Within successful public administration regimes there is a dynamic focus on

socialization and communication to reinforce the notion of public service. This can include the
swearing of a special oath when entering public office to regular training classes on what is
expected of public servants. It can also include special recognition (awards and ceremonies) as
well as special salary schemes! "ob security! benefits and even status. #ocialization and
rewards of public servants has been a concern of theorists for thousands of years.$% In the end!
much of the socialization is left to managers who must both model and articulate the
expectations within the organization.$&
'. ()*+, )-.,T/I0# 12 3+4*I05,#31-#I4I*IT6 5odalyn 7. #alvaleon8Tusoy 93) #tudent
:. #013, 12 T/, 35,#,-T)TI1- 3ublic (alues and 3ublic 1ffice )dministration 0ode of
)dministrative ,thics for ,thics 3ublic #ervice
$. W/)T I# ,T/I0)* 4,/)(I15; ,thical 4ehavior 8 what is accepted as good and right in the
context of the governing moral code (alues broad beliefs about what is or is not appropriate behavior
<. 3+4*I0 122I0,= 3ublicoffice is both a duty and a position of great importance in a government
bureaucracy.
>. 3ublic office is a public trust. 3ublic officers and employees must at all times be accountable to the
people! serve them with utmost responsibility! integrity and loyalty! and efficiency! act with patriotism
and "ustice! and lead modest lives.#ection ' of )rticle ?I of the '@&% 0onstitution of the 5epublic of
the 3hilippines
A. ()*+,# 12 3+4*I0 ).9I-I#T5)TI1-The sum of thevalues of the peoplein a society it
serves.It changes as rapidlyas do the peoplevalues
%. 7overnment 3eople 3ublic )dministration
&. ).9I-I#T5)TI(, ,T/I0#= ,thics is a way of life= #ocietyBs view of what constitutes
appropriate behavior by its public officials
@. ,T/I0# I- T/, W15C3*)0, What is an ethical dilemma; #ituation that reDuires choosing a
course of action
'E. ,?)93*,# 12 ,T/I0)* .I*,99)# #hould I support my bosses incorrect views; F #hould I
sign a false document; #hould I accept a gift from a client; F #hould I give special treatment to a friend
of bossB friend;
''. ,T/I0)* .I*,99)#0onfronting = What )re 6our 5esponsibilities;conflicting G To the
publicresponsibilities is the G To the staHeholdersmost typical way G To the organizationpublic
administrators G To the professionexperience ethical G To your colleaguesdilemmas. G To yourself 8
Terry 0ooper
':. -I-, 0)+#,#I2)0T15# 12 -,7)TI(,4,/)(I15 I- 71(,5-9,-TJ '. The difficulty of
coping the economic realities because of unrealistic salary levels of government employeeK F :. The
excessive desire for wealth and the good life among other higher8 echelon government officialsK $.
*ow moral standards or values F <. )n administrative behavior that facilitates or support corruption
'$. -I-, 0)+#,#I2)0T15# 12 -,7)TI(,4,/)(I15 I- 71(,5-9,-TJ >. 5elated to the
preceding factor! strong corrupting influence of clientele F A. 4ad example set by the leadership %. The
Hinship system F &. ) cumbersome system of "ustice @. +nenforceable and obsolete laws
'<. 01., 12 ,T/I0# 215 3+4I0 #,5(I0, 0ode of ,thics s a self8regulation manual among
professionals
'>. 2or most public servants thetaHing of an oath of loyaltymerely formalizes aresolution already made.
Itamounts to an outerexpression of an innerdedication 8 the legalaspects of a code of ethicsby which the
public employeeis guided in all his official actsand by which he expects allhis fellow worHers to
proceed Lohn ). (ieg
'A. ,?,0+TI(, 15.,5 -1. :'%= '. /ave faith in .ivine 3rovidence that guides the destinies of
men and nations.= :. *ove your country for it is the home of your people! the seat of your affections!
and the source of your happiness and well being. Its defense is your primary duty. 4e ready at all times
to sacrifice and die for it if necessary.= $. 5espect the 0onstitution which is the expression of your
sovereign will. The government is your government. It has been established for your safety and
welfare. 1bey the laws and see that they are observed by all and that public officials comply their
