Self-disclosure and reporting processes

Summary

Require and support staff and third parties to self-disclose gifts, benefits, incidents, mistakes and real or perceived conflicts of interest.

Why this countermeasure matters

Lack of self-disclosure and reporting processes may lead to:

• staff and third parties failing to self-disclose gifts, benefits, incidents, mistakes and real or perceived conflicts of interest
• fraudulent conduct, dishonest influences or coercion
• staff and contractors being coerced to commit fraud for the benefit of another person or entity.

How you might apply this countermeasure

Some ways to implement this countermeasure include:

• requiring staff to declare conflicts of interest
• creating a process for staff to self-report accidental unauthorised accesses or disclosures
• creating a register for staff to self-report gifts and benefits
• requiring staff or contractors to self-report when their circumstances change, such as to maintain a security clearance
• immunity for self-disclosure of cartel or group conduct.

How to check if your countermeasures are effective

Here are some ways to measure the effectiveness of this type of countermeasure:

• confirm policy and guidance material exists for self-disclosure or self-reporting.
• confirm guidance material is available and easy to access.
• review guidance material to make sure it is clear and easy to understand.
• confirm guidance material and processes align with policy and legislation such as the Public Governance, Performance and Accountability Act 2013.
• ask staff about the forms, processes or systems to make sure they have a consistent understanding of how to use them.
• analyse the use of registers such as conflict of interest registers or inadvertent access registers.