Implementing The Gifts, Benefits And Hospitality Framework
Implementing the Gifts, Benefits and Hospitality FrameworkImplementing the Gifts, Benefitsand Hospitality FrameworkDecember 2015Victorian Auditor-General’s Report93885 VAGO GBH Framework Cover.pdf Page 1 of 1Telephone 61 3 8601 7000Facsimile 61 3 8601 vel 2435 Collins StreetMelbourne Vic. 3000December 201593885 VAGO GBH Framework Cover.pdf Page 1 of 1
VICTORIAVictorianAuditor-GeneralImplementing the Gifts,Benefits and HospitalityFrameworkOrdered to be publishedVICTORIANGOVERNMENT PRINTERDecember 2015PP No 124, Session 2014–15
This report is printed on Monza Recycled paper. Monza Recycled is certified Carbon Neutral by The Carbon ReductionInstitute (CRI) in accordance with the global Greenhouse Gas Protocol and ISO 14040 framework. The Lifecycle Analysis(LCA) for Monza Recycled is cradle to grave including Scopes 1, 2 and 3. It has FSC Mix Certification combined with 55%recycled content.ISBN 978 1 925226 43 0
The Hon. Bruce Atkinson MLCPresidentLegislative CouncilParliament HouseMelbourneThe Hon. Telmo Languiller MPSpeakerLegislative AssemblyParliament HouseMelbourneDear Presiding OfficersUnder the provisions of section 16AB of the Audit Act 1994, I transmit my report on theaudit Implementing the Gifts, Benefits and Hospitality Framework.In managing gifts, benefits and hospitality (GB&H) agencies are currently guided by aframework issued by the Victorian Public Sector Commission (VPSC) in conjunction with aPremier's Circular. These both include minimum requirements and accountabilities—compliance requires their inclusion in policies, but stops short of mandating theirachievement.This audit goes beyond testing this minimum level of compliance. It examines whether asample of creative industries agencies have effectively managed the risks associated withproviding and receiving GB&H.I found that the agencies we examined cannot show how they are effectively managingGB&H activities. They also cannot show how they are putting the minimum requirementsand accountabilities of the current framework into operation. While they have documentedpolicies that include the framework's requirements and accountabilities, this approach is notsufficient to manage the significant risks to their impartiality and integrity.To achieve this, agencies need to do a better job of identifying, assessing and treatingGB&H risks. They also must improve how they monitor and report on GB&H activities. Thiswill provide the basis for more effective oversight by management and audit committees. Inaddition, Creative Victoria needs to be more visible and proactive in its oversight role forstate-owned industries.A revised framework that focuses on the effective management of GB&H risks will beessential in supporting agencies to make these changes.Yours faithfullyDr Peter FrostActing Auditor-General10 December 2015Victorian Auditor-General’s ReportImplementing the Gifts, Benefits and Hospitality Frameworkiii
ContentsAuditor-General's comments . viiAudit summary . ixBackground . ixConclusions .xFindings . xiRecommendations . xiiiSubmissions and comments received . xiv1. Background . 11.1Introduction . 11.2Challenges in managing GB&H . 21.3Legislative and policy framework for GB&H . 21.4Risks of the inappropriate use of GB&H. 51.5Operating context for creative industries agencies . 61.6Audit objective and scope . 71.7Audit method and cost . 81.8Structure of the report . 82. Managing gifts, benefits and hospitality risks . 92.1Introduction . 102.2Conclusion . 102.3Agency management of GB&H . 102.4Management monitoring and reporting . 172.5Oversight of GB&H activities . 193. Understanding gifts, benefits and hospitality risks . 233.1Introduction . 243.2Conclusion . 243.3Approaches to managing GB&H risks . 253.4Consultation and communication weaknesses . 263.5Evidence on policy awareness and integrity . 293.6Implications . 33Appendix A. Audit Act 1994 section 16—submissions and comments . 35Victorian Auditor-General’s ReportImplementing the Gifts, Benefits and Hospitality Frameworkv
Auditor-General’s commentsEvery day, public sector employees carry out duties that affect the lives andinterests of Victorians. This includes handling private and confidential informationand making decisions about how to spend the public funds entrusted to them.Victorians rightly expect that these employees will apply the highest standards ofintegrity and impartiality in these roles. They want to know that governmentresources are distributed fairly and that decisions about how to do this are impartialand underpinned by integrity.Providing and receiving gifts, benefits and hospitality (GB&H) presents a particularmanagement challenge to public sector agencies. On the one hand these activitiescan be a legitimate part of pursuing government-endorsed objectives. For example,creative industries agencies often have to raise funds from outside governmentand oversee the effective delivery of artistic events. Providing or receiving GB&H isoften critical to doing this.However, these activities can diminish the public's trust if they create