duties.
'%. ,?,0+TI(, 15.,5 -1. :'%= <. 3ay your taxes willingly and promptly. 0itizenship implies not
only rights but also obligations.= >. #afeguard the purity of suffrage and abide by the decisions of the
ma"ority.= A. *ove and respect your parents. It is your duty to serve them gratefully and well.= %.
(alue your honor as you value your life. 3overty with honor is preferable to wealth with dishonor.= &.
*ead a clean and frugal life. .o not indulge in frivolity or pretense. 4e simple in your dress and modest
in your behavior.
'&. ,?,0+TI(, 15.,5 -1. :'%= @. *ive up to the noble traditions of your people. (enerate the
memory of the heroes. Their lives point the way to duty and honor.= 'E. 4e industrious. 4e not afraid
or ashamed to do manual labor. 3roductive toil is conducive to economic security and adds to wealth of
the nation.= ''. 5ely on your efforts for your progress and happiness. 4e not easily discouraged.
3ersevere in the pursuit of your legitimate ambitions.= ':. .o your worH cheerfully! thoroughly and
well. WorH badly is worse than worH undone. .o not leave for tomorrow what you can do today.
'@. ,?,0+TI(, 15.,5 -1. :'%= '$. 0ontribute to the welfare of your community and promote
social "ustice. 6ou do not live for yourself and your families alone. 6ou are part of society to which you
owe definite responsibilities.= '<. 0ultivate the habit of using goods made in the 3hilippines. 3atronize
the product and trades of your countrymen.= '>. +se and develop our natural resources and conserve
them for posterity. They are inalienable heritage of its people. .o not traffic with your citizenship.
:E. 01., 12 ,T/I0# 215 3+4*I0122I0,5# )-. ,93*16,,#I. 5espect and uphold the
0onstitution and laws of the 5epublic of the 3hilippines.II. 1bserve the highest standard of morality!
integrity! honesty! loyalty! and devotion to the public weal.III. 3erform his tasHs thoroughly! faithfully!
and efficiently.I(. 4e physically and mentally fit for public service and live within his income.(.
,xpose corrupt practices in the public services without fear or favor.
:'. 01., 12 ,T/I0# 215 3+4*I0122I0,5# )-. ,93*16,,#(I. #erve the public
courteously! "ustly and impartially regardless of Hinship! friendship! social standing! religious or
political differences(II. .ischarge duties promptly without thought of gifts! benefits or any
remuneration which may influence the proper performance of official functions.(III. ,ngage in no
business with the 7overnment or with any private party! either directly or indirectly! which will be
inconsistent with his position as a public servant.I?. .ivulge no confidential information coming to
him by the nature of his office or duties.
::. 01., 12 ,T/I0# 215 3+4*I0122I0,5# )-. ,93*16,,#?. +phold! respect! and observe
these principles! ever conscious that public office is a public trust which he should neither violate! nor
should he allow suspicion to raise that such has been abused or betrayed. 9emorandum 0ircular -o.
'E@ was issued on 9arch $E! '@A> by the 3resident of the 3hilippine 5epublic
:$. 5,2,5,-0,#J= Lose 3. *everiza. 0hapter :EJ (alue and ,thics of 3ublic 5esponsibility.
3ublic )dministrationJ The 4usiness of 7overnment. #econd ,dition= 7oogle images for the
pictures and icons= 6ouTube(Lanuary :'! :E'E). cccvideovault. What are community values;.
5etrieved from httpsJIIwww.youtube.comIwatch;vMeCz:5A'6+(E
215 61+5 351T,0TI1-! .1 -1T +#, ) 71(,5-9,-T 3/1-,! 2)?! 15 0193+T,5 T1
01-T)0T 3171
The 3ro"ect 1n 7overnment 1versight has a long history of worHing with individuals daring to expose
corruption. 9any of these individuals with whom 3171 has worHed choose to remain anonymous to
the public and even to 3171 itself.
If you have information regarding fraudulent or wasteful activities in the government or the industries
it regulates! and you would liHe to expose it in order to Heep the government accountable to its citizens!
please contact us.
3171 may be able to further research your concerns! bring public attention to any wrongdoing! and
alert those who can bring about change. WeNve been watchdogs since '@&'.

