Integrity in the APS

1.1 Integrity in the Australian Public Service (APS) embodies high professionalism and ethical conduct, forming the foundation of public trust and effective governance. It emphasises prioritising the public interest, ensuring reliable delivery of government programs, and fostering a culture of shared responsibility at all levels to maintain confidence in the public sector’s role in delivering the best outcomes for Australia. Integrity can be complex conceptually and interpreted differently based on the context and circumstances of individual agencies and organisations. However, at its core, integrity is about what we do and how we do it, overlaid with accountability and transparency.

1.2 The Australian public expects all public service agencies and officials to act and lead with integrity. Strengthening integrity across government is a key priority in the APS Reform Agenda, particularly to address integrity issues highlighted in a range of recent Parliamentary inquiries, Royal Commissions, independent reviews, and reporting.

1.3 The Australian National Audit Office (ANAO) is an integrity agency. Its purpose is to support accountability and transparency in the Australian Government sector through independent reporting to the Parliament and thereby contribute to improved public sector performance.

1.4 Maintaining credibility and independence is essential in exercising the Auditor-General’s powers and delivering against the mandate of the Auditor-General Act 1997. To demonstrate these qualities, the ANAO regards integrity as a core value of the organisation - essential in sustaining the confidence of Parliament, strengthening public trust in government and delivering quality audit products. It is critical to the operations and reputation of the ANAO that the organisation maintains strong institutional integrity.

ANAO transparency

1.5 Operational transparency is a key aspect in maintaining strong institutional integrity. To support this posture, the ANAO established the ANAO Integrity Framework in 2020 and appointed an Integrity Advisor. Under the Integrity Framework the Integrity Advisor prepares an annual report to the ANAO Executive Board of Management on actions taken under and to support maturation of the Integrity Framework.

1.6 Since 2023, this has included publishing the ANAO Integrity Framework and an annual integrity report. The ANAO continues to refine and expand integrity reporting to provide transparency of integrity measures and to demonstrate our ongoing commitment to enabling a high-integrity culture with the ANAO.

Source: APSC | Integrity in the APS

Governance, accountability, systems and culture

1.7 Aligned with the Australian Public Service Commission (APSC), the ANAO considers integrity in the APS as a muti-layered concept shaped by frameworks, policies, assurance mechanisms, its employees and broader organisational culture

1.8 The ANAO’s Integrity Framework contextualises this for the ANAO, and identifies the Commonwealth and ANAO legislation, policies, processes, practices and reporting mechanisms that promote proactive integrity management. The ANAO Integrity Framework has been specifically designed to assist in improving governance practices and ethical decision making; and supporting risk, fraud and misconduct management.

1.9 Our core integrity-enabling foundations include:

• The ANAO Integrity Framework, setting the foundations for our approach through establishing an overarching structure to the integrity control system, and supporting our institution’s integrity;
• Accountability through governance oversight and reporting; and
• Embedding a strong pro-integrity culture. A pro-integrity culture involves the embedding of integrity into an agency’s culture, where integrity is a core consideration of all it does. The ANAO embeds integrity through leadership role modelling and communication, capability development across the employee lifecycle, awareness raising and availability of resources to support ethical and effective decision making.

How we support integrity

1.10 Integrity is part of the ANAO’s DNA – it’s a core value that supports us to deliver the Auditor General’s mandate, and consideration across all activities ensures we hold ourselves to a higher level of accountability given the privileged status, information-gathering powers and impact of our work in Parliament. The ANAO values – respect, integrity and excellence – align with the APS values and address the unique aspects of the ANAO’s business and operating environment.

1.11 The ANAO promotes, educates and empowers its people through embedding a pro-integrity culture, encouraging staff to perform duties objectively, impartially and in the best interests of Parliament. To build awareness and support integrity capability development the ANAO appoints key advisors, including the Integrity Advisor and Public Interest Disclosure (PID) Officers. These advisors are available to all staff to provide guidance and support in applying the expected integrity behaviours in every aspect of our work.

• The Integrity Advisor is responsible for matters associated with integrity and is a point of contact for staff who are seeking advice and support on the application of the Integrity Framework. The role of the Integrity Advisor includes:
  • responsibilities to increase integrity awareness across the ANAO;
  • support the effective, ongoing application of the Integrity Framework; and
  • reporting annually to the ANAO Executive Board of Management (EBOM) on actions taken under the Framework.
• The ANAO’s two PID Officers support the Integrity Framework through demonstrating best practice, adherence to the legislation and ethical leadership. They also support the responsibilities of the Integrity Advisor and are a resource for staff where integrity queries may arise.

