Integrity
Developing and maintaining a culture committed to ethical, behaviour and compliance with the law.
Our Values and Code of Conduct
Our Code of Conduct has been updated from 18 pages to 3 concise pages, to assist staff and understand behaviour expected of them. Critical subjects remain the same, with a focus on seven key conduct areas. The revision aligns the Code of Conduct with our strategic direction Keeping WA Moving and Public Sector Commission requirements. It also achieves closer alignment across the Transport Portfolio.
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 a range of committees.
Each Directorate’s business plan is linked to the Keeping WA Moving and Corporate Business Plan. 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 online Scorecard. The Accountable and Ethical Decision- Making training course is compulsory for all new employees and is delivered via e-learning.
Corruption Prevention
We have strategies in place to prevent the misappropriation of funds and inappropriate use of public property that include a comprehensive Annual Audit Plan that provides a balanced mix of financial, operational and information technology audits. In addition, Risk Management is considered an integral part of the annual business planning. Risks are managed and monitored at all levels.
We have also deployed a Fraud and Corruption Control Plan and a Fraud and Corruption Policy, which together clearly set out the relevant policies and obligations for all employees with respect to preventing, mitigating and reporting instances of fraud and corruption. These documents are available to all employees via the iRoads intranet site.
Conflicts of Interest and Acceptance of Gifts and Benefits
Our Code of Conduct requires all employees to ensure our personal, financial and political interests do not conflict with our performance or ability to perform in an impartial manner. Where a conflict of interest occurs, it should always be resolved in favour of the public interest rather than personal interest. We also have a Conflict of Interest and Gifts and Benefits Policy and Register, maintained by the Manager Legal and Insurance Services. We consider conflict of interest to include:
- decisions that are biased as a result of outside activities or private employment
- outside activities that result in less than satisfactory work performance or cause breaches of standards such as those relating to occupational safety and health
- information gained from official employment that is used for private gain
- government resources that are used for private gain
- government time that is used to pursue private interests
- acceptance of gift or benefits
- disclosure of confidential information obtained during the course of duty
- breach of ethics
- granting/receiving favours for political, status, relationship, personal or business advantage
- actions jeopardising government and Main Roads policies and procedures
- actions which place Main Roads at risk.
Each Corporate Executive member signs a representation memorandum addressed to the Managing Director which includes a section on personal interests in our 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 us during the financial year.
Our Conflict of Interest and Gifts and Benefits Policy states that Main Roads 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.
Where a Conflict of Interest (whether actual, potential or perceived) has been identified strict procedures including declaration to the Manager Legal and Insurance Services must be followed.
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 undertaken 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.
Compliance with Public Sector Standards and Ethical Codes
There were no compliance issues that arose during the year regarding the Public Sector Standards. 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.
Ethical Procurement
Our procurement policies and procedures comply with the requirements of the State Supply Commission and are certified to AS/NZS 9001:2008. Policies are documented in the Procurement Management Manual and all tendering and contract administration procedures are documented in the Tendering and Contract Administration Manual. An ongoing compliance program ensures these policies and procedures are implemented.
A Tender Committee, with two of our experienced senior officers and two senior external government officials, provides additional assurance that procurement actions comply with policies and standards for high-risk and potentially contentious procurements.
Procurement Grievances
No grievances were received during the past year, indicating our procurement processes continue to be fair and equitable. A procedure for dealing with procurement grievances is referenced in all tender documents and a copy is accessible from our website. The procedure has been 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, should they be lodged by contractors. The table below lists our Top 10 major suppliers or contractors and their award value over the past year.
| Major Suppliers/Contractors | 2015-16 Awards Value (GST excl) |
|---|---|
| John Holland Pty Ltd | $176.1 |
| Georgiou Group Pty Ltd | $66.4 |
| McConnell Dowell Constructors Pty Ltd | $27.4 |
| Brierty Limited | $22.0 |
| York Civil Pty Ltd | $21.3 |
| BMD Constructions Pty Ltd | $17.7 |
| Decmil Australia Pty Ltd | $14.0 |
| Watpac Civil & Mining Pty Ltd | $13.7 |
| Highway Construction/Albem Operations JV | $10.1 |
| MACA Civil Pty Ltd | $9.1 |
We engage with a large number of suppliers of varying characteristics. In total over the last financial year we engaged directly with 1,216 suppliers and made in the order of $1.54 billion in payments. Suppliers consisted of:
- 142 government agencies
- 10 research bodies or universities
- 1,064 classified as contractors.