The .ownside of OWhistleblowingO or exposing corruption
Whistleblowing is often not easy. ,xposed whistleblowers are almost always reprimanded! fired! andIor
harassed! even if they have not Ogone publicO and even if their allegations are proven to be true. It taHes
a lot of courage and forethought to taHe on a powerful government agency or a private contractor. The
mental! emotional! and fiscal hardships that a whistleblower may encounter should be fully understood
before any steps are taHen to disseminate information 8 publicly or not.
In recent years! protections for federal employees have been unraveled by hostile "udicial rulings. )s a
result! federal employees have little protections against retaliation.

,xpose 0orruption )nonymously
4y worHing with 3171 anonymously! the whistleblower generally does not risH retaliation or
"eopardize his or her career. It is entirely up to the whistleblower to provide 3171 with the necessary
information! documents! or leads. This allows the whistleblower to expose the wrongdoing while
lowering the risH of being attacHed. In the past 3171 has worHed with whistleblowers who remain
anonymous even to 3171. +nless you have already been publicly labeled as a whistleblower! we
usually do not recommend coming forward publicly and exposing yourself to the many risHs associated
with doing so.

/ow8to 7uide for 3ublic ,mployees ,xposing 3roblems
The )rt of )nonymous )ctivism

Three national nonprofits have "oined forces to help public employees who blow the whistle on waste!
fraud! or abuse by releasing a how8to manual! The )rt of )nonymous )ctivismJ #erving the 3ublic
While #urviving 3ublic #ervice. 0iting the increased dangers of whistleblowing! the support groups
hope the guide will allow more public employees to come forward while avoiding retaliation from
agencies seeHing to hide their foibles and corruption.
0licH here to read 0hapter ' of The )rt of )nonymous )ctivismJ #erving the 3ublic While #urviving
3ublic #ervice. 0licH here to order a copy online.
OThe )rt of )nonymous )ctivism gives us the tools and guidance necessary to NmaHe noiseN in defense
of our fellow citizens while protecting ourselves from harm.O
88 2ranH #erpico (in forward to the booH)

/ow 3171 0hooses Its 3ro"ects
The following are the criteria 3171 uses to determine which pro"ects we pursue. They do not present
rigid guidelines! but provide us with a consistent way to evaluate our priorities.

0apacity to maHe a uniDue contribution
1pening for positive systemic change in the federal government
)bility to broaden public awareness
+rgency for action
)vailability of inside sources andIor documents
2or more information on how 3171 worHs on its pro"ects! see our )bout page.

What 3171 .oes -ot .o
We do not deal with local and state issues unless federal money is involved.
We do not provide legal advice or representation. 9oreover! we will not recommend a specific legal
counsel.
We do not looH at individual cases of fraud or waste unless they are directly representative of systemic
or wide spread problems in the federal government andIor its contractors.
)lthough 3171 evaluates every lead we receive! because we are a small organization! we are unable
to pursue every case. ThanH you for understanding our intentions and limitations.
If your information does not involve the federal government then we cannot taHe your case! but may be
able to refer you to another organization. 0licH here for other resources.