How we measure integrity

1.12 Whilst measuring integrity performance is not a mandated requirement, it is good practice to undertake monitoring and reporting against key integrity metrics at regular intervals. For the ANAO, this includes adoption and continual refinement of suitable metrics, including metrics in the APSC Integrity Metrics Resource. Monitoring against a range of integrity metrics enables agencies to make informed decisions on where to focus efforts to uplift integrity awareness, monitoring and reporting. Results against key integrity metrics are set out in Chapter 2.

1.13 Staff survey data, including the APS Census, National Anti-Corruption Commission (NACC) Corruption survey and ANAO specific surveys, provides rich, qualitative insights into staff perceptions on a range of integrity related matters. Results analysis can indicate integrity ‘hot spots’ and areas for further investigation through different internal activities, including action plans, Integrity Week activities and group business plans.

1.14 Additionally, the ANAO assesses the maturity of the Integrity Framework. This has included assessment against the IntoSAINT methodology, designed for Supreme Audit Institutions (SAI), and this year, against the Commonwealth Integrity Maturity Framework. This ensures that the ANAO is considering its role in the APS ecosystem in addition to being a SAI. A maturity assessment summary is included in Chapter 3.

Integrity Advisor Performance Report

2.1 While behaving with integrity is the responsibility of all ANAO staff, the Integrity Advisor leads delivery of a range of activities to increase integrity awareness, capability uplift and support staff and deliver executive reporting.

Integrity Awareness

2.2 Integrity awareness education and support for ANAO staff starts on commencement. In addition to completing mandatory e-learning as part of the induction program, the Integrity Advisor delivers integrity foundations training at the monthly new starter induction sessions. Introduced from January 2025, the sessions include Executive integrity insights, an introduction to the Integrity Framework and Integrity Advisor and contextualising common scenarios staff face in working with the ANAO. Between January and June 2025, the Integrity Advisor delivered four integrity induction sessions to 31 new starters.

2.3 Integrity Awareness week is an annual event that spotlights what it means to work within and promote an integrity-positive culture. Framed around a key integrity theme, the week includes a range of events and daily messages on integrity topics. Two Integrity Awareness weeks were held in 2024-25:

• Integrity Awareness Week 2024 held 15 to 19 July, with a focus on integrity as a daily practice; and
• Integrity Awareness Week 2025 held 7 to 10 April, focused on identifying integrity issues and available reporting pathways.

2.4 The ANAO continued to refine its integrity learning program in 2024–25. This included the release of two integrity and independence leaning modules that emphasise the importance of integrity in audits. Released to coincide with Integrity Awareness Week activities, the modules highlight the application of key principles including ethical behaviour, transparency and accountability, and highlight everyone’s responsibility in maintaining trust and credibility in auditing practices.

2.5 The Integrity Advisor additionally attended internal forums, group meetings and technical updates to discuss integrity matters. This included delivering presentations following publication of the annual Integrity Report November 2024 to highlight results, discuss emerging trends and promotion of the forward integrity activity schedule.

Capability uplift and support

2.6 In 2024–25, ANAO staff consulted the Integrity Advisor, seeking guidance or clarification, on 11 integrity-related matters. This increased engagement compared to the prior year (2023–24: 3) reflects ongoing staff awareness and commitment to upholding ethical standards across the organisation. Consultation occurred across a range of integrity aspects, outlined in table 2.1 below.

Table 2.1: Integrity Advisor queries 2024–25

2.7 The Integrity Advisor also engages with the ANAO Executive on a regular basis. This includes consultation on in-flight projects to ensure integrity perspectives are considered, to build a shared understanding of integrity culture, and support initiatives to address areas of vulnerability. In 2024–25, this included:

• advice to the Auditor-General on integrity related matters, including reviewing Integrity Agencies Group papers and briefing on the Attorney-General’s Department-led development of a Commonwealth Integrity Framework;
• meeting regularly with the Chief Operating Officer (COO) to discuss the Integrity Framework and advise on emerging integrity matters; and
• consulting with staff involved in integrity-related positions including Public Interest Disclosure (PID) Officers, Harassment Contact Officers (HCOs) and HR.

2.8 Additionally, in 2024–25 the Attorney-General’s Department led development of the Commonwealth Integrity Strategy. Alongside other APS integrity agencies, the ANAO was consulted, raising integrity considerations drawn through audit insights and better practice considerations to support strategy refinement.

