IPC Statement of Business Ethics

Read the document below or download it here: IPC Statement of Business Ethics October 2023

Purpose

This statement sets out the ethical values that the Information and Privacy Commission (IPC) expects when conducting business. IPC’s ethical standards are enshrined in our Code of Conduct and other governance policies.

The IPC expects its staff to behave ethically and that suppliers, contractors and consultants to the IPC comply with these standards when conducting business with the IPC. This Statement also outlines what you can expect from the IPC when conducting business with us.

What you can expect from us

Under our Code of Conduct, IPC staff are accountable for their actions and are expected to:

• act with integrity and avoid conflicts between their personal interests and professional duties;
• respect and follow IPC’s policies and procedures;
• use public resources effectively and efficiently;
• make decisions solely on merit;
• protect confidential information;
• never solicit or accept payment, gifts or other benefits from a supplier for the discharge of official duties; and
• record and give reasons for decisions (where appropriate).

What we expect from you

We expect suppliers, contractors and consultants to:

• comply with relevant IPC policies and procedures;
• provide accurate and reliable advice and information when required;
• declare actual or perceived conflicts of interest as soon as you become aware of them;
• act ethically, fairly and honestly in all your dealings with, and on behalf of, IPC;
• respect the obligation of IPC staff to abide by our Code of Conduct and other policies;
• maintain records of services provided to the public on behalf of the IPC in accordance with Section 121 of the Government Information (Public Access) Act 2009, and provide access to this information upon request;
• not engage in collusive practices;
• prevent the unauthorised release of privileged information, including confidential information;
• refrain from discussing IPC dealings with the media, except with IPC’s consent;
• not offer IPC staff any financial or other inducement which may give any impression of unfair advantage; and
• report to IPC any suspected breach of these ethical standards.

 Why do you need to comply

IPC only wishes to do business with consultants, contractors and suppliers that share our values and ethics. By complying with our Statement of Business Ethics you will be able to advance your business interests in a fair and ethical manner and be certain in the knowledge that others dealing with the IPC are doing the same.

Consequences for not complying with IPC’s ethical requirements could include:

• termination of contracts;
• loss of future work opportunities; and
• loss of reputation.

Conflicts of interest

A conflict of interest exists where a reasonable and informed person would perceive that an individual could be influenced by a private interest when carrying their public duty. A conflict of interest may involve avoiding a personal disadvantage as well as gaining a personal advantage. Conflicts of interest that lead to partial decision‐making may constitute corrupt conduct.

Perceptions of a conflict of interest can be as important as actual conflicts of interest. Conflicts of interest must be avoided or managed in order to uphold the probity of IPC decision‐making. Consultants, contractors and suppliers doing business with IPC are required to disclose, in writing, any perceived or actual conflicts. Such disclosures will be recorded on the relevant file.

Confidentiality

All IPC information must be treated as confidential unless otherwise indicated in writing. All communication between IPC and consultants, contractors and suppliers should be clear, direct and accountable to minimise the risk of perception of inappropriate conduct.

Gifts and benefits

The IPC expects its staff to declare any gifts and benefits received during the course of their work, in accordance with the IPC’s Gifts and Benefits Policy. Consultants, contractors and suppliers should not offer any such incentives to IPC staff.

Sponsorships

Any sponsorship arrangements whether in‐kind or financial, must not interfere with the ability of the IPC to carry out its regulatory functions and such processes must be open and transparent. All arrangements will be considered in accordance with the IPC’s Sponsorship/Strategic Partnership Policy.

Work Health and Safety

It is expected that the IPC and those who conduct business with the IPC will ensure that workers and visitors’ health and safety is of paramount importance and that all legislative and procedural safety requirements are complied with.

Reporting wrongdoing

If you have any questions regarding this Statement of Business Ethics or to provide information about suspected unethical behaviour, fraud, corrupt conduct, maladministration or substantial waste please contact the IPC directly by letter, e-mail or phone.

Public officials reporting about this type of conduct can be protected by the Public Interest Disclosures Act 2022. This Act protects public officials from reprisal or detrimental action and ensures reports are properly investigated and dealt with. You are encouraged to make these reports to the IPC if you believe you are aware of wrongdoing. Reports may also be made to:

• The Independent Commission Against Corruption (ICAC) ph. 02 8281 5999.
• NSW Ombudsman ph. 1800 451 524
• The Information and Privacy Commission ph. 1800 472 679

Related documents

The following documents provide additional guidance and should be read in conjunction with this policy.

• IPC Code of Conduct
• IPC Gifts and Benefits Policy
• IPC Sponsorship/Strategic Partnership Policy
• IPC Public Interest Disclosures Internal Reporting Policy