Managing secondary employment risks in public authorities

In 2016, some integrity matters around secondary employment came to the Commissioner’s attention. These matters, along with requests for advice and support on this topic, prompted the Commissioner to commence an evaluation of secondary employment policies and practices across the sectors. The evaluation sought to gather information about current practices and to identify opportunities to reduce and prevent misconduct.

For the purposes of this evaluation, secondary employment refers to paid work undertaken by employees outside their position with a public authority. The suggested actions arising from this evaluation however may also be applied to public officers undertaking voluntary and unpaid work.

While secondary employment in and of itself is not unethical, without careful management it can pose conflicts of interest, misuse of resources and employee performance risks. Recognising and managing such risks reduces misconduct, maintains integrity and builds public trust.

The evaluation commenced in December 2016 with an online survey sent to 201 public authorities. Results from the survey provided useful baseline information on existing policies and practices, as well as a number of interesting insights, as detailed to the right.

Facts and figures
Fact 1 One in 10 public authorities reported that they do not have a documented framework to guide employees in identifying secondary employment risks
Fact Almost all employee requests regarding secondary employment arrangements are approved by their managers
Fact 3
More than half of public sector agencies reported their Accountable and ethical decision making training does not describe or refer to the risks of secondary employment
Fact 4 Authorities do not prompt staff to re-disclose or seek approval on a regular basis and generally rely on employees remembering to advise them of any changes

To gain a better understanding of actual practice on the ground, two focus groups were held comprising representatives from public sector agencies and local government. Key observations included:

  • conflicts of interest are not well understood, no matter the policy in place
  • training managers is important so they can identify potential issues and explain them to employees
  • any issues are usually due to lack of knowledge rather than wilful misbehaviour.

Policies and practices were further assessed through an in-depth evaluation of a sample of 11 public authorities. Authorities included in the sample were selected based on workforce size and composition, business function and location.

The evaluation involved face-to-face interviews, as well as an examination of records such as applications for secondary employment, decision logs and conflict of interest self-assessments. 

The interview responses and records were evaluated using the following four key dimensions for managing integrity risks:

  • Organisational culture
  • Organisational capability
  • Robust decision-making frameworks 
  • Good governance.

In terms of organisational culture, authorities evaluated agreed that a strong culture and tone at the top was an important element in realising sustainable behavioural change.

Overall, the evaluation revealed limited capability by employees and managers in identifying conflicts of interest leading to a possible underreporting of secondary employment. 

The evaluation report suggests a number of actions, based on its findings, to improve the identification and management of integrity risks posed by secondary employment. 

Suggested actions for public authorities

  • Ensure induction processes cover employee obligations and collect information on any second jobs
  • Remind employees to request approval and to advise of any changes to their arrangements
  • Regularly communicate a current secondary employment policy to guide practice
  • Require all employees, across all locations, to undertake ethics training that builds capability to recognise and manage risks
  • Provide customised training to supervisors and managers who monitor the impacts of secondary employment
  • Audit records of secondary employment disclosures, across all business functions, to identify where employees and managers need more guidance and education on reporting and managing conflicts of interest
 Our reports are available on the Reviews page of our website

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Page last updated 19 October 2017