conflicts ofinterest between employees' personal interests and their public duty or if spendingon GB&H is considered lavish or inappropriate.Audit teamRay WinnEngagement LeaderNerillee MillerTeam LeaderSid NairAnalystRateeb BhuiyanAnalystEngagement QualityControl ReviewerCaitlin MakinWhile the dollar amounts involved in GB&H may be small in relation to an agency'soverall expenditure the reputational and corruption risks are significant.Anti-corruption agencies in Victoria, New South Wales and Queensland identifiedthe inappropriate acceptance of GB&H as a major misconduct and corruption risk: Victoria's Independent Broad-based Anti-corruption Commission (IBAC) listedthe acceptance of GB&H as a potential 'red flag of corruption' for theprocurement bidding process. IBAC further illustrated the risk in the case study ‘the slippery slide of gifts andbenefits’ using an Independent Commission Against Corruption investigationto illustrate the clear link between accepting GB&H and the corruption ofprocurement processes across 14 local councils in NSW. In Queensland, the Crime and Misconduct Commission characterisedaccepting even small gifts, especially for those involved in procurement, asgiving rise to potentially major misconduct risks.In this audit I examined how well a sample of creative industries agencies hadmanaged the risks associated with providing and receiving GB&H. Sampledagencies included Creative Victoria (a division of the Department of EconomicDevelopment, Jobs, Transport & Resources), Museum Victoria, Arts CentreMelbourne and the National Gallery of Victoria.In addition we included the Victorian Public Sector Commission (VPSC) and theDepartment of Premier & Cabinet (DPC) in the audit because of their roles informing the current government framework covering agencies' GB&H policies.Victorian Auditor-General’s ReportImplementing the Gifts, Benefits and Hospitality Frameworkvii
Auditor-General’s commentsMy audit found that agencies cannot show how they are effectively managingGB&H activities. While they have documented policies that include the minimumrequirements set out in the government's framework, this approach is not sufficientto manage the significant risks to their impartiality and integrity.Our analysis of agencies’ GB&H activities identified examples of clear risks thathad not been flagged and appropriately treated, including potential conflicts ofinterest, unclear business benefits and gifts of an inappropriate value beingaccepted.The agencies we examined performed poorly against all the key criteria used toassess the quality of their management of GB&H risks because they had not: monitored, reviewed and reported on GB&H activities and systematicallyidentified, analysed and evaluated the risks or the effectiveness of currentcontrols in mitigating the risks followed a structured, systematic approach to selecting and applyingtreatments to address these risks adequately consulted and communicated with employees and other keystakeholders, such as suppliers and funded organisations, to provide clarityabout what is acceptable and what to do if they observe poor practices.The current government framework does not provide an adequate basis to addressthese weaknesses because of its focus on agencies documenting rather thanachieving its minimum requirements and accountabilities. This is a critical flaw butthere is a precedent for the type of transformation that is required.The VPSC consulted with Victoria's key integrity bodies including my office toproduce a 2015 guide on Managing Conflicts of Interest: a guide to policydevelopment and implementation. The guide describes how to develop andimplement conflict of interest policies that successfully and appropriately managethe risks. This is a template for the type of guidance needed to help agencieseffectively manage the GB&H risks.Our recommendations accordingly targeted two areas: first, how the audited agencies should improve their practices to bettermanage GB&H and the associated risks second, the need for the VPSC and DPC to update the framework to requireagencies to effectively manage these risks.I have some concerns about Museum Victoria’s response to this report anddescribe these in my further audit comment in Appendix A.Dr Peter FrostActing Auditor-GeneralDecember 2015viii Implementing the Gifts, Benefits and Hospitality FrameworkVictorian Auditor-General’s Report