5,315T 0155+3TI1- 2159 P
What organization(s)Igovernment agencyIgovernment contractor is involved in the alleged
wrongdoing;

What is the specific wrongdoing of which you have Hnowledge; 4e as specific as possible by
providing detailed information.
Is the wrongdoing still going on; If no! when was the activity suspended;
.o you have documents or other physical evidence that you would be able to send us to support your
claim if 3171 taHes your case;
.o you Hnow if this wrongdoing is occurring elsewhere or is it limited to your officeIregionIbranch;
Who have you told of the possible wrongdoing (co8worHers! supervisors! other organizations! etc);
1ther than those you may have told! are others also aware of this wrongdoing;
What adverse action has occurred against you (if any);
9ay we contact you; 6es or -o
If not! please give us as much detail about the substance of the waste! fraud! or abuse as possible! and
contact us during regular business hours in about 'E worHing days. We are liHely to have follow8up
Duestions.
/ave you been in contact with the media; 6es or -o
Is it 1C if 3171 contacts the media about your case; 6es or -o
3hilippinesJ Integrity Indicators #corecard
3hilippinesJ Integrity #corecard 5eport Q #ub80ategoryJ Whistle8blowing 9easures
Indicators #core
<& )re employees protected from recrimination or other negative conseDuences when reporting
corruption (i.e. whistle8blowing); A$
<@ Is there an internal mechanism (i.e. phone hotline! e8mail address! local office) through which
civil servants can report corruption; 'EE
>E In practice! is the internal mechanism (i.e. phone hotline! e8mail address! local office) through
which civil servants can report corruption effective; %>
Indicator and sub8Indicator .etails
<& )re employees protected from recrimination or other negative conseDuences when reporting
corruption (i.e. whistle8blowing);

<&aJ In law! civil servants who report cases of corruption! graft! abuse of power! or abuse of
resources are protected from recrimination or other negative conseDuences.

#coreJ 6,# -1 score
0ommentsJ There are several laws that protect and reward people who provide information
against corrupt practices and other crimes such as 5) A@&' and 3. %<@. /owever! these laws apply to
witnesses andIor complainantsK not directly to whistle8blowers.
)ccording to the )I9#8/ills 7overnance 5esearch on whistle8blowing in the 3hilippines! there are
eight pending whistle8blowing bills in the /ouse and #enate. )lmost all of the bills seeH to strengthen
the accountability! integrity! and responsiveness of public officials and employees. It is observed that
there is an emerging consensus on designing a whistle8blowing legislation primarily as an anti8
corruption measure.
5eferencesJ Witness 3rotection! #ecurity and 4enefit )ct! 5) A@&'. R *I-C S
3residential .ecree %<@ 8 7ranting Immunity from 3rosecution to 7ivers of 4ribes and 1ther 7ifts and
to their )ccomplices in 4ribery and 1ther 7raft 0ases )gainst 3ublic 1fficers. R *I-C S
<&bJ In practice! civil servants who report cases of corruption! graft! abuse of power! or abuse of
resources are protected from recrimination or other negative conseDuences.

#coreJ 'EE %> >E :> E score
0ommentsJ The culture does not encourage whistle8blowing. In fact! one of the main reasons
why people do not report corrupt practices is because of its negative conseDuences. 9ost often!
whistle8blowers are fired and become ostracized by friends and co8worHers. The fear generated by such
retaliation creates a chilling effect on the willingness of people to come forward.
The anti8corruption party list 0I4)0 relates that they have encountered many cases where citizens
were harassed or discriminated against for filing formal charges against public officers and employees.
To avoid negative conseDuences! reports are done anonymously. /owever! this limits the availability of
information to pursue the caseIcomplaints.
5eferencesJ 3hone interview with Carina 0. .avid! former 0ivil #ervice 0ommission chairwoman and
officer of 2ormer #enior 7overnment 1fficials (2#71)! #ept. 'A! :EE&.
,8mail interview with attorney 2redericH 9iHhail 2arolan! chief of staff! 0itizensN 4attle )gainst
0orruption (0I4)0) party list! /ouse of 5epresentatives! #ept. '%! :EE&! Tuezon 0ity.
UWhistleblowing in the 3hilippines )wareness! )ttitudes and #tructuresU. )I9#8/ills 7overnance
0enter. R *I-C S
<&cJ In law! private sector employees who report cases of corruption! graft! abuse of power! or
abuse of resources are protected from recrimination or other negative conseDuences.

