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Integrity

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Policy framework statement

The Integrity Policy Framework specifies the integrity requirements that all Health Service Providers (HSPs) must comply with in order to ensure effective and consistent standards of behaviour and actions of staff across the WA health system.

Purpose

The purpose of this policy framework is to ensure:

an effective and consistent approach to integrity governance across the WA health system
the management of integrity matters is consistent with regulatory, policy and legislative frameworks and the Australian Standards.

Applicability

This policy framework is binding on each HSP to which it applies or relates.

Principles

The key principles that underpin this policy framework are:

Ethical conduct

The WA Health Code of Conduct (Code) identifies the fundamental values of the WA health system, and translates these values into principles that guide staff members conduct in the workplace. The Code defines the standards of ethical and professional conduct and outlines the behaviours expected across the WA health system.

Integrity governance

Formal arrangements are established which monitor and evaluate structures, systems and processes to promote a culture of integrity and appropriately respond to issues.

Legislative context

This policy framework is made pursuant to ss 26(2)(l)(f) of the Health Services Act 2016. Policy frameworks are also referred to in s. 27 and s. 34(2)(c).

Other relevant parts in the Act that relate specifically to this policy framework include s. 146 and s. 167.

The legislation below, may also apply:

Corruption, Crime and Misconduct Act 2003
Health Practitioner Regulation National Law (WA) Act 2010
Public Sector Management Act 1994 (and Regulations)

Mandatory requirements

Under this policy framework HSPs must comply with all mandatory requirements including:

WA health system policies

Please refer to the Public Sector Commissioner’s Instructions and compliance instruments to access relevant statewide integrity related policies, circulars and other relevant information.

Policy framework custodian

Deputy Director General

Enquiries relating to this Policy framework may be directed to: PolicyFrameworkSupport@health.wa.gov.au

Review

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This policy framework will be reviewed as required to ensure relevance and recency. At a minimum this policy framework will be reviewed within two years after first issue and at least every three years thereafter.