Audit summaryBackgroundVictorians trust that public sector employees will perform their duties impartially anduse public resources responsibly to pursue government’s objectives and benefit thecommunity. The giving and receiving of gifts, benefits and hospitality (GB&H) canbe a legitimate and appropriate part of doing government business. However, theinadequate management of these activities risks diminishing public trust andundermining the integrity of decisions made by public sector employees.Maintaining transparency around public sector activities is essential if thecommunity is to effectively scrutinise public sector performance and holdgovernments to account. Greater transparency also promotes a culture where thelevel of trust between employees, agencies and the community is enhanced, andwhere integrity within the public sector is strengthened.Managing GB&H is complicated because they can be essential for public sectoremployees to do their jobs properly. However, they can create conflicts of interestbetween employees’ personal interests and their public duty, and can diminishpublic trust if spending on GB&H is considered lavish or inappropriate.Recent investigations, audits and research across Australia have highlighted therisks associated with public sector employees providing or receiving GB&H.This audit is focused on a sample of Victorian creative industries agencies. Thenature of their operational environments creates specific challenges for managingGB&H activities. The provision and receipt of GB&H plays a legitimate and criticalrole in these agencies achieving their government-endorsed objectives. This couldbe accepting GB&H to generate revenue from sponsor-attended events or becauseemployees are responsible for overseeing funded events and accepting offers toattend.In managing GB&H agencies are currently guided by a framework issued by theVictorian Public Sector Commission (VPSC) in conjunction with a Premier'sCircular. These both includes a set of minimum requirements and accountabilities.Compliance with the framework requires agencies to include these in their policies,but stops short of mandating their achievement.Victorian Auditor-General’s ReportImplementing the Gifts, Benefits and Hospitality Frameworkix
Audit summaryAudit objective and scopeThis audit goes beyond testing this minimum level of compliance to examinewhether selected agencies have effectively managed the risks associated withproviding and receiving GB&H. The audit included the following creative industriesagencies: Creative Victoria (CV) (a division within the Department of EconomicDevelopment, Jobs, Transport & Resources), Museum Victoria, Arts CentreMelbourne (ACM) and the National Gallery of Victoria (NGV).ConclusionsAgencies cannot show how they are effectively managing GB&H activities orapplying the minimum requirements and accountabilities of the current framework.While they have documented policies that include the minimum requirements andaccountabilities, this approach is not sufficient to manage the significant risks totheir impartiality and integrity.Specifically agencies have not: effectively managed GB&H activities—they comply with the framework but fallshort of effectively managing the risks from receiving and providing GB&H monitored, reviewed and reported on GB&H activities to provide assuranceabout their performance and provide the basis for effective oversight systematically identified, analysed and evaluated the risks or theeffectiveness of current controls in mitigating the risks these activities pose followed a structured, systematic approach to selecting and applyingtreatments to address these risks adequately consulted and communicated with employees and other keystakeholders, such as suppliers and funded organisations, to provide clarityabout what is acceptable and what to do if they observe poor practices.This lack of transparency in how these activities are managed further highlights therisks to agencies' impartiality and integrity.Our recommendations target two areas: how these agencies should improve their practices to better manage GB&Hand the associated risks the need for the Department of Premier & Cabinet (DPC) and VPSC toupdate the guidelines to require agencies to effectively manage these risks.x Implementing the Gifts, Benefits and Hospitality FrameworkVictorian Auditor-General’s Report
Audit summaryFindingsAgencies' management of GB&HAgencies cannot show how they are effectively managing GB&H activities orapplying the minimum requirements and accountabilities of the current framework.This is because the way agencies currently document and analyse GB&Hinformation lacks rigour which highlights the need for greater scrutiny andtransparency in managing these activities.Our analysis of agencies GB&H activities identified examples of clear risks that hadnot been flagged and appropriately treated, including potential conflicts of interest,unclear business benefits and gifts of an inappropriate value being accepted.Agencies have not adequately monitored, reviewed and reported on GB&Hactivities and associated risks. Oversight has not been sufficiently informed by anadequate analysis of GB&H activities. This means agencies have not generatedthe information needed to adequately review the management of GB&H activities.The processes used are not adequate to record and transparently mitigate therisks generated by GB&H activities.Specifically we found:no internal management reporting on GB&H activities or risks, except at NGVwhere a six-monthly report was introduced in July 2015 the absence of meaningful review of GB&H activities, for example by internalauditors, except at CV where the former State Services Authority conducted areview following adverse findings by the Victorian Ombudsman in 2011 ACM