefits are accepted
• confidential information obtained during the course of duty is disclosed
• ethics are breached
• favours are granted or received for political, status, relationship, personal or business advantage
• actions jeopardise Government and Main Roads policies and procedures
• actions place Main Roads at risk.

Each Corporate Executive member is required to sign a representation memorandum addressed to the Managing Director which includes a section on personal interests in Main Roads’ contracts. The Chief Finance Officer, Managing Director and Accountable Authority then sign a Management Representation letter to the Auditor General addressing various categories including Internal Controls and Risk Management.

Other than normal contracts of employment of service, no senior officers, firms of which senior officers are members, or entities in which senior officers have substantial interests, had any interests in existing or proposed contracts with Main Roads during the financial year.

Acceptance of Gifts and Benefits

Our Procurement Conflict of Interest and Gifts and Benefits Policy states that employees and Contract Personnel engaged by Main Roads must not:

• be influenced, or perceived to be influenced, by the offer or receipt of gifts or benefits
• engage in actions where a conflict of interest, or perceived conflict, arises in the course of their duty or contract obligations.

If a Conflict of Interest (whether actual, potential or perceived) is identified, full details are recorded in the Conflict of Interest Register and the Manager Supply and Transport notified as soon as practical, before the potential conflict can give rise to any material problem or concern.

We do not condone the acceptance of any gift, benefit or hospitality invitation, regardless of value. Employees should not accept offers of gifts, benefits or hospitality invitations from contractors, consultants or suppliers.

All gifts, benefits and hospitality invitations (regardless of value) must be declared in the Gifts and Benefits Register by the officer receiving the offer. The declaration should identify the relationship between the gift offered, the gift giver and the gift receiver.

The Gift and Benefits Register is maintained and reviewed by Manager Legal and Insurance Services.

Misconduct and Inappropriate Behaviour

All employees are expected to abide by the following:

• Public Sector Code of Ethics
• Main Roads Code of Conduct
• Main Roads Values
• Corruption and Crime Procedures and Guidelines

When a complaint or a report of alleged inappropriate behaviour or misconduct is received, management is required to take action through internal processes. An initial review of the information or complaint is done to understand the nature and severity of the alleged behaviour. The outcome of this review determines the most appropriate action which may include:

• discipline
• grievance resolution
• performance management
• Corruption and Crime Commission Procedures
• improvement actions

These processes may necessitate an investigation into the behaviour to enable a fair and equitable decision to be made on the outcomes.

Misconduct as defined by the Corruption and Crime Commission must be reported to the Commission.

Ethical Procurement

Our procurement policies and procedures comply with the requirements of the State Supply Commission and are certified to AS/NZS 9001:2015. Policies are documented in the Procurement Management Manual and all tendering and contract administration procedures are documented in the Tendering and Contract Administration Manual. A compliance program ensures these policies and procedures are implemented.

A Tender Committee, consisting of two senior internal officers and two senior external Government officials, provide additional assurance that procurement actions comply with policies and standards for high risk, potentially contentious procurements. In addition, we submit all procurement plans and tender recommendations for goods and services arrangements over $5 million for review and endorsement by the WA Government’s State Tender Review Committee.

Procurement Grievances

A procedure for dealing with procurement grievances is referenced in all tender documents and is accessible from our website. The procedure is endorsed by the Western Australian Road Construction and Maintenance Industry Advisory Group and provides for a customer-focused, fair, structured and relationship-based approach to reviewing grievances lodged by contractors.

During the year, two grievances were received and have since been closed out. The grievances did not highlight any common areas of concern. The low number of grievances, which represent less than 1% of all contracts awarded, is consistent with previous years and indicates that our procurement processes continue to be fair and equitable.

Major Suppliers

The table below lists our major suppliers/contractors and their award value.

Compliance with Public Sector Standards and Ethical Codes

Minimal compliance issues arose during the year regarding the Public Sector Standards, with only two against the Employment Standard and three against the Grievance Standard. All were either dismissed or resolved via conciliation. There were multiple discipline processes and disciplinary actions relating to breaches of the Code of Conduct and Public Sector Code of Ethics.

Steps to enhance processes to ensure compliance include:

• providing information about Public Sector Standards and Codes of Conduct on our intranet and in our induction material
• writing to applicants for recruitment, selection and appointment processes with details on how to access the Public Sector Standards
• ongoing training to recruitment and selection panel members to ensure compliance with relevant Public Sector Standards
• providing a network of Contact and Grievance Officers across the State
• reviewing and auditing all related policies, procedures and guidelines to ensure compliance with Public Sector Standards.

Pricing Policies of Services Provided

Our supply of goods and services represent works and services carried out for other public sector and private bodies on a cost recovery basis. Further details are available in the notes to the Financial Statements.