Code of conduct

Introduction

At WorkCover Queensland (WorkCover) we conduct our business according to the highest standards of ethical conduct. It is expected that all employees meet these standards of conduct and support the vision and values of WorkCover.

The purpose of the Code is to provide you with a clear understanding of the standard of conduct expected when performing your duties or representing WorkCover at conferences, training events, on business trips and attending work-related social events.

The Code places an obligation on all employees to take accountability for their own conduct.  To achieve this, all employees of either WorkCover Employing Office or WorkCover Queensland are expected to familiarise themselves with and act in accordance with this Code.

Framework for ethical conduct

The Code does not attempt to provide an exhaustive list of what to do in all situations, instead the Code represents a broad framework of ethical conduct that you have an obligation to uphold.

The Public Sector Act 2022 also provides the basis for disciplinary action for those who fail to meet their obligations.

The standards of conduct in the Code are based on the four ethics values contained in the Public Sector Ethics Act 1994 (Qld).  The ethics values which are considered essential for the performance of public administration in Queensland are:

• integrity and impartiality
• promoting the public good
• commitment to the system of government
• accountability and transparency.

The Code was developed in consultation with employees and those organisations that represent their interests. Through this consultative approach, the Code was developed to reflect the operational needs of WorkCover Employing Office and WorkCover Queensland and provides a basis for high standards of ethical conduct in the way you do your work. The Public Sector Act 2022 provides the basis for disciplinary action for those who fail to meet their obligations.

Application of the Code

The Code applies to all employees whether they are permanent, fixed-term temporary (full-time or part-time); agency supplied temporary staff, casual or a contractor.

The Code applies to WorkCover Queensland or WorkCover Employing Office or WorkCover Queensland and WorkCover Employing Office, each of which hereinafter is referred to as WorkCover.

In applying the Code you are to consider both the 'spirit' and 'content' of the Code. If you are in any doubt as to the meaning of the Code or its application in any given situation, you should seek advice from your manager.

As an employee of WorkCover and, therefore, an employee of a government entity, you have a responsibility to conduct yourself in a manner that will not undermine public confidence in the integrity of WorkCover.

Employees who have human or financial resource management accountabilities (i.e. managers or team leaders) have the responsibility of monitoring the use of WorkCover resources and the performance of employees. Managers are also responsible for taking the appropriate action where an employee breaches the Code of Conduct.

In every aspect of your work with WorkCover you are obliged to act in the public interest. Acting in the public interest means faithfully and impartially implementing legislation and the policy intentions of the elected Government and the WorkCover Board.

Your obligation under the Code

The Code sets out your obligations in relation to each of the four ethics principles. The practical application of each principle involves you in meeting an obligation to apply a standard of conduct which is wholly consistent with the 'spirit' and 'intent' of the principle. It is important to remember that there may be situations where you will be called upon to demonstrate sound judgement in the application of the Code to ensure the public interest is met.

This code is to be read in conjunction with any relevant WorkCover policy as referred to herein.

Note: all policies are accessible via the SharePoint Polices Page

Value 1: Integrity and impartiality

Ethics Obligation

A WorkCover employee is to promote public confidence in the integrity of the public sector and WorkCover and should:

• be committed to the highest ethical standard;
• accept and value their duty to provide advice which is objective, independent, apolitical and impartial;
• show respect towards all persons, including employees, clients and the general public;
• acknowledge the primacy of the public interest and undertake that any conflict of interest issue will be resolved or appropriately managed in favour of the public interest; and;
• be committed to honest, fair and respectful engagement with the community.

Required standards of conduct

1.1 Commit to the highest ethical standards

As WorkCover employees we are required to ensure that our conduct meets the highest ethical standards when we are fulfilling our responsibilities.  We will:

• ensure any advice that we provide is objective, independent, apolitical and impartial
• ensure our decision making is ethical
• engage with the community in a manner that is consultative, respectful and fair
• meet our obligations to report suspected wrongdoing, including conduct not consistent with this code.