introduced reporting on GB&H activities in its quarterly compliancereports to its audit committee commencing in October 2015 other than NGV's recent reporting, the only form of regular review wasthrough audit committees considering policy updates and annual gift registersand attestations. However, the information supporting these submissions wasgenerally insufficient and we were unable to confirm the rigour and depth ofreview from the records of these meetings. Agencies need to improve how they monitor and report on GB&H activities andrisks to provide the basis for more effective oversight by management and auditcommittees. In addition CV needs to be more visible and proactive in its oversightrole for state-owned creative organisations and cultural facilities. Allrecommendations applying to CV have been directed to the Department ofEconomic Development, Jobs, Transport & Resources, because CV is a divisionwithin this department.Victorian Auditor-General’s ReportImplementing the Gifts, Benefits and Hospitality Frameworkxi
Audit summaryUnderstanding GB&H risksAgencies have documented policies that include the minimum requirements andaccountabilities of the current GB&H framework. However, this approach of doingthe minimum necessary to comply is not sufficient to effectively manage the risksfrom receiving and providing GB&H because the way agencies identify, evaluateand treat these risks is inadequate.Agencies’ approaches to consulting and communicating with staff and stakeholdershave not been adequate: They could not show that they had regularly consulted staff and relevantexternal stakeholders in any structured way to understand the GB&H risks. They relied too heavily on a passive approach to informing and training staffabout GB&H policies and risks. Staff were expected to read material orcomplete e-learning modules when joining the organisation. Only ACMdelivered face-to-face training to new staff which included GB&H. They had not communicated their GB&H expectations and acceptablepractices to suppliers. The one exception to this was an NGV email sent tosuppliers advising them of the terms of their GB&H policy.The results of VSPC's People Matter Survey clearly show areas of potentialweakness, including how well staff understand GB&H policies and a lack ofconfidence and knowledge about the mechanisms they can use to highlightpotential misconduct.Agencies need to improve how they communicate with employees andstakeholders and need to measure their effectiveness in communicating key GB&Hrequirements and what to do if poor practices are observed.DPC and VPSC need to revamp the GB&H framework. The creative industriesagencies included in this audit should not wait for the revision of the framework butshould act to effectively manage the risks associated with GB&H.xii Implementing the Gifts, Benefits and Hospitality FrameworkVictorian Auditor-General’s Report
Audit at the Department of Economic Development, Jobs, Transport &Resources, Museum Victoria, Arts Centre Melbourne and theNational Gallery of Victoria review and revise their management ofthe receipt and provision of gifts, benefits and hospitality to betterunderstand and scrutinise these activities.222.That the Department of Economic Development, Jobs, Transport &Resources, Museum Victoria, Arts Centre Melbourne and theNational Gallery of Victoria review and revise how they monitorand report on gifts, benefits and hospitality activities by: introducing regular management and audit and risk committeereports on the receipt and provision of gifts, benefits andhospitality to identify trends and emerging risks, andrecommend how to address these accompanying the annual tabling of gift registers to auditcommittees with reports that adequately inform about the risks,the effectiveness of existing controls and any additionalrequired mitigation activities using the annual gift register tabling to propose anyamendments required to existing gifts, benefits and hospitalitypolicies.223.That the Department of Economic Development, Jobs, Transportand Resources play a more visible and active oversight role by: communicating the importance of this audit's findings andrecommendations to all state-owned creative organisations andcultural facilities following up on agencies' progress in applying therecommendations and updating the Minister for CreativeIndustries on their progress in addressing these risks.224.That the Department of Economic Development, Jobs, Transport &Resources, Museum Victoria, Arts Centre Melbourne and theNational Gallery of Victoria review and revise their management ofthe receipt and provision of gifts, benefits and hospitality toeffectively manage the risks by: identifying and evaluating the risks to their impartiality, integrityand reputation developing and implementing evidence-based treatments toaddress these risks where existing controls are inadequate demonstrating the extent to which they have delivered on theminimum requirements and accountabilities of thegovernment's gifts, benefits and hospitality framework.345.That the Victorian Public Sector Commission and the Departmentof Premier & Cabinet review and update the gifts, benefits andhospitality framework to achieve the outcome of agenciesdemonstrating the effective management of gifts, benefits andhospitality risks including: being clear about the intended outcomes that agencies need toachieve requiring the collection of sufficient evidence so agencies candemonstrate the achievement of minimum requirements requiring agencies to publish gifts, benefits and hospitalityregisters on their websites.34Victorian Auditor-General’s ReportImplementing the Gifts, Benefits and Hospitality Frameworkxiii