Integrity Reporting

2.9 The annual integrity report for 2023–24 was published in November 2024 following EBOM endorsement.

2.10 In March 2025, an internal mid-year integrity report was presented to EBOM. As part of continuous monitoring, the report identified areas where the ANAO may face vulnerabilities and risks to integrity, or elements of the Integrity Framework that require strengthening. The report also highlighted areas where new controls have been implemented to improve the maturity of the ANAO Integrity Framework during the year.

Status of actions under the Annual Integrity Strategy 2024–25

2.11 The 2023–24 Integrity Report set out the Integrity Strategy for 2024–25. This included actions to fulfil the Integrity Advisor role to support the effective and ongoing application of the Integrity Framework and increase integrity awareness across the ANAO. The status of these actions as at 30 June 2025 is outlined in table 2.2 below.

Table 2.2: 2024–25 Integrity Strategy Activities

Integrity Metrics Analysis

Human Resources (HR) matters

2.12 ANAO staff numbers continued to increase in 2024–25 to support delivery of our audit program, with a headcount of 471 ongoing employees at 30 June 2025. This included 30 graduates participating in the ANAO’s graduate program.

2.13 The ANAO Enterprise Agreement 2024-2027 (EA) commenced operation on 29 March 2024. In 2024–25, the ANAO refreshed several workplace policies, guidelines and procedures to ensure the policies effectively address workforce needs and reflect the evolving workplace environment. Key changes included:

• Improved consultation provisions on workplace matters that impact staff prior to decisions being made;
• Introduction of EL Time off in lieu (TOIL) for reasonable additional hours worked;
• Mandatory cultural competence training for all EL2 positions;
• New APS-wide parental leave provisions;
• Improved support to understand, prevent and address workplace sexual harassment (Respect@Work); and
• Enhanced flexible work arrangements, including a bias towards approving requests.

Support for people matters

2.14 During 2024–25, the ANAO’s Human Resource Business Partners (HRBP) team provided advice to the Executive, managers and staff on a range of people matters, including matters related to probation, performance, and wellbeing. Proactive support from the HRBP team is aimed at preventing matters from developing into formal cases.

2.15 Supporting executive monitoring of people matters, the HRBP team provide quarterly people metrics to the Group Executive Directors (GEDs) and meet monthly to discuss HR related data and cases.

2.16 In 2024–25 there was an increase in managers seeking informal advice and support from the HRBP team. While informal advice is not actively tracked due to the informal and ad hoc nature of the requests, there was an increase in formal case matters, particular related to performance and employee wellbeing.

2.17 To further support managers and supervisors, HRBP is revising manager guides and communicating the importance of active performance management, alongside manager and supervisor advice sessions held prior to the mid- and end-cycle performance discussions to support effective performance management. A focus throughout the reporting period has been on uplifting and supporting managerial capability. Key activities to support uplift have included learning sessions on holding effective performance and management discussions, setting clear expectations, coaching and developing staff, delegation, engaging with a neurodiverse workforce, and employee wellbeing and resilience.

Probation and Performance management

2.18 In 2024–25 a total of 64 staff undertook a probation period (excluding Graduates). Probation status at 30 June 2025 is provided in Table 2.3.

Table 2.3: Probation status

2.19 The ANAO HRBP team supports managers with the application of the performance management framework with a focus on probation management, including awareness raising with managers regarding completion of three- and six-monthly probation reporting.

2.20 High rates of performance agreements and regular performance conversations are strong indicators that employees and managers are aligned on deliverables, behaviours, career goals, and development needs. Regular conversations on and review of performance agreements is not only a best practice—it is a critical integrity safeguard. It enables the ANAO to proactively identify, prevent, and address integrity risks such as fraud, waste, and misconduct. This oversight fosters accountability and reinforces a culture of ethical behaviour. Timely and consistent monitoring also supports leadership decision-making by surfacing patterns and risks early, allowing for targeted interventions that uphold organisational integrity and maintain public trust.

2.21 The ANAO performance management cycle runs from 1 November to 31 October each year and participation in the cycle is mandatory for most ANAO employees.² The summary of performance ratings for eligible staff for the performance management cycle ended 31 October 2024 is set out in the table below.

2.22 As at 30 June 2025, 417 staff had performance agreements in place and all APS and Executive Level (EL) staff are compliant with the Performance Agreement policy. The HRBP team monitor and communicate with GEDs regarding performance agreements that have not been submitted by the required due dates.

Table 2.4: Performance ratings as at 31 October 2024.

2.23 The key to addressing underperformance is identifying performance and behavioural concerns early and acting without delay. Early intervention and support for managers and supervisors ahead of formal performance cycle assessment stages, and active HR monitoring through GED and SES discussions has resulted in a decrease in staff rated as ‘not meeting expectations’, falling from three in the prior performance cycle to one for the year ending 30 October 2024.