1.2 Manage conflicts of interest

A conflict of interest involves a conflict between our duty, as WorkCover employees, to serve the public interest and our personal interests. The conflict may arise from a range of factors including our personal relationships, our employment outside the public service, our membership of special interest groups, or our ownership of shares, companies, or property. As public service employees we may also experience conflicts of interest between our public service ethics and our professional codes of ethics (for example as health care professionals or as lawyers), or with our personal beliefs or opinions.

Having a conflict of interest is not unusual and it is not wrongdoing in itself. However failing to disclose and manage the conflict appropriately is likely to be wrongdoing. As employees we are committed to demonstrating our impartiality and integrity in fulfilling our responsibilities and as such we will:

• always disclose a personal interest that could, now or in the future, be seen as influencing the performance of our duties;
• actively participate in developing and implementing resolution strategies for any conflict of interest; and;
• ensure that any conflict of interest is resolved in the public interest.

1.3 Contribute to public discussion in an appropriate manner

Commenting on WorkCover policy is a matter for the Board, the CEO and Government Ministers, not employees. Unless prior authorisation has been given, we will not comment to the media directly or through social media platforms on WorkCover policy.

Where providing factual information to the public on WorkCover policy is a part of our official duties and responsibilities, we will ensure that information is appropriately authorised, and that we properly represent WorkCover policy and administration in its intended manner and spirit. Like any other citizen, we have the right to contribute to public discussions on community and social issues in our private capacity. In doing so, we will:

• take reasonable steps to ensure that any comment we make will be understood as representing our personal views, not those of WorkCover and/or the government;
• maintain the confidentiality of information we have access to due to our roles, that is not publicly available; and;
• be aware that personal comments about a public issue may compromise our capacity to perform the duties of our role in an independent, unbiased manner.

1.4 Manage participation in external organisations

Our work does not remove our right to be active privately in a political party, professional organisation or trade union. As a member of a political party, however, we are aware that participating in activities in the public arena, where we may be identified as associated with a government department, can give rise to a perception of conflict of interest (see section 1.2). Where this situation arises, we will declare and manage our activities in accordance with our WorkCover’s policies. If we are elected as workplace representatives or officials of a trade union or professional association, we are not required to seek permission from our workplace before speaking publicly in that capacity, and we will make it clear that our comments are made only on behalf of that organisation. In all instances, we will comply with the appropriate laws of privacy, confidentiality and information management.

1.5 Demonstrate a high standard of workplace behaviour and personal conduct

We have a responsibility to always conduct and present ourselves in a professional manner, and demonstrate respect for all persons, whether fellow employees, clients or members of the public. We will:

• treat co-workers, clients and members of the public with courtesy and respect, be appropriate in our relationships with them, and recognise that others have the right to hold views which may differ from our own;
• ensure our conduct reflects our commitment to a workplace that is inclusive and free from all forms of harassment;
• ensure our fitness for duty, and the safety, health and welfare of ourselves and others in the workplace, whether co-workers or clients;
• ensure our private conduct maintains the integrity of the public service and our ability to perform our duties; and;
• comply with legislative and/or policy obligations to report employee criminal charges and convictions.

Value 2: Promoting the public good

Ethics Obligation

WorkCover employees are to recognise that we are mechanisms of the public sector through which elected representatives deliver programs and services for the benefit of the people of Queensland, public service agencies, public service authorities and public service officials.  Specifically this role is as the workers’ compensation insurer for the workers of Queensland.  Through this role, we accept and value our duty to:

• be responsive to both the requirements of the WorkCover board, the government and to the public interest;
• manage public resources effectively, efficiently and economically;
• achieve excellence in service delivery; and;
• achieve enhanced integration of services to better service clients.