However, our indirect supply chain is far more extensive. This can be evidenced by the characteristics of major projects such as Gateway WA where this project alone engaged with 489 Contractors and 424 Suppliers.
Unauthorised Use of Credit Cards
We hold 321 corporate credit cards with transactions reviewed for personal use by incurring and certifying officers during statement processing.
In 2016 four cardholders had personal expenditure, all identified by the cardholder prior to the official review. Two instances occurred due to inadvertent use of the corporate card instead of their personal card. The other two due to EFTPOS machines selecting the card while still in the cardholder’s wallet or bag. As all are apparently genuine errors no disciplinary action has been taken. Each officer reimbursed the money within five days of identifying the error.
- Aggregate amount of personal use expenditure for the reporting period $107.73
- Aggregate amount of personal use expenditure settled by the due date $107.73
- Aggregate amount of personal use expenditure after the period $0.00
- Aggregate amount of personal use expenditure outstanding at balance date $0.00.
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. Any relevant Pricing Policies we set are developed in accordance with the Department of Treasury’s Costing and Pricing Government Services Guidelines.
Government Building Training Policy
State Government Building and Construction Contracts
| Measure | Number |
|---|---|
| Active contracts within the scope of the GBT Policy in the reporting period | 2 |
| Contracts granted a variation to the target training rate in the reporting period | 0 |
| Head contractors involved in the contracts | 2 |
| Construction apprentices/trainees required to meet target training rate across all contracts | 38 |
| Construction apprentices/trainees employed by head contractors and the subcontractors they are using for the contracts | 41 |
| Contracts which met or exceed the target training rate | 1 |
State Government Maintenance Contracts
The new policy, effective from 1 October 2015, has not been applied retrospectively to our maintenance contracts (Integrated Services Arrangements), which were implemented during 2010 and 2011. Whilst the Policy includes an option for agencies to consider transitioning existing contracts to the new Policy, it has not been deemed necessary with replacement contracts being implemented over the next two years. The new contracts will apply the policy.
Expenditure on Advertising, Marketing Research, Polling and Direct Mail (Electoral Act 1907)
| STATEMENT OF EXPENDITURE REQUIRED UNDER SECTION 175ZE OF THE ELECTORAL ACT 1907 | |||
|---|---|---|---|
| In accordance with Section 175ZE of the Electoral Act 1907, Main Roads Western Australia incurred $1,291,300 during 2015-16 in advertising, market research, polling, direct mail and media advertising. Expenditure was incurred in the following areas: | |||
| ADVERTISING AGENCIES | $ | DIRECT MAIL ORGANISATIONS | $ |
| 303 Mullenlowe Group Pty Ltd | 315,900 | Lasermail Pty Ltd | 4,100 |
| A Team Printing Pty Ltd | 600 | Direct Mail Organisations Total | 4,100 |
| Adcorp Australia Ltd | 106,500 | ||
| Albany Chamber Of Commerce | 3,700 | MARKET RESEARCH ORGANISATIONS | $ |
| Daniels Printing Craft | 16,100 | Hatchd Digital | 18,100 |
| Executive Media Pty Ltd | 4,000 | Metrix Consulting Pty Ltd | 44,000 |
| Expo Document | 1,800 | Painted Dog Research Pty Ltd | 7,000 |
| Icon Illustration | 5,100 | Market Research Organisations Total | 69,100 |
| 13,200 | |||
| Linkletters | 10,800 | POLLING ORGANISATIONS | Nil |
| Litsupport Pty Ltd | 2,400 | ||
| Picasso Print And Design | 4,000 | MEDIA ADVERTISING ORGANISATIONS | $ |
| Premiere Events | 3,500 | Angry Chicken Publishing Pty Ltd | 10,800 |
| Preservation Framers | 300 | Carat Australia Media Services Pty Ltd | 460,800 |
| Quality Press WA | 4,100 | Community Spirit Newspaper Inc. | 200 |
| Snap East Perth | 14,200 | 3,800 | |
| State Law Publisher | 4,400 | Hootesuite Media Inc. | 50 |
| The Brand Agency | 184,600 | Media Highway | 50 |
| Advertising Agencies Total | 695,200 | Minuteman Press Perth | 2,400 |
| Mitchell Communication Group Ltd | 2,900 | ||
| Optimum Media Decisions (WA) Ltd | 39,600 | ||
| Regional Publishers | 800 | ||
| Southern Cross Austereo | 1,500 | ||
| Media Advertising Organisations Total | 522,900 | ||
| Grand Total | 1,291,300 | ||