2.24 As at 30 June 2025, there are 5 active underperformance cases being monitored, including one formal Performance Improvement Plan (PIP) or pre-PIP being in place. The first steps in addressing underperformance are to ensure that the staff member has clear performance expectations and to hold regular performance conversations.

Code of conduct matters

2.25 Monitoring Code of Conduct reports is important in identifying and responding to inappropriate behaviour, preventing it from reoccurring, and demonstrating that employees are held accountable if found to have breached the Code. In 2024–25 there were four Code of Conduct investigations (2023–24: nil).

2.26 Investigations were in progress as at 30 June 2025 and related to staff allegedly not behaving in accordance with ANAO and APS values, and non-compliance with ANAO corporate policies and procedures. Without pre-empting investigation outcomes, which will be reported in 2025–26, the cases indicatively do not highlight systemic integrity issues. The ANAO has a zero-tolerance approach for behaviours that do not align with the ANAO values and APS Code of Conduct, which is consistently reiterated through staff communications.

Bullying, harassment and discrimination

2.27 In 2024–25 there were two formal reports of bullying and harassment made to the ANAO Human Resources Business Partnering (HRBP) team (2023–24: three). In each case, the HRBP team investigated the claims. The matters were managed through intervention methods such as counselling, mediation or giving formal direction.

2.28 In 2024–25 there were no formal reports of discrimination (2023–24: one).

2.29 The ANAO additionally considers the APS census results in assessing its integrity culture, and staff application of expected integrity behaviours. The APS Census results related to perceived bullying, harassment and discrimination indicate that incidents for ANAO staff are slightly below the APS rate, however, any incidence remain unacceptable. Chapter 3 includes analysis of the 2025 census results, including discrimination, bullying and harassment.

Harassment Contact Officer matters

2.30 Following commencement of the 2024-27 Enterprise Agreement, Harassment Contact Officers (HCOs) replaced Diversity Contact Officers. HCOs play a vital role in promoting the respect at work principles through assisting in enabling a safe, respectful, and inclusive workplace.

2.31 HCOs are ANAO officers who are a supportive and informed point of contact for employees with harassment-related concerns. They do not act as a mediator or investigator, however, offer confidential support, information and guidance on ANAO policies, procedures and available support mechanisms.

2.32 There were no integrity related matters raised with the HCOs in 2024–25 (2024–25: one).

Leave, flex and TOIL balances

2.33 High levels of overtime, flex, or TOIL balances may indicate excessive workload, staff not accessing leave entitlements, or performance concerns, which can impact upon staff integrity. The outcome of reducing large annual leave and flex balances is to ensure workloads are appropriate, reducing the risk of stress and burnout, and ensuring appropriate supervision levels to maintain performance. Accumulated flex balances across the ANAO will vary between groups and at different times in line with peak work periods

2.34 The HRBP team works closely with managers of staff who have exceeded annual leave and flex time limits. As at 30 June 2025, four APS employees had exceeded flex time thresholds, with HRBP actively supporting managers to reduce this with affected employees.

2.35 The ANAO EA 2024-2027 introduced EL TOIL. HRBP review and report EL TOIL as part of quarterly people metrics, providing insights to each group regarding workloads over peak work periods.

Exit survey results

2.36 Staff who are leaving an agency are more likely to raise integrity concerns during exit processes. This provides the ANAO an opportunity to collect important information on integrity issues.

2.37 In 2024–25, 55 of 83 (66.3 per cent) ANAO staff who left the agency completed an exit survey – an increase compared to the prior period (2023-24: 52.6 per cent). The main reasons for separating in 2024–25 were:

• Promotion or transfer to another Government agency (23 per cent);
• Dissatisfaction with management or leadership (12 per cent); and
• Lack of job satisfaction (11 per cent).

2.38 While employees departing due to a promotion or to expand their skills through transfer to another agency are seen positively, exit survey free-text responses also indicated factors in departure decisions included leadership, workload and bureaucracy. Fifty-four per cent of respondents indicated they had experienced high stress at work, with twenty-two per cent disagreeing that the ANAO valued work life balance and employee wellbeing.

2.39 Leadership, high workloads and poor work-life balance can pose integrity risks. Employees experiencing high job demands, tight deadlines and increased stress may lead to burnout, errors and compromised ethical judgment. In 2024-25, these issues were explored in executive dialogue sessions with ANAO staff supporting development of the Census Action Plan and 2025-26 Corporate Plan. Sustainable resource management and employee wellbeing are core focus areas in the year ahead.