#coreJ 6,# -1 score
0ommentsJ There are several laws that protect and reward people who provide information
against corrupt practices and other crimes such as 5) A@&' and 3. %<@. /owever! these laws apply to
witnesses andIor complainantsK not directly to whistle8blowers.
Internally! some big companies have their own whistle8blowing policy liHe the 3hilippine *ong
.istance Telephone (3*.T)! one of the 3hilippine companies listed on the -ew 6orH #tocH ,xchange
(-6#,). 4ecause of this! it needs to comply with -6#,Ns regulatory reDuirements such as #ection <E<
of the #arbanes81xley )ct! a landmarH +nited #tates law on corporate accountability! which reDuires
companies to establish internal control structures and procedures including an internal whistle8blowing
policy. The policy protects a whistle8blower who identifies himself or herself by defining the
punishable actions that constitute retaliation against a whistle8blower.
1f the eight pending whistle8blowing bills in 0ongress! at least three seeH to strengthen corporate
accountability or clearly apply to whistle8blowing in the private sector.
In practice! liHe in the civil service! private sector employees report anonymously to avoid negative
conseDuences of blowing the whistle.
5eferencesJ Witness 3rotection! #ecurity and 4enefit )ct! 5) A@&'. R *I-C S
7ranting Immunity from 3rosecution to 7ivers of 4ribes and 1ther 7ifts and to their )ccomplices in
4ribery and 1ther 7raft 0ases )gainst 3ublic 1fficers! 3. %<@. R *I-C S
UWhistleblowing in the 3hilippines )wareness! )ttitudes and #tructuresU. )I9#8/ills 7overnance
0enter. R *I-C S
<&dJ In practice! private sector employees who report cases of corruption! graft! abuse of power!
or abuse of resources are protected from recrimination or other negative conseDuences.

#coreJ 'EE %> >E :> E score
0ommentsJ The personal risHs also apply to whistle8blowers in the private sector. These risHs
include the loss of "ob and other retaliatory actions at worH! ostracism by colleagues! severance of
social relationships and threats to personal security and safety.
5eferencesJ UWhistleblowing in the 3hilippines )wareness! )ttitudes and #tructuresU. )I9#8/ills
7overnance 0enter. R *I-C S
3eer 5eview 0ommentsJ Whistleblowers have been Hilled in the 3hilippines. -ot always or even often!
but the recriminations can be very severe.
<@ Is there an internal mechanism (i.e. phone hotline! e8mail address! local office) through which
civil servants can report corruption;

<@J In law! is there an internal mechanism (i.e. phone hotline! e8mail address! local office)
through which civil servants can report corruption;

#coreJ 6,# -1 score
0ommentsJ There is no legislated mechanism in which civil servants can report corruption.
/owever! there are existing programs launched by the 0ivil #ervice 0ommission and the 1ffice of the
1mbudsman establishing these sort of mechanisms using e8mail! hotlines! and text messages (#9#).
These reporting mechanisms are designed for the general public but include civil servants. There are
also -71 hotlines! such as 4antay CaliHasan! that are available to the public to report corrupt
environmental practices.
The reporting mechanism of the 0#0 is not primarily designed as an anti8corruption mechanism but for
complaints on inefficiency and discourtesy of civil servants! though petty graft and corruption are also
reported and dealt with.
5eferencesJ 3hone interview with Carina 0. .avid! former 0ivil #ervice 0ommission chairwoman and
officer of 2ormer #enior 7overnment 1fficials (2#71)! #ept. 'A! :EE&.
,8mail interview with attorney 2redericH 9iHhail 2arolan! chief of staff! 0itizensN 4attle )gainst
0orruption (0I4)0) party list! /ouse of 5epresentatives! #ept. '%! :EE&! Tuezon 0ity.
>E In practice! is the internal mechanism (i.e. phone hotline! e8mail address! local office) through
which civil servants can report corruption effective;

>EaJ In practice! the internal reporting mechanism for public sector corruption has a
professional! full8time staff.