Required standards of conduct

2.1 Commit to excellence in service delivery

WorkCover is entrusted with being the Queensland workers’ compensation insurer. We have a responsibility to:

• deliver services fairly, courteously, effectively, and ensure we use resources efficiently and economically;
• assist all members of the community, particularly people with disabilities, those who speak languages other than English, and those you may find it difficult to access government services and;
• treat complaints from clients and the community seriously and respond to constructive feedback as an opportunity for improvement.

2.2 Ensure appropriate community engagement

Community participation is crucial in WorkCover’s service delivery. We have a responsibility, where appropriate and in accordance with our official duties, to:

• listen and respond to issues and concerns raised by individuals or communities;
• consult with the public to assist with operations; and;
• assist in raising community awareness about WorkCover’s role and policies.

2.3 Work as an integrated service

In order to deliver excellence in customer service, we will work together to address complex issues and provide integrated services to the community. We have a responsibility, where appropriate and in accordance with our official duties, to:

• share information across Queensland public service agencies, where permitted by law, to enhance the seamless delivery of services;
• share common-use assets, accommodation, and infrastructure within Queensland public service agencies to generate economies and efficiencies; and;
• work cohesively at the local, regional, state and national levels to provide integrated services.

Value 3: Commitment to the system of government

Ethics Obligation

A WorkCover employee is to recognise that we have a duty to uphold the system of government and the laws of the state, Commonwealth and local government, public sector agencies, public sector entities and public officers and:

• accept and value their duty to uphold the system of government and the laws of the State, the Commonwealth and local government;
• are committed to effecting official WorkCover priorities, policies and decisions professionally and impartially; and;
• accept and value their duty to operate within the WorkCover framework.

Required standards of conduct

3.1 Commit to our roles in public sector

Our role is to undertake our duties, and to give effect to the policies of WorkCover and the elected government. We will:

• accept that the elected government and the board have the right to determine policy and priorities;
• be responsive to those policies and priorities and then to implement them professionally and impartially;
• comply with the laws of State, Australian and local governments;
• comply with all relevant awards, certified agreements, subsidiary agreements, directives, whole-of-government policies and standards; and;
• adhere to WorkCover’s policies, organisational values and organisational documents.

3.2 Maintain appropriate relationships with ministerial staff

Ministerial advisors and the public service share a common commitment to serving the government of the day.  Central to good government, and the ability to carry out the designated role of the public service, are positive and productive interactions between the administrative and political arms of government.  If providing advice to Ministers is a part of our role, we will ensure our interactions are positive and productive when engaging with ministerial staff.  Ministerial staff are not empowered to direct public service employees in their own right.  If this occurs, we will bring this to the attention of our agency’s senior management.

3.3 Ensure proper communication with members of parliament

We have the right to communicate directly with a Member of Parliament on any issue affecting us as a private citizen. In communicating with Members as private citizens, we will maintain the confidentiality of information that is not publicly available, and information we have access to due to the nature of our roles at WorkCover Queensland.

Value 4: Accountability and transparency

Ethics Obligation

WorkCover employees are to recognise that public trust in public office requires high standards of public administration, public service agencies, public sector entities and public officials:

• are committed to exercising proper diligence, care and attention;
• are committed to using public resources in an effective and accountable way;
• are committed to managing information as openly as practicable within the legal framework;
• value and seek to achieve high standards of public administration;
• value and seek to innovate and continuously improve performance; and;
• value and seek to operate within a framework of mutual obligation and shared responsibility between public service agencies, public sector entities an public office.

Required standards of conduct

4.1 Ensure diligence in public administration

We have an obligation to seek to achieve high standards of public administration and perform our duties to the best of our abilities. We will:

• apply due care in our work, and provide accurate and impartial advice to all clients whether members of the public, public service agencies, or any level of government;
• treat all people equitably and consistently, and demonstrate the principles of procedural fairness and natural justice when making decisions;
• exercise our lawful powers and authority with care and for the purpose for which these were granted; and;
• comply with all reasonable and lawful instructions, whether or not we personally agree with a given policy direction.

