Additional Governance Disclosures

Delegation of Authority

Our Delegation of Authority Manual outlines administrative responsibilities for officers and their authority to carry out day-to-day tasks. The Delegation of Authority is in accordance with the amended Main Roads Act 1930 (WA) and the principle of public administration set out in section 7(d) of the Public Sector Management Act 1994. Employees are aware that delegation limits are specified in the Delegation of Authority Manual and that they must not be exceeded.

Ministerial Directives

There were no directives issued by the Minister for Transport under section 19(b) of the Main Roads Act 1930 (WA), as amended, during the year.

Freedom of Information

The Freedom of Information Act 1992 gives the public a general right to apply for access to documents held by government agencies. An information statement has been produced in accordance with the requirements of the Freedom of Information (FOI) Act and is available on our website. This statement provides a guide on how to apply for access to documents, as well as information about documents that may be available outside of the FOI process. During the year, we received 37 FOI applications.

FOI enquiries can be emailed to: foi@mainroads. wa.gov.au.

Integrity Framework

Main Roads’ Integrity Framework represents our commitment to effective fraud and corruption risk management and the promotion of a culture of integrity. The framework consolidates and clarifies policies and processes in relation to fraud and corruption, gifts and benefits, conflict of interest, lobbyists, and misconduct. Features of the Integrity Framework include biennial fraud and corruption risk workshops, a detection program, and increased transparency through a central fraud and corruption incident register. The framework was developed in a consultative fashion and is aligned with Australian Standard 8001. The Integrity Framework is available to all employees via the iRoads intranet site.

Corruption Prevention

We have detection activities and strategic controls in place to prevent the misappropriation of funds and inappropriate use of public property including a comprehensive Annual Audit Plan, Detection Plan and Fraud and Corruption Risk Management Cycle. Our Integrity Framework clearly sets out the relevant policies and obligations for all employees with respect to preventing, mitigating and reporting instances of fraud and corruption.

Conduct and Ethics

All employees are expected to abide by the Public Sector Code of Ethics, Main Roads’ Code of Conduct and Main Roads’ Values and Integrity Framework. When a complaint or a report of alleged inappropriate behaviour or misconduct is received, management is required to act by undertaking an initial review of the information or complaint. 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.

Customer Privacy

Main Roads, as with all Western Australian Government agencies, is not subject to the Privacy Act 1988 (Cwlth) and to date we do not have an equivalent statute. However, where possible, we adhere to the Australian Privacy Principles set out in Schedule 1 of the Privacy Act.

We value the privacy of our customers, however some of our activities may be of concern to them. These include the data or personal information we may collect through our website, communications, surveys, permits or through technologies deployed to the road network such as CCTV cameras or Bluetooth detectors.

Main Roads complies with the CCTV Usage Policy which outlines appropriate use of CCTV. The main purposes for this usage within our Road Network Operations Centre include traffic management, enforcement, engineering and safety and security.

The list of incidents and scenes that CCTV should not be used for viewing include private property, open public places, individuals’ faces and bodies, close up scenes where there are injured parties present (unless at the request of the Emergency Services), items involving personal identification or for personal purposes that do not support business activities. Main Roads does not automatically record its CCTV cameras but can do so in a limited way for training purposes or if requested by Emergency Services.

We also operate in accordance with the Surveillance Devices Regulations 1999. We use a commercially available off-the-shelf system to anonymously collect traffic data from Bluetooth-enabled devices in passing vehicles using sensors installed at signalised intersections and selected locations on freeways. The Media Access Control address collected from the sensors is replaced with randomly generated identification numbers, which is then used to derive travel times and monitor performance of the road network. This data cannot identify individual vehicles or people. Our external website has further information on our privacy policy.

Public Interest Disclosures

We are committed to the aims and objectives of the Public Interest Disclosure Act 2003. We recognise the value and importance of contributions by staff to enhance administrative and management practices and strongly support disclosures being made by staff regarding improper conduct. The Public Interest Disclosure Guidelines are available online for all staff.

Conflicts of Interest

Our Code of Conduct and Integrity Framework 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 consider conflict of interest to include:

• decisions that are biased, as a result of outside activities or private employment
• outside activities resulting in less than satisfactory work performance or causing breaches of standards such as those relating to occupational safety and health
• use of information for private gain when the information was acquired through official employment
• use of government resources for private gain
• use of government time to pursue private interests
• acceptance of gifts or benefits
• disclosure of confidential information obtained during the course of duty
• breach of ethics
• favours granted or received for advantage including political, status, relationship, personal or business advantage
• actions jeopardising government and Main Roads’ policies and procedures
• actions placing Main Roads at risk.

Each Corporate Executive member signs a representation memorandum addressed to the Managing Director including 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 categories including Internal Controls and Risk Management.

Other than usual 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.

Acceptance of Gifts and Benefits

Our Integrity Framework 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 (MLIS) must be adhered. We also have a Conflict of Interest and Gifts and Benefits register, maintained by the MLIS.

Business Continuity Management

The Public Sector Commissioner’s Circular 2015–03 and Treasurer’s Instruction 825 (Risk Management and Security) require agencies to ensure Business Continuity Plans are in place enabling the agency to respond to, and recover from, any business disruption. To ensure compliance, the Legal and Commercial Services branch works collaboratively across Main Roads to develop, maintain and test Business Continuity Action Plans. Business Continuity Management supports the values, principles and corporate focus of the agency’s Risk Management Policy.

Benefits include:

• increasing ability to minimise the consequences of any outage
• ensuring timely resumption of vital services
• providing greater protection of agency reputation and public image
• allocating and using assets, finances and resources effectively and efficiently
• ensuring good corporate governance.

All Main Roads branches and directorates in the Perth Metropolitan area have a Business Continuity Action Plan in place and function within an overarching Business Continuity Management Procedure.

Integrated Management System

Our Integrated Management System (IMS) brings together our third-party certified systems and processes into a single framework. This system has been certified under the Quality, Environment and Occupational Health and Safety Standards for a number of years and provides:

• consistency in how we plan and manage projects, contracts, supply, environment, and occupational health and safety
• clarification of roles and responsibilities
• alignment of our processes, procedures and policies with our business activities
• a culture of continuous improvement.

During the year we undertook a re-certification audit of our IMS, confirming we continue to comply with requirements of International and Australian Standards and consequently received certification for a further three years.

In addition, Main Roads successfully achieved certification to the new International Standard ISO 45001:2018 Occupational Health and Safety Management System.