Audit summaryRecommendations – continuedNumber6.RecommendationPageThat the Department of Economic Development, Jobs, Transport &Resources, Museum Victoria, Arts Centre Melbourne and theNational Gallery of Victoria: review and improve the way they consult on and communicategifts, benefits and hospitality activities and policies measure how successful communication and training havebeen in fully informing staff and stakeholders about intendedgifts, benefits and hospitality behaviours and in achieving thedesired outcomes.34Submissions and comments receivedWe have professionally engaged with the Department of Premier & Cabinet, theVictorian Public Sector Commission, the Department of Economic Development,Jobs, Transport & Resources, Arts Centre Melbourne, the National Gallery ofVictoria and Museum Victoria throughout the course of the audit. In accordancewith section 16(3) of the Audit Act 1994 we provided a copy of this report to thoseagencies and requested their submissions or comments.We have considered those views in reaching our audit conclusions and haverepresented them to the extent relevant and warranted. Their full section 16(3)submissions and comments are included in Appendix A.xiv Implementing the Gifts, Benefits and Hospitality FrameworkVictorian Auditor-General’s Report
11.1BackgroundIntroductionVictorians trust that public sector employees will perform their duties impartially anduse public resources responsibly to pursue government’s objectives and benefit thecommunity. The giving and receiving of gifts, benefits and hospitality (GB&H) can be alegitimate and appropriate part of doing government business. However, theinadequate management of these activities risks diminishing public trust andundermining the integrity of decisions made by public sector employees.The Code of Conduct for Victorian Public Sector Employees is legally binding anddescribes how employees should apply core values. This includes demonstrating: integrity by avoiding any real or apparent conflicts of interest and striving to earnand sustain a high level of public trust impartiality by making decisions and providing advice on merit and without bias,caprice, favouritism or self-interest accountability by seeking to achieve the best use of resources and submittingthemselves to appropriate scrutiny.Maintaining transparency around public sector activities is essential if the community isto effectively scrutinise public sector performance and hold governments to account.Greater transparency also promotes a culture where the level of trust betweenemployees, agencies and the community is enhanced, and where integrity within thepublic sector is strengthened. Figure 1A describes what we mean by GB&H.Figure 1ADefining gifts, benefits and hospitalityA gift or benefit is anything of value that is offered to, or provided by, a public sectoremployee in the course of their work, apart from normal employment entitlements.Examples of gifts and benefits are: flowers and a present for a long-serving employee an invitation to attend a sporting or cultural event at no cost gifts provided to or received from a visiting international delegation.Hospitality is the friendly reception and treatment of guests and can be received by orprovided by public sector employees—for example, where public sector employees: provide refreshments for staff and visitors attending a business meeting or seminar attend agency-funded training, a team building exercise, a policy launch or a celebrationat agencies' premises or at an external facility receive food, drink, entertainment or travel paid for by another organisation.Source: Victorian Auditor-General's Office based on the Victoria Public Sector Commission’sGifts, Benefits and Hospitality Policy Framework, 2012.Victorian Auditor-General’s ReportImplementing the Gifts, Benefits and Hospitality Framework1