4.2 Ensure transparency in our business dealings

In order to ensure all WorkCover dealings with private industry are conducted with the highest level of integrity we will ensure:

• our business meetings with persons who were formerly Ministers, Parliamentary Secretaries or senior government representatives are not on matters those persons had official dealings with in their recent previous employment in accordance with government policy;
• any engagement we have with lobbyists is properly recorded; and;
• we manage gifts, benefits or hospitality in accordance with WorkCover policies.

4.3 Ensure appropriate use of official resources, public property and facilities

We are accountable for all resources that we use in the course of our duties. We will:

• be economical, and avoid waste and extravagance in the use of public resources for proper purposes;
• use any public resource in accordance with official policies;
• purchase, manage and care for public resources in accordance with official policies; and;
• responsibly utilise human assets such as corporate knowledge and intellectual property, as public resources.

4.4 Ensure appropriate use and disclosure of official information

The public has a right to know the information that is created and used by the government on their behalf. This right is balanced by necessary protections for certain information, including personal information. Information privacy legislation protects against the misuse of personal information and we have an obligation to ensure the lawful collection and handling of personal information. In addition, we will:

• treat official information with care and use it only for the purpose for which it was collected or authorised;
• store official information securely, and limit access to those persons requiring it for legitimate purposes; and;
• not use confidential or privileged information to further personal interests.

We will continue to respect the confidentiality of official information when we leave public service employment.

4.5 Commit to innovation and continuous performance improvement

The capacity of WorkCover to deliver workers’ compensation insurance services to the community depends on an innovative and creative workforce, and a commitment to continuously improve the performance of our agency and ourselves. We each have a responsibility, having regard to our own roles, to:

• maintain and develop our professional skills and knowledge;
• in consultation with our managers, take reasonable steps to identify and apply for development opportunities relevant to our current roles and responsibilities;
• actively participate in employee performance management processes, including induction, performance planning and development; and;
• actively contribute to developing and improving business planning and processes, including innovative ways of delivering services.

A guide for ethical decision making

The guide below gives some things to consider in light of your obligations under the Code.  It will not make the decision for you, but it will help you to analyse all the relevant facts and circumstances of a situation to reach a decision.

Step 1. Identify and assess the situation

• What do you want to do?
• What are the facts and circumstances of the situation?
• Does it break the rules, of the law, or is it inconsistent with Government policy?
• Is this consistent with your obligations under the Code?
• What ethical principle or principles does it relate to and why?
• Who is affected and are peoples’ entitlements or obligations involved?

Step 2. Look at the situation from a government entity standpoint

• What is your duty as an employee of a government entity?
• What legislation, policies, procedures or guidelines are relevant?
• With whom should you consult?

Step 3. Would your actions or decisions withstand public scrutiny?

• Would a reasonable person consider that you were in a position to improperly use your powers or position?
• Would the public perceive your action or decision as honest and impartial?
• Is there a conflict of interest?

Step 4. Identify and consider the options

• Get advice from your manager or specialists within WorkCover.
• What are the options and what are the consequences that would result from each option?
• What are the costs and long-term consequences, if any?
• Are the options and consequences you have identified consistent with the four ethics principles and obligations?
• How would the public view a particular option?

Step 5. Choose your course of action

Make sure the course of action you have chosen:

• is within your position's authority and delegation and is consistent with the relevant legislation, policies and procedures, including this Code
• is procedurally fair and can be justified to your manager, the Executive Officer, the Board, the Minister, Parliament and the public
• is documented, if it is likely that a person will require a statement of reasons
• supports WorkCover's vision, values and goals
• involves the specialists within WorkCover, where appropriate.

Code of Conduct Agreement

NB: WorkCover means WorkCover Queensland or WorkCover Employing Office or WorkCover Queensland and WorkCover Employing Office as the context shall require.

It is the vision of WorkCover to be the best workers' compensation insurer and make a positive difference to people's lives Integral to the success of our organisation is your commitment to WorkCover’ vision and values, and agreement to conduct yourself in accordance with the standards outlined below.