#coreJ 'EE %> >E :> E score
0ommentsJ The 1ffice of the 1mbudsman faces a lacH of funds! manpower and eDuipment! but
meager resources have not prevented it from performing its duties. ) series of grants from international
donors allows the 194 to investigate cases sourced from the World 4anH! the ,uropean +nion!
)us)I.! +#)I. and the 900.
The 0ivil #ervice 0ommission as a constitutional body receives automatic appropriations.
5eferencesJ 7abriella Tuimson! 3hilippine -ational Integrity #ystem #tudy! :EEA.
O1mbudsman meager resources not an obstacle in doing its "ob!O government Web site! Luly :&! :EE>. R
*I-C S
)ttorney 5odolfo ,lman of the 1ffice of the 1mbudsman in 9indanao! during the 0lub &&& 2orum in
.avao 0ity! 9arch >! :EE&.
3hone interview with Carina 0. .avid! former 0ivil #ervice 0ommission chairwoman and officer of
2ormer #enior 7overnment 1fficials (2#71)! #ept. 'A! :EE&.
3eer 5eview 0ommentsJ That the 1ffice of the 1mbudsman under the leadership of 9erceditas
7utierrez has been performing its duties remains Duestionable in the minds of many people. 5eports of
infighting and demoralization within the 1ffice of the 1mbudsman! as well as the Duestionable
integrity of some of its officials and perceived partiality of 7utierrez! have significantly diminished the
generally good reputation that the agency en"oyed under former 1mbudsman #imeon 9arcelo.
#ee O5oxasJ 1mbudsman fails in duty to Nprotect the people!NO )4#804- -ews website! -ov. :! :EE&!
R *I-C S
O1mbudsman sacHs (illa8Ignacio! team from T00 cases!O -ov <! :EE&! 79) -ews website! R *I-C S.
3eer 5eview 0ommentsJ I would put it a little lower 8 >E.
>EbJ In practice! the internal reporting mechanism for public sector corruption receives regular
funding.

#coreJ 'EE %> >E :> E score
0ommentsJ 4oth the 1ffice of the 1mbudsman and the 0ivil #ervice 0ommission are
constitutional bodies having yearly earmarHed public funding.
5eferencesJ 3hone interview with Carina 0. .avid! former 0ivil #ervice 0ommission chairwoman and
officer of 2ormer #enior 7overnment 1fficials (2#71)! #ept. 'A! :EE&.
'@&% 3hilippine 0onstitution
3eer 5eview 0ommentsJ That is true! but they do not receive enough money to enable them to do their
"obs effectively.
>EcJ In practice! the internal reporting mechanism for public sector corruption acts on
complaints within a reasonable time period.

#coreJ 'EE %> >E :> E score
0ommentsJ 1mbudsman 7utierrez said allegations that they are sitting on cases and complaints
are not true and points out a number of Obig fishO cases that are being investigated.
With regard to the reporting mechanism in the 0#0! .avid! a former chairwoman! relates that in her
time with the commission! complaints on petty corruption liHe illegal use of official vehicle are dealt
with and responded to within one to two weeHs &E percent of the time.
5eferencesJ Interview with 1mbudsman 9erceditas -. 7utierrez! #ept. '&! :EE&! and R *I-C S
3hone interview with Carina 0. .avid! former 0ivil #ervice 0ommission chairwoman and officer of
2ormer #enior 7overnment 1fficials (2#71)! #ept. 'A! :EE&.
3eer 5eview 0ommentsJ Its protestations to the contrary notwithstanding! the 1ffice of the
1mbudsman has been widely criticized for its perceived nonaction on certain corruption cases! such as
the fertilizer scam involving a former agriculture undersecretary Hnown to be close to the first
gentleman. 3rior to this scandal! the office had cleared 0omelec officials of any any criminal liability in
the controversial '.$ billion peso (+#V :%.< million) poll computerization pro"ect with a private
company.
O1mbudsman report indicts Loc8"oc for fertilizer scam!O -ewsbreaH! Lune >! :EE&! R *I-C S
O#enators call on 1mbudswoman Nto save her officeNs integrity!O #un#tar 0ebu! 1ctober >! :EEA!
R *I-C S
3eer 5eview 0ommentsJ I thinH the interview sub"ects are being Hind to themselves and their former
colleagues.
>EdJ In practice! when necessary! the internal reporting mechanism for public sector corruption
initiates investigations.

