As sector distinctions between public and private spheres become ever more blurred, the Committee on Standards in Public Life ('the Committee') has this month published useful new high level ethical guidance, which applies equally to public and private sector providers. The role of commissioners of public services and the importance of examining the whole supply chain is also highlighted.
The new guidance can be downloaded here – it is short and practical, and is designed to emphasise the key messages in the longer report on ethical standards in public life published by the Committee in 2014 (please click here to read a copy of the full 2014 report).
The guidance published this month highlights that all those delivering services to the public, whether public, private or voluntary organisations, should ensure that they have a high level ethical framework and ethical capability, which includes
- principled leadership and governance: including Board level modelling and oversight
- clear lines of accountability; and
- a culture of dialogue, challenge and transparency which is embedded throughout the organisation.
A risk-based approach is recommended, which should be proportionate and flexible; how that is implemented will depend on the model of delivery and the kind of provider.
As ever, however, the devil is the detail of how to achieve the aims outlined above and the Committee's new guidance sets out practical examples, 'what hurts and what works', checklists and real life case studies. It also suggests a range of specific tools to assist with implementing the recommendations in the guidance, including
- whistleblowing policies / 'speaking up' mechanisms
- gifts and hospitality registers
- anti-bribery and corruption policies
- declarations of interests requirements
- procedures for dealing with conflicts of interest.
This latest guidance is the most recent in a series of new developments demonstrating an increasing emphasis on organisations not only embedding and policing their own ethical standards, but also dealing effectively with poor standards – for example, private and public sector organisations must now comply with the anti-corruption requirements of the Bribery Act 2010, scrutiny of supply chains under the Modern Slavery Act 2015 and an increased focus on 'whistleblowing' protections – and, in addition, consultation is currently open on a new single whistleblowing policy for providers to the NHS, including independent providers of NHS services.
Please do contact us if you require advice or assistance with implementing any of the above requirements – whether in respect of drafting and actively embedding the relevant policies and procedures in your organisations, training directors or your management team, or undertaking health checks or audits of your organisation.
Please click here for a copy of our briefing on the Modern Slavery Act, which affects organisations with financial year ends on or after 31 March 2016.
Please click here for details of our services in relation to raising concerns / 'whistleblowing'.