New Commissioner of Taxation Rob Heferen has started to put his personal leadership stamp on the growing organisation’s culture and values, revealing a comprehensive refresh of the agency’s Integrity Framework as it re-applies human muscle to eliminating fraud and corruption inside and out.

Heferen will on Tuesday write to all Australian Taxation Office staff, setting out his expectations and drawing their attention to the reworked document in the wake of unexpected losses from a surge in first-person GST refund claim fraud and a recent high-profile corruption and bribery conviction for a former APS5 tax officer who was gaoled for 30 months earlier this year.

About 150 ATO staff were investigated underOperation Protego, the crackdown on fake GST refund claims that chalked up almost $2 billion in payments for bogus claims, propelled by posts on TikTok.

“Everything we do at the ATO has a foundation in integrity. It informs our compliance activities and efforts to deliver value for government and taxpayers, and is woven through our culture,” Heferen told ATO staff.

“Having such a strong focus on integrity requires ongoing work from all of us. It’s a commitment and not something we can set and forget. This need for continuous improvement drove the establishment of the APS Integrity Taskforce in 2023, and it’s in this same spirit that today I’m launching our refreshed ATO Integrity framework.”

The catalogue of “integrity threats” listed by the ATO in the refreshed Integrity Framework is comprehensive.

It includes the stock-standard “inappropriate, unethical or corrupt conduct”, “careless or ill-judged (albeit well-intentioned) actions”, “ignorance of, or total disregard for, legal and ethical obligations” and the ever-present risk of “conflicts of interest, outside employment, personal associations, and gifts and benefits, not declared or appropriately managed”.

However, some grey-zone risks indicate a tightening of how influences and persuasion are applied to the ATO in the wake of the PwC scandal and the resulting consultant crackdown.

“Unethical recruitment processes and practices” get a specific mention as do “staff using their ATO position to favour prospective employers while still employed with the ATO”, “not knowing when, or how to report inappropriate behaviour”, and “enabling inappropriate behaviour”.

One of the more contemporary threats listed is “inconsistent, biased or unethical decision making”, which strongly suggests humans need to be in charge and directly accountable for automated processes and modelling scenarios.

Checking for bias and ethical considerations is certain to become more prominent across compliance functions for all APS agencies as the government continues to experiment with artificial intelligence and process automation.

The integrity framework dedicates a whole page to “maintaining system integrity”, with specific threats listed for loose access control and leakage of information, “vulnerabilities in business processes that provide exploitation opportunities” and “not managing conflicts arising from the ‘revolving door’ of staff moving from public service to private sector”.

Heferen told staff he wants them to “keep integrity at the forefront” and encouraged them to “make time to review the ATO Integrity framework, and have regular integrity conversations with your manager and team.”

“The framework guides us to ensure we are a fair and ethical organisation; however, I want to highlight that integrity starts with you. As an ATO employee, you play a critical role in strengthening and maintaining integrity in the ATO,” Heferen said.

“If you see or hear something that might be wrong, call it out.”


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