#coreJ 'EE %> >E :> E score
0ommentsJ The 1ffice of the 1mbudsman is charged with five ma"or functionsJ public
assistance! graft prevention! investigation! prosecution and administrative ad"udication. In practice the
1mbudsman has initiated motu propio investigations including parallel investigations on ongoing
cases.
In the 0ivil #ervice 0ommission! complaints are endorsed to the concerned government agencies.
5egional offices arbitrate 0#08related complaints.
The 1ffice of the 1mbudsman has consistently been aggressive in investigating cases of corruption in
government. +nliHe the -ational 3rosecution #ervice under the .epartment of Lustice which
investigates only cases formally brought under its "urisdiction! the 1mbudsman investigates motu
propio cases filed in whatever form and in whatever manner. The 1ffice of the 1mbudsman has
investigated and successfully prosecuted 3resident ,strada! a 3resident of the 5epublic of the
3hilippines! and has also investigated a former #ecretary of Lustice! -ani 3erez. .uring the 3erez
hearings! the ombudsman also summoned the 2irst 7entleman! her former classmate! to participate in
the investigation.
5eferencesJ R *I-C S. 5) A%%E #ec '> (')J OInvestigate and prosecute on its own or on complaint by
any person! any act or omission of any public officer or employee! office or agency! when such act or
omission appears to b illegal! un"ust! improper or inefficient.O
3hone interview with Carina 0. .avid! former 0ivil #ervice 0ommission chairwoman and officer of
2ormer #enior 7overnment 1fficials (2#71)! #ept. 'A! :EE&.
3eer 5eview 0ommentsJ The 1ffice of the 1mbudsman is consistently perceived to be selective in its
pursuit of cases to investigate and prosecute! allegedly running only after the small fish while letting
the big ones get away with their misdeeds.
/ow to stop fraud and corruption in the worHplace
WhatNs the best approach for stopping fraud and corruption;
The Hey deterrent of fraud and corruption is awareness and prevention. #ome of the processes which
are deemed most effective involve denial of opportunity! effective leadership and oversight! auditing
and pre8employee screening.
.enial of opportunity may be translated in the form of internal controls and consistently adhering to
clearly defined procedures established by the +niversityNs leadership.
WhatNs wrong with "ust trusting people;
-obody wants to doubt co8worHers and their honesty.
In fact! most people will not engage in fraudulent and corrupt conduct. /owever! we must understand
and accept the reality that fraud is possible and some people will be corruptW
)ll too often in the past! Otrusted employeesO in organisations have been given the OHeys to the
HingdomO with little or no oversight and control! leaving the door wide open for fraudulent or corrupt
behaviour.
Trust is important X but trust is not an internal controlW 5elying on trust alone is asHing for trouble
particularly in those areas of an organisation where this is a greater risH of that trust being breached.
If you do not believe that fraud and corruption is possible in the worHplace! you will never identify it!
even if it is clearly evident. (ery often symptoms (i.e. red flags 8 refer to 3ortrait of a 2raudster 8
what to looHout for) may be viewed as administrative errors because individuals cannot conceive of the
existence of fraud or corruption particularly where there is a long time affiliation with co8worHers.
Why isnNt it enough to "ust sanction someone once such behaviour is identified;
5emember the fraud triangle; #imply punishing a person who has been caught committing a fraud is
not a totally effective way to deter fraud. #ome of the reasons are as followsJ
) fraudster will only commit fraud when there is a perceived opportunity to solve their problems in
secret. They donNt anticipate getting caught! so the threat of sanctions doesnNt really carry any weight
i.e. they donNt expect to face them.