Fraud and Corruption

2.40 Monitoring fraud and corruption is vital to protecting public funds and services, maintaining trust, and ensuring ethical conduct across sectors. The ANAO enforces a zero-tolerance approach, taking all reasonable steps to prevent, detect, and respond to fraud and corruption. Regular monitoring helps identify and address non-compliant or illegal behaviour, prevent recurrence, and reinforce accountability by demonstrating that employees and contractors will be held responsible for their actions.

2.41 There were three suspected incidents of fraud or corruption identified in the ANAO in 2024–25 (2023–24: nil). The reports related to three members of staff who may have breached ANAO policy, with investigations conducted into the potential misconduct. The three suspected incidents were reported in accordance with ANAO policy, including to the relevant governance committee. Investigations remained underway as at 30 June 2025.

2.42 Supporting the implementation of the ANAO Fraud and Corruption Framework, commencing with effect from 1 July 2024, fraud and corruption awareness was emphasised in staff information sessions and through internal communication strategies. Staff were also required to complete mandatory fraud and corruption training by 5 November 2024.

Disclosures under the Public Interest Disclosure (PID) Scheme

2.43 Changes to the number of PIDs between years may indicate broader integrity concerns within an agency. Where themes occur, it may highlight the need for reformed integrity practices in relation to that area.

2.44 To ensure ANAO staff are aware of the PID requirements and their obligations, Authorised Officers provided annual refresher training via service group technical updates and service group meetings.

2.45 Seven Public Interest Disclosure (PID) matters were received by ANAO PID Authorised Officers in 2024–25 (2023–24: one). Of the seven PID matters considered by Authorised Officers, five were determined not to be disclosable conduct (personal work-related grievance). For the two remaining PID matters, the ANAO was determined not to be an authorised recipient. For PID matters where ANAO was not the authorised recipient, the Authorised Officer responded to the discloser explaining the Public Interest Disclosure Act 2013 (PID Act) disclosure process and provided the discloser with the PID contact details for the entity that the disclosure related to. All PID matters received were assessed and responded to by Authorised Officers within the 14-day PID Act deadline.

2.46 One PID matter referred for investigation in a prior period was finalised in 2024–25 with no further action taken as the matter was determined to be conduct more appropriately investigated under another law or power. This investigation was completed after the 90-day PID Act deadline (91 days).

Misuse of credit cards

2.47 Credit cards present agencies with options to purchase goods and services with increased efficiency, including reduced administrative costs and increased flexibility, particularly where official travel is required. However, the use of credit cards can expose agencies to risks of inappropriate or unauthorised expenditure, and controls to manage risks, including monitoring use, are essential.

2.48 In 2024 –25, there were 13 instances of misuse of ANAO corporate credit cards (2023–24: eight). While this is an increase on prior years, overall, these instances represent less than 0.1 per cent of total credit card transactions.

2.49 Each instance was investigated, with all incidents found to be inadvertent. All instances of credit card misuse were reported to the Executive Board of Management. The Chief Finance Officer contacted those staff who misused their credit card, reminded them of their obligations when using the card, and ensured that the amounts associated with the misuse of the credit cards were repaid into the ANAO’s bank account.

NACC Commonwealth Integrity Survey

2.50 The NACC conducted the 2024 Commonwealth Integrity Survey from 19 August to 20 September 2024. The ANAO results were provided to the Integrity Advisor for information. The ANAO results were largely positive and the ANAO results exceeded the overall Commonwealth results for organisational controls, employee comprehension and reporting likelihood. Positive results include:

• 96 per cent of ANAO staff who responded the culture in the ANAO supports people to act with integrity and that the ANAO has high ethical standards;
• 98 per cent of ANAO staff who responded were confident that they can identify what constitutes corruption within their area of responsibility; and
• 100 per cent of ANAO staff who responded understand the ANAO’s integrity values and expectations;

2.51 In response to questions related to where opportunity for corruption may arise in the ANAO the highest results were ‘there are small, informal sub-groups that exclude others and have their own way of doing things’ (25 per cent) and ‘people take leave to escape the workplace culture’ (17 per cent).

2.52 The survey included scenarios where respondents were asked to identify corruption. Overall, 88 per cent of ANAO respondents gave the best answer to the majority of the scenarios. The Integrity Advisor will consider incorporating these scenarios into integrity awareness week messaging or session.

2.53 For reporting likelihood results, 93 per cent of ANAO respondents would make an official report of corruption if they had specific details of the corrupt conduct. The number one reason for not reporting corrupt conduct was ‘they may not have sufficient proof’. Other reasons for not reporting included ‘it could affect their career’, ‘fear of retaliation or reprisal’, ‘too busy doing other work’, ‘they didn’t know how to report’ and ‘they don’t think action would be taken’.