Version	Effective from	Amendment(s)
28	22 January 2024	Minor amendment to MP 0138/20 Managing Conflicts of Interest Policy. Supporting Information document: 'System Manager Conflicts of Interest (COIR) User Guide page 8 updated with insertion of authorised approver for conflicts of interest declarations related to Chief Executives of Health Service Providers is the Director General, Department of Health and SWIS being the register nominated approver.
27	22 January 2024	Minor amendment to MP 0136/20 Gifts, Benefits and Hospitality Policy. Supporting Information document: 'System Manager Gift Declaration Registry User Guide' page 3 updated with designated approver for policy consistency. Insertion of authorised approver for conflict of interest declarations related to Chief Executives of Health Service Providers on page 24.
26	2 January 2024	Minor amendment to MP 0125/19 Notifiable and Reportable Conduct Policy. Definition of reportable conduct under the Parliamentary Commissioner Act 1971 updated to include (ca) significant neglect of a child and (cb) any behaviour that causes significant emotional or psychological harm to a child.
25	21 December 2023	Minor amendments to the following Integrity Policy Framework mandatory policies: MP 0105/19 Fraud and Corruption Control Policy-minor amendments to the Fraud and Corruption Control Guide. MP 0136/20 Gifts Benefits and Hospitality Policy-minor amendments including removal of two supporting information and insertion of Public Sector Commission Guidance - Understanding Conflicts of Interests as a supporting information. MP 0138/20 Managing Conflicts of Interest Policy- minor amendments to policy and supporting information document: Managing Conflicts of Interest Information. MP 0125/19 Notifiable and Reportable Conduct Policy-minor amendments to the supporting information document: Notifiable and Reportable Conduct Guide.
24	5 December 2023	Minor amendment to MP 0105/19 Fraud and Corruption Control Policy. Supporting Information 'Fraud and Corruption Control Guide' pages 24 and 25 updated to include reference to sections of the WA Health Financial Management Manual.
23	2 October 2023	Policy review and amendment to MP 0114/19 Integrity Governance Policy. Amendments include the following: Purpose section amended to align with Commissioner's Instruction 40 (CI 40) requirements and reflect recent amendments to the Health Services Act 2016; Policy Requirements section amended to reflect CI 40 requirements; Compliance monitoring section updated to reflect the policy requirements; Inclusion of related document: CI 40 to reflect its mandatory status and replaced the supporting information repealed CI 8: Codes of Conduct and Integrity Training with the Public Sector Commission Integrity Framework Template and Integrity Framework Guide.
22	30 August 2023	Amendment: MP 0083/18 Disputes About the Professional Conduct of a Contracted Medical Practitioner Engaged Under a Medical Services Agreement Policy changed from Procurement to Integrity Policy Framework. Policy ownership also amended from Director Legal and Legislative Services to Director System-wide Integrity Services.
21	19 July 2023	Policy review and amendment to MP 0125/19 Notifiable and Reportable Conduct Policy. Amendments include: restructured and refined the purpose and compliance monitoring sections to improve clarity and to enhance the quality of the policy overall, clarified the meaning of terms to reinforce HSP responsibilities under the Health Services Act 2016 and other relevant legislation, updated information on other relevant policies and supporting information to improve clarity and ensure accuracy, amended policy requirements section to include an additional requirement relating to support for staff and updated the definitions section to reflect changes to the policy and to the Health Services Act 2016.
20	11 July 2023	Minor amendments to MP 0138/20 Managing Conflicts of Interest Policy. Amendment to the policy purpose to replace reference to section 20 (1)(b) of the Health Services Act 2016 with section 19 (1A) to reflect the recent amendments to Health Services Act 2016.
19	11 July 2023	Minor amendments to MP 0136/20 Gifts, Benefits and Hospitality Policy. Amendment to the policy purpose to replace reference to section 20 (1)(b) of the Health Services Act 2016 with section 19 (1A) to reflect the recent amendments to Health Services Act 2016.
18	11 July 2023	Minor amendment to MP 0127/20 Discipline Policy. Amendment to the policy purpose to replace reference to section 20 (1)(b) of the Health Services Act 2016 with section 19 (1A) to reflect the recent amendments to Health Services Act 2016.
17	10 July 2023	Minor amendment to MP 0124/19 Code of Conduct Policy. Policy updated to reference the amendment to section 145 of the Health Services Act 2016 requiring the reporting of misconduct findings made against a registered health practitioner including findings made by tribunals in other Australian jurisdictions to the Health Service Provider by the practitioner within 7 days.
16	6 July 2023	Policy review and amendment to MP 0126/19 Pre-employment Integrity Check Policy. Amendments include: restructured and refined the purpose and policy requirements to improve clarity in relation to responsibilities and enhance the quality of the policy overall, updated compliance monitoring statement to reflect mandatory policy requirements, inclusion of supporting information document: Pre-employment Integrity Check Process Diagram, removed supporting information: Case Management System (CMS) User Document, updated applicability section to reflect mandatory policy requirements, updated definitions table, minor amendments to wording to improve clarity and ensure consistency with legislation.
15	18 May 2023	Policy review and amendment to MP 0105/19 Fraud and Corruption Control Policy. Amendments include: applicability changed to WA health entities to include Department of Health and health service providers, restructured and refined policy requirements section and included Fraud and Corruption Control Australian Standards AS 80001:2021 (AS 80001:2021), updated compliance monitoring statement to reflect mandatory policy requirements, updated supporting information documents - Fraud and Corruption Control Guide, inclusion of Fraud and Corruption Control System Template, removal of Fraud and Corruption Control Plan Template and updated definitions table.
14	23 December 2022	Policy transitioned to Employment Policy Framework - 15 February 2023. New Policy MP 0176/22 Working with Children Check Policy. This policy supersedes OD 0454/13 WA Health Working with Children Check Policy.
13	10 October 2022	Minor amendment to MP 0136/20 Gifts, Benefits and Hospitality Policy. Removal of State of Emergency message from Policy and landing page. There is no current state of emergency in Western Australia.
12	5 May 2022	The following minor amendments to the Integrity Policy Framework: Minor wording changes to align with the policy framework template and other policy frameworks. Addition of principles to support the framework. Listing of relevant sections of the Health Services Act 2016 relating to this framework. Removal of Public Sector Standards in Human Resources Management - Employment as they are not relevant to this framework. Addition of the Integrity Strategy for WA Public Authorities 2020-2023 as supporting information. Addition of glossary terms.
11	11 February 2022	Minor amendments to MP 0138/20 Managing Conflicts of Interest Policy as follows: Minor rewording changes throughout the policy Addition of statement regarding applicability to contracted health entities Minor amendments to definitions. Minor amendments to MP 0114/19 Integrity Governance Policy as follows: Minor re-wording throughout the Policy. Extend applicability to all WA health system entities. Inclusion of Commissioner’s Instruction No. 8: Codes of conduct and integrity training as Supporting Information. Amendments to definitions.
10	23 August 2021	Inclusion of Accountable and Ethical Decision Making as Mandatory Training on the Policy Framework Landing Page.
9	6 August 2021	Minor Amendments to address broken links in: MP 0136/20 Gifts, Benefits and Hospitality Policy MP 0138/20 Managing Conflicts of Interest Policy MP 0125/19 Notifiable and Reportable Conduct Policy MP 0105/19 Fraud and Corruption Control Policy
8	11 June 2020	New MP 0138/20 Managing Conflicts of Interest Policy - Supersedes MP 0113/19 Managing Conflicts of Interest Policy.
7	27 May 2020	New MP 0136/20 Gifts, Benefits and Hospitality Policy published - supersedes MP 0112/19 Gifts, Benefits and Hospitality Policy.
6	06 April 2020	Major amendment to MP 0112/19 Gifts, Benefits and Hospitality Policy.
5	2 January 2020	New MP 0127/20 Discipline Policy published - supersedes MP 0040/16 Discipline Policy.
4	31 October 2019	New MP 0124/19 Code of Conduct Policy published - supersedes MP 0031/16 Code of Conduct. New MP 0125/19 Notifiable and Reportable Conduct Policy published - supersedes - MP 0029/16 Notifying Misconduct Policy; and MP 0043/16 Reporting of Criminal Conduct and Professional Misconduct Policy. New MP 0126/19 Pre-Employment Integrity Check Policy published - supersedes MP 0032/16 Pre-Employment Integrity Check Policy.
3	10 July 2019	New MP 0112/19 Gifts, Benefits and Hospitality Policy, MP 0113/19 Managing Conflicts of Interest Policy and MP 0114/19 Integrity Governance Policy published.
2	27 March 2019	New MP 0105/19 Fraud and Corruption Control Policy.
1	25 March 2019	Original version