If a fraudster rationalises their conduct! to them it is legal or "ustified. Thus! they donNt see their actions
as something that should be sanctioned.
2raudsters greatly fear that their behaviour will be detected. The threat of sanctions is only ever a
secondary consideration.
What can I do to deter fraudulent and corrupt behaviour;
To effectively deter fraud and corruption! you need toJ
be aware of where fraud and corruption is liHely i.e. understand and manage the areas of risH under
your controlK
have a good understanding of why people may engage in fraudulent or corrupt activity i.e. understand
the components of the fraud triangle and be on the looHout for red flagsK and
always Odo the right thingO! and encourage others to do the same.
What is Odoing the right thingO;
2or all staff! doing the right thing means living the +niversityNs values! and worHing and behaving in
accordance with the 0ode of 0onduct! #taff ,nterprise )greementI,mployment 0ontracts! +niversity
policy frameworH and all relevant laws and regulations.
)s a manager! it means Oleading by exampleO (i.e. setting the right tone! walHing the talH) and taHing
appropriate steps to ensure that your internal controls are adeDuate and operating effectively toJ
prevent fraud and corruption from occurringK and
detect and appropriately respond (as soon as possible) to any incidences should they be found or
suspected.
5egardless of who you are! what you do! or what youNre responsible for! it also meansJ
saying -1W to anything that sounds or looHs suspicious! improper or illegalK and
having the courage to speaH out and speaH up when you see something that "ust doesnNt looH or feel
right.
Watch this video produced by the )merican Institute of 0ertified 3ublic )ccountants and the )02,
()ssociation of 0ertified 2raud ,xaminers) to see how things can go terribly wrong when the Otone at
the topO is not right in an organisation.
What are some essential internal controls for deterring fraudulent and corrupt behaviour;
The following basic internal controls are a good starting point for ensuring a low fraud and corruption
worHing environmentJ
#egregation of duties! to prevent one person from undertaHing an entire transaction alone.
0learly established lines of delegated authority and responsibility.
3osition descriptions that clearly represent the "obs people actually do.
0ompulsory clearance of overdue accumulated leave! particularly for those in Hey positions of trust.
Lob rotation (wherever possible)! again for those in Hey positions of trust.
#taff awareness! education and training to ensure all staff are aware of and can recognise the signs of
possible fraudulent or corrupt behaviour.
)deDuate protective measures for safeguarding! assets! processes and data.
.ocumentation retained and managed in accordance with records management policy.
) worH environment where people feel comfortable in raising concerns and are not penalised for doing
so.
1ngoing management oversight I monitoring of worH functions to verify that controls are operating
effectively e.g. reconciliations! confirmations! exception reports.
/ow can I improve my Hnowledge of how to prevent and deal with fraud and corruption;
/ere are some hypothetical case studies which illustrate the types of fraudulent or corrupt acts that can
taHe place in the worHplace! the risHs that the +niversity may be exposed to from these acts! and what
can be done to preventIminimise or manage them.
#ee how well you understand the risHs raised in each case and consider what you wouldIcould do if
faced with the same circumstancesW
0ase #tudy -o. ' 8 0orruption in the procurement of services
0ase #tudy -o. : 8 Theft in the worHplace
0ase #tudy -o. $ 8 2raudulent corporate card expenses
0ase #tudy -o. < 8 0onflict of interest involving receipt of gifts
0ase #tudy -o. > 8 5esearch misconduct (an interactive video from the +# 1ffice of 5esearch
Integrity)