2.54 In the questions related to awareness of corruption, 4 per cent of ANAO respondents (13 staff) had specific knowledge of corrupt conduct in the agency. Cronyism and nepotism were the highest rated descriptions answered to describe the corrupt behaviour. Of these 13 staff, 54 per cent discovered or witnessed it themselves, and 54 per cent did not take any action, with similar reasons as identified in the paragraph above.

2.55 While overall the results are largely positive, a small percentage of staff responded that they had knowledge of perceived corrupt conduct and did not take action either because they didn’t know how to, they didn’t think any action would be taken and/or they were concerned that they would be subject to detrimental action if they made a report.

NACC engagement guidance

2.56 The ANAO published internal guidance for staff regarding engagement with the NACC in November 2024. Guidance was released to ensure staff are aware of their responsibilities if they are contacted by the NACC and about the resources available to assist them.

Completion of mandatory learning and development

2.57 Completion of mandatory training is essential to maintaining integrity and public trust at the ANAO. It ensures employees understand ethical codes, legal responsibilities, and public sector expectations, and directly supports the uplift of integrity awareness and capability. As part of a pro-integrity culture, integrity-related training reinforces the ANAO’s commitment to high ethical standards, accountability and transparency.

2.58 On commencement at the ANAO, all staff must complete the ANAO Induction Learning Pathway which includes mandatory eLearning courses, and the ANAO Induction Workshop. This pathway equips new staff with the knowledge needed to work lawfully, ethically and safely at the ANAO. Attendance is monitored to confirm completion, and all staff must then complete the mandatory refresher training annually.

Table 2.5: ANAO mandatory training program overview

2.59 Due to varying due dates based on staff commencement date, initial mandatory training completion date, and the date refresher training is completed, it is difficult to provide an accurate overall staff completion result at a single point in time. The ANAO has a comprehensive system in place to communicate mandatory training requirements, track completion, and address instances of non-compliance. Key support and monitoring activities include:

• reminders on commencement and ahead of refresher deadlines
• access to modules via the intranet and Learning Management System,
• performance management communications,
• biannual compliance surveys to confirm training is up to date,
• monthly reporting to and discussion at EBOM and with the GEDs on non-compliance; and
• individual follow up on non-compliance, where required.

Conflicts of interest

2.60 Proactive conflict management enables effective mitigation of integrity risks related to unethical conduct and corruption and supports fair and objective decision-making. As part of its proactive integrity culture, the ANAO supports all staff to identify, declare, mitigate and manage potential, perceived and actual conflicts of interest in their work. Audit independence is critical to the work of the ANAO, and all audit staff are required to be independent of auditees. Conflicts of interest and independence are managed by intersecting processes, including the disclosure of personal interests and audit independence declarations.

Personal interest disclosures

2.61 The Auditor-General, all SES officers (including those acting in SES positions for longer than three months), and employees who, in the Auditor-General’s opinion, may have similar decision-making responsibilities, are required to submit at least annually a written declaration of their and their immediate family’s financial and other interests that could involve a real or apparent conflict of interest. The requirement for SES and key personnel to complete and submit a declaration of interest is governed by section 13 of the Public Service Act 1999.

2.62 An annual declaration process occurs in September each year. However, it is expected that staff monitor their personal and financial interests, alongside changes in the nature of their role and responsibilities, to advise potential or actual conflicts immediately and to take proactive action to avoid or manage the conflict. All declarations are reviewed by the Deputy Auditor-General and escalated to the Auditor-General where required.

2.63 As part of the September 2024 annual declaration process, all 36 required SES officers and 6 other key personnel completed declarations of personal interest. Staff proactively self-identify and submit management strategies for approval as part of the declaration process, and of the approved declarations, there were no potential conflicts requiring escalation for further management.

Independence declarations

2.64 Providing the Auditor-General with further assurance of independence in respect of its audit work, the ANAO has policies requiring that all audit staff complete independence declarations. Under the ANAO Audit Manual the Auditor-General, Deputy Auditor-General, ANAO audit staff and in-house audit contractors are required to complete a declaration of independence prior to participating in an audit, review, other assurance engagement or information report. Any actual, perceived or potential threats to independence are declared to the responsible Engagement Executive for evaluation.

2.65 Safeguards are put in place to reduce any threats to an acceptable level. These safeguards can include removing members from an audit team or excluding them from specific aspects of audit work where the threat arises, and additional levels of review to ensure that judgements made are appropriate.

2.66 The ANAO monitors compliance with independence policies through its quality assurance program, including independence documentation requirements. Compliance with independence documentation requirements is also monitored through Internal Audit. The results of the quality assurance program are reported to the responsible Engagement Executive, EBOM and the Quality Committee, and published as part of the annual Audit Quality Report.

Gifts and benefits

2.67 The ANAO must meet public expectations of integrity, accountability, independence, transparency and professionalism. This can only happen if staff are not influenced, or perceived to be influenced, by gifts, benefits, or bribes. The Auditor-General’s Instructions and Financial Management Procedures set a clear guiding principle for ANAO officials to avoid the acceptance of gifts, benefits or hospitality and decline at the time of offer. In some instances, staff may accept gifts such as when the ANAO receives cultural gifts from international delegations or hosts.

2.68 Monitoring and reporting gifts and benefits supports employees to work with and demonstrate integrity, accountability and transparency. ANAO staff must report any offered gift or benefit, whether accepted or refused, within 10 business days of the offer being made via the gifts and benefits register. Permission to retain any gift or benefit requires permission of the Deputy Auditor-General or the COO.

2.69 The gifts and benefits register is published on the ANAO website on a monthly basis for transparency and accountability. The gifts and benefits register includes gifts and benefits offered to the Auditor-General. Additionally, the ANAO publishes the Auditor-General official expenses on the website This is a voluntary disclosure that is updated every six months.

2.70 In 2024–25, a total of 132 gifts and / or benefits were reported. Table 2.6 describes the result of declaration.

Table 2.6: Gifts and benefits reported

2.71 Of these, 58 were gifts or souvenirs from peer audit office staff during international conferences and capacity building activities that the ANAO undertakes with the Audit Board of the Republic of Indonesia (BPK) and the Papua New Guinea Audit Office. These gifts were accepted as cultural gifts or were gifts provided to all attendees or presenters at conferences. Other items retained included:

• items that provided benefits to the ANAO, such as flight or frequent flyer membership upgrades, networking opportunities and a conference attendance on a topic relevant to an audit topic; and
• low value, unsolicited items, including notebooks, chocolates and conference collateral.

2.72 Seventy-seven per cent of were declared within the required timeframe of 10 days (median of seven days and range of 122 days).

Outside employment or activities

2.73 The ANAO provides its staff with flexibility to participate in employment or activities outside the Australian Public Service if the employment or activities do not conflict with or adversely affect the performance of their official duties. A range of activities may be deemed to be in the public interest and of professional benefit to the individual and to the ANAO. Outside employment (paid or unpaid) or volunteer activities are undertaken by an employee in addition to their official duties or while on paid or unpaid leave from the ANAO.

2.74 To support ANAO staff to work with integrity, be accountable and transparent, prior approval is required for all outside employment and activities, unless specifically excluded from the policy. The Deputy Auditor-General is the delegate for approving outside employment or activities.

2.75 As at 30 June 2025, the ANAO had 34 approvals recorded for staff undertaking outside employment or activities. There was an increase in outside employment activities compared to 2023–24 (16) with approvals including staff working with the Australian Electoral Commission during in the 2025 federal election.

Protective security

2.76 Under the Protective Security Policy Framework (PSPF), all non-corporate Commonwealth entities under the Public Governance, Performance and Accountability Act 2013 (PGPA Act) are required to report annually on their protective security maturity. The 2024–25 cycle introduced a revised assessment structure, with the PSPF now organised into six security domains (Governance, Risk, Information, Technology, Personnel, and Physical), with the annual review moving from a maturity model to a compliance reporting model. For 2024–25, ANAO self-assessed its systems as effective (90-100 per cent compliance).

Pre-employment suitability screening

2.77 ANAO conducts pre-employment eligibility checks including rigorous selection processes, identity verification and Security Clearances or equivalent.

Security incidents

2.78 ANAO monitors security processes through a skilled security team, guided by the ANAO Security Committee, which is responsible for monitoring security policies. The Security Committee receives reports on trends of breaches and discusses concerns if they arise.

Threats

2.79 The IT security team is constantly monitoring the network, investigating potential incidents, considering intelligence from Government and market entities and fine tuning the protections to improve our systems.

2.80 Phishing is a common attack vector against the ANAO. We have implemented a range of technical defences to reduce the likelihood of a malicious email entering out network. Staff are trained to report phishing and other suspicious emails.

Access controls

2.81 The ANAO has access controls in place to all IT systems, supported by active logging and monitoring of user access.

Updating security policies and training programs

2.82 To mitigate present and future security threats and risks, security policies and training programs are regularly reviewed and enhanced, as resourcing permits.