As an employee of WorkCover you are expected to:

• Comply with all WorkCover policies, procedures and lawful directions from management. All WorkCover policies are accessible via the WorkCover Intranet.
• Ensure that you reflect a professional image of WorkCover at all times, with particular consideration to your attire, grooming and personal presentation.
• Use personal computers, mobile devices supplied by WorkCover, the Internet and other ICT (Information and Communication Technology) equipment in a professional manner and for the use it was intended, particularly noting that the access, distribution and storage of material which could be construed as offensive is prohibited.

Protect confidential information

• Maintain the confidentiality of all information obtained in the course of your employment with WorkCover. When accessing confidential information outside of your usual workplace such as on mobile devices or public computers, ensure that you take reasonable steps to maintain the confidentiality of the information you are accessing and that you are using it for the intended purpose.
• Understand that information and documentation you use in the course of your duties is confidential and the property of WorkCover.  Such material remains at all times the property of WorkCover, and you assign to WorkCover all copyright (including future copyright) in those documents and other materials.
• Maintain a high regard for the private and confidential nature of personal information; do not disclose or discuss any details relating to your salary and performance review with any other WorkCover employees other than your Manager or People and Workplace Experience.
• Refrain from accessing information on WorkCover employees, customers or others that is not necessary for the performance of your duties.

Value relationships with others

• Treat others with both fairness and respect, value diversity in the workplace and don’t allow your personal beliefs or relationships to affect your judgement when performing your official duties.
• Avoid situations where any actual or perceived conflict of interest may arise. Instances such as the management of a family member’s claim, engaging a service provider who is a friend or relative or connecting with customers through personal social medial channels, should be avoided. If a conflict of interest situation is unavoidable, disclose it promptly to your manager.
• Act with integrity and assume accountability for your actions when dealing with members of the public, clients, and other employees of WorkCover.
• Understand that WorkCover recognises bullying and harassment behaviour as a serious issue which is considered unacceptable and will not be tolerated. This includes unacceptable behaviour targeting an individual through social media or other public domains.

Our way of business

• Perform your duties in a conscientious manner conducive to the health and safety of both yourself and your co-workers.
• Refrain from the personal use of alcohol, drugs, or any other substance that may adversely affect your ability to perform your duties, threaten the safety of others or negatively impact on the image of WorkCover.
• Ensure that you have the necessary authority before releasing official documents or making public comment on behalf of WorkCover.
• Ensure that any comments or written material you make about WorkCover, in a public or private capacity, are done so in a respectful manner. This includes comments made using social media channels, blogs, other online domains and verbal and references provided on behalf of employees both past and present.
• Ensure you do not display, or cause to be displayed, inappropriate material or messages. This includes material displayed on the internal bulletin board, office bulletin board, personal workstation or other office areas.
• Understand that if in the reasonable opinion of WorkCover you are found to have been dishonest, to have wilfully disobeyed any of the conditions of this code, or are found to be guilty of misconduct, your contract of employment may be terminated.
• Understand that upon the cessation of your employment you are required to return all WorkCover property including keys, security access cards, reports, working documentation, including all files, notes and memoranda, manuals, equipment, corporate credit cards, computer information including all CD-ROMs, portable storage devices and programs including those which may have been installed on your home computer.

As an employee of WorkCover I understand it is my obligation to read, understand and agree that, as an employee of WorkCover, I have a responsibility to perform my duties in accordance with the standards outlined in this code.

I acknowledge and agree that my assent to the terms outlined above shall, where appropriate, endure beyond the term of my employment with WorkCover.

Where to from here?

If, after reading this Code you are unsure about your obligation in general or in relation to a specific situation, you should discuss this with your manager.

If you have concerns about approaching your direct manager, you should contact the next senior person in your area.  Where this is not possible or practical, you should make contact with People Group who will be able to provide you with guidance and advice on the appropriate steps to follow to resolve your concerns.