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Approval

This Policy Framework has been approved and issued by the Director General of the Department of Health as the System Manager.

Approval by	Dr David Russell-Weisz, Director General, Department of Health
Approval date	31 January 2019
Date published	01 January 0001
File number	F-AA-61335

Compliance

This policy framework is binding on those to whom it applies or relates. Implementation at a local level will be subject to audit.

Glossary of terms

Term	Meaning
Applicability	Under Section 26 of the Health Services Act 2016, policy frameworks may apply to : All Health Service Providers A type of public health service facility A type of public health service A type of staff member of a health service provider.
Health Service Provider	Health Service Provider means a health service provider established under s. 32 of the Health Services Act 2016 and may include North Metropolitan Health Service (NMHS), South Metropolitan Health Service (SMHS), Child and Adolescent Health Service (CAHS), WA Country Health Service (WACHS), East Metropolitan Health Service (EMHS), Quadriplegic Centre PathWest and Health Support Services (HSS).
Integrity	Integrity refers to the expected standards of behaviour and actions of staff which reflect honesty, accountability, transparency, impartiality and acting with care and diligence.
Integrity governance	Integrity governance refers to the formal arrangements by which an organisation establishes, monitors and evaluates structures, systems and processes to promote a culture of integrity and appropriately respond to issues. Integrity governance structures include mechanisms to escalate risks to the peak governance body of the organisation, for review and action.
WA health system	The WA health system is comprised of the Department of Health, Health Service Providers (NMHS, SMHS, CAHS, WACHS, EMHS, Quadriplegic Centre, PathWest and HSS) and to the extent that contracted health entities provide health services to the State, the contacted health entities.