2.83 Security awareness training is mandatory on joining the ANAO and refreshed every twelve months. This is supplemented by ongoing communications about different security topics every month.

Security – integrity culture

2.84 The Chief Security Officer and Chief Information Security Officer indicated that the strong integrity culture of the ANAO supports integrity regarding IT security, where staff exhibit a high level of commitment and adherence to the security policies. They reported that staff are aware of and attentive to security threats, and this is evidenced by the majority of security incidents being self-reported, and willingness of staff to report something they consider unusual

2.85 The current threat environment is assessed as high. The ANAO is looking to ensure that security roles and responsibilities in this environment remain effective, with staff vigilance remaining a key factor in maintaining a safe environment.

Procurement

2.86 All Commonwealth entities must comply with the Commonwealth Procurement Rules when procuring goods and services, including reporting contracts over $10,000 on AusTender within 42 days of entering an arrangement. Monitoring ANAO performance against this metric enables effective record keeping practices and compliance with mandatory requirements and supports identification of procurement process issues.

2.87 In 2024–25, 90 procurement contracts and 57 contract variations/amendments made by the ANAO were registered on AusTender within the required 42-day period.

2.88 There were four instances where procurement contracts and two instances where contract variations/amendments were registered on AusTender after 42 days. The ANAO is seeking to eliminate all instances of late reporting by undertaking daily reviews of procurement activity and is investigating whether the process can be automated. All instances of reporting outside the mandated timeframe are reported to EBOM.

2.89 In 2024-25, the ANAO did not receive any complaints regarding ANAO procurement processes (2023–24: nil). The procurement complaints mailbox is a mechanism for suppliers and/or potential suppliers to lodge a formal complaint if they believe the ANAO has breached or will breach Commonwealth Procurement Rules and this has affected or will affect their interests.

2.90 The Procurement Team continues to review and update ANAO procurement processes to deliver improvements and ensure compliance. This includes continuous updating of templates, reviewing the current ANAO Panel management and utilisation strategy, undertaking daily checks and reports for AusTender contract uploads to minimise occurrences of not adhering to the 42-day reporting requirement.

Awards and recognition

2.91 The ANAO awards system recognises and rewards people whose behaviours and contributions align with the ANAO values of integrity, excellence, and respect, and assist the ANAO to achieve its objectives. This system includes formal ANAO awards such as the Auditor-General’s Australia Day Awards and the Auditor-General’s Outstanding Achievement Awards.

2.92 In 2024–25 award recipients included ANAO staff who demonstrated a commitment to ANAO integrity principles and professionalism with a focus on commitment to assisting staff and colleagues.

3.1 In 2019, the ANAO undertook its first formal integrity maturity assessment. The self-assessment of integrity (IntoSAINT)³ identified the ANAO does not face significant risk in terms of integrity. However, the assessment identified opportunities to strengthen the control environment. Recommendations were made against four domains: the integrity system, organisational practices, capability and communications.

3.2 Outcomes of work to address those recommendations were reported in prior years and include the establishment of the Integrity Framework and Integrity Advisor role, and regular monitoring and evaluation activities.

3.3 Supporting continual improvement and integrity system enhancement, the ANAO considers the evolving APS integrity policy and guidance landscape, both in terms of our own integrity approach, and how Commonwealth entities are establishing and maturing their own systems. This has included considering guidance released by the Australian Public Service Commission (APSC) and NACC, alongside APS inquiry findings and recommendations, such as the Louder Than Words: An APS integrity action plan (2023).

3.4 The Integrity Advisor commenced delivery of an annual Integrity Report in 2021 that included a high-level narrative assessment of the maturity of the framework based on activities undertaken across integrity awareness, capability and accountability pillars to strengthen the framework. This assessment has been maintained in subsequent annual reports and published externally since 2023–24.

3.5 As part of continuous improvement and reflective of its pro-integrity culture, the ANAO has continued to enhance integrity monitoring and reporting. This has included review of integrity indicators to strengthen monitoring and reporting maturity through incorporation of additional metrics aligned with the APSC Integrity Metrics Resource.

3.6 Further, as part of this report cycle, the ANAO has conducted an initial self-assessment against the Commonwealth Integrity Maturity Framework. This analysis serves to deepen the understanding of the ANAO’s integrity maturity in an APS context and is complementary to maturity as a SAI, as established in the IntoSAINT assessment.

ANAO Integrity Context

3.7 This section considers available information to assess whether vulnerabilities identified in the 2019 IntoSAINT assessment continue to be present, or if there are other emerging vulnerabilities and risks that need to be considered in the resilience of the Integrity Framework. This includes an assessment of the environment, issues raised