Background1.2Challenges in managing GB&HManaging GB&H is complicated because they can be essential for public sectoremployees to do their jobs properly. However, they can create actual or perceivedconflicts of interest between employees’ personal interests and their public duty, andcan diminish public trust if spending on GB&H is considered lavish or inappropriate.The vastly different roles and operating contexts across the public sector mean that arigid ‘one size fits all’ approach is not suitable. Banning these activities is an option butmay hamper agencies in their legitimate pursuit of government objectives.For some organisations, these activities are a constant and core component of theiroperations. For example, where they provide and receive GB&H in order to promoteoverseas trade or attract sponsorship and support for the creative industries. For otheragencies, these activities should be restricted to a level commensurate withrecognising employees’ service and facilitating normal business-related meetings andtraining.1.3Legislative and policy framework for GB&HFigure 1B shows the legislative and policy framework for GB&H. The most relevantmaterial is contained in the 2012 Premier's Circular and the related Victoria PublicSector Commission (VPSC) guidance.Figure 1BLegislative and policy frameworkGuidanceDescriptionPremiers Circular—Gifts, benefits and hospitality policy framework—revised April 2012Circular No. 2012 Purpose—advise agency heads that policies and procedures shouldbe consistent with the revised VPSC policy framework (see below).In addition secretaries of departments are required to: send the VPSC an annual attestation to the operation, review,promulgation and scrutiny of appropriate departmental policies require an attestation from portfolio public sector agencies.VPSCGifts, Benefits andHospitality PolicyFramework, 2012 Conflicts of Interest Sets minimum requirements for employees accepting and providinggifts, benefits and hospitality.Sets minimum accountabilities for public sector organisation heads.Provides guidance and illustrations to help public sector agenciesmanage the risks and construct appropriate policies.Provides guidance on the development, implementation and reviewof conflict of interest policies.Agency policies and proceduresPolicies andprocedures2 Set by each agency taking account of legislation and guidance.Implementing the Gifts, Benefits and Hospitality FrameworkVictorian Auditor-General’s Report
BackgroundFigure 1BLegislative and policy framework – continuedGuidanceDescriptionLegislationPublic Administration Act 2004 (PAA)Section 7 Describes the values public sector employees must follow.Section 81 The board of a public entity must ensure that an adeq
Implementing the Gifts, Benefits and Hospitality Framework. 2015-16:19 December 2015. Level 24 35 Collins Street. Melbourne Vic. 3000 Telephone 61 3 8601 7000. Facsimile 61 3 8601 7010 www.audit.vic.gov.au. Victorian Auditor-General's Report December 2015. 2015-16:19. Implementing the Gifts, Benefits . and Hospitality Framework
Silat is a combative art of self-defense and survival rooted from Matay archipelago. It was traced at thé early of Langkasuka Kingdom (2nd century CE) till thé reign of Melaka (Malaysia) Sultanate era (13th century). Silat has now evolved to become part of social culture and tradition with thé appearance of a fine physical and spiritual .
May 02, 2018 · D. Program Evaluation ͟The organization has provided a description of the framework for how each program will be evaluated. The framework should include all the elements below: ͟The evaluation methods are cost-effective for the organization ͟Quantitative and qualitative data is being collected (at Basics tier, data collection must have begun)
̶The leading indicator of employee engagement is based on the quality of the relationship between employee and supervisor Empower your managers! ̶Help them understand the impact on the organization ̶Share important changes, plan options, tasks, and deadlines ̶Provide key messages and talking points ̶Prepare them to answer employee questions
Dr. Sunita Bharatwal** Dr. Pawan Garga*** Abstract Customer satisfaction is derived from thè functionalities and values, a product or Service can provide. The current study aims to segregate thè dimensions of ordine Service quality and gather insights on its impact on web shopping. The trends of purchases have
On an exceptional basis, Member States may request UNESCO to provide thé candidates with access to thé platform so they can complète thé form by themselves. Thèse requests must be addressed to esd rize unesco. or by 15 A ril 2021 UNESCO will provide thé nomineewith accessto thé platform via their émail address.
Chính Văn.- Còn đức Thế tôn thì tuệ giác cực kỳ trong sạch 8: hiện hành bất nhị 9, đạt đến vô tướng 10, đứng vào chỗ đứng của các đức Thế tôn 11, thể hiện tính bình đẳng của các Ngài, đến chỗ không còn chướng ngại 12, giáo pháp không thể khuynh đảo, tâm thức không bị cản trở, cái được
Food outlets which focused on food quality, Service quality, environment and price factors, are thè valuable factors for food outlets to increase thè satisfaction level of customers and it will create a positive impact through word ofmouth. Keyword : Customer satisfaction, food quality, Service quality, physical environment off ood outlets .
the CDS Hooks definition, t he user interface presentation of the cards to the physician is the task of the EHR that invoked the CDS service. 1.3. Hepatitis serology test interpretation by Hepaxpert Hepaxpert [7] is an app developed by Medexter Healthcare for the textual interpretation of hepatitis A, B, and C serology antigen and antibody test results. After the test results are entered in .
