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E f f e c t i v e a n d a c c o u n t a b l e s e r v i c e d e l i v e r y individual behaviour, including recruitment processes, appraisal and reward structures, leadership and contemporaneous prompts to good behaviour alongside formal codes and sanctions for poor behaviour. Conclusion two The need now is for ethical standards issues to be addressed actively at the organisational level. High standards do not occur automatically. Nor should they be taken for granted. High standards are everyone’s personal responsibility. But personal behaviour is shaped by organisational culture. High standards need to be actively driven by leadership and example. Ethical issues should feature regularly on the agendas of the boards of public bodies and, where appropriate, on risk registers. All such boards should consider whether ethical risks have been adequately addressed and actively monitor standards of behaviour throughout their organisations, either themselves, or through their audit and risk committees. Permanent secretaries and chief executives of all organisations delivering public services should take personal responsibility for ethical standards in their organisations and certify annually, in their annual report or equivalent document, that they have satisfied themselves about the adequacy of their organisation’s arrangements for safeguarding high standards. Conclusion three New ethical risks are being created by the development of new models of service delivery. There is a growing area of ambiguity occupied by people contracted to deliver public services who may not be public office-holders. We strongly believe that the ethical standards captured by the seven principles should also apply to such people. In all cases where new methods of delivering public services are being created, commissioners and providers should give careful thought to the mechanisms necessary to maintain expected high standards of behaviour and promote the seven principles of public life. Public servants designing and commissioning services should, in a consistent and proportionate way, address ethical issues throughout the procurement process. Contractors and others should acknowledge the particular responsibilities they bear when delivering public services, paid for by public money, to individuals who may not have the choice of going elsewhere. Where powers to regulate standards are devolved to promote local responsibility and leadership, care should always be taken to ensure that there is independent scrutiny, that the results of such scrutiny are made publicly available and that those who have responsibility for imposing sanctions have adequate legal or other powers to do so. Conclusion four Low and declining levels of confidence in the integrity of public institutions remain a matter of concern. While trust is a complex phenomenon, there is scope for trying to increase public confidence in public office-holders and public institutions by addressing the outstanding standards issues identified in this report and by being more attentive to, and active in, addressing emerging issues rather than waiting until pressures for reform become irresistible. Public office holders and organisations should seek to improve their own trustworthiness by consistently and reliably exemplifying high standards of ethical behaviour, openness and accountability and establishing and promulgating robust mechanisms for detecting and dealing with wrongdoing. They should endeavour to increase public understanding of their role and work and should aim to create a culture, which harnesses the power of the media to promote high standards and deter or expose misconduct. The outstanding ethical issues identified in this report should be actively addressed before they become even more problematic and further undermine confidence in our public institutions. Endnotes 1 The index is based on measures of perceptions of corruption in the countries surveyed. Perceptions are important for confidence reasons. But they may diverge from underlying substance. It is probable that, in the UK as in other countries, they will be influenced by a wide range of factors that may have little or nothing to do with actual evidence of corruption – the way the media reports stories, for example, or dissatisfaction with the substance of the policies being pursued by the government of the day. It is also possible that effective regulation could have perverse effects on perceptions, by uncovering nefarious practices which might have previously occurred without anyone being aware of them. During our inquiry into party funding we were told that the relative absence of concerns relating to political finance in Sweden (one of the countries ranking above the UK in the Transparency International index) could be caused by a different political culture in which cheating is less likely. Or it could be explained by the limited nature of regulation there. 2 See p. 53. 3 Including the Charity Commission governance framework, 2005 (reviewed annually); HM Treasury, Corporate governance in central government departments: Code of good conduct, 2005 (revised 2011); and the Commissioner for Public Appointments, Code of practice for ministerial appointments to public bodies, 2009 (revised 2012). 4 Minister for the Civil Service, Civil Service Code, November 2010. 5 A YouGov survey for Public Concern at Work (PCAW) in 2011 found that 19 per cent of respondents viewed the word 'whistleblower’ negatively and 35 per cent neutrally. Commonwealth Governance Handbook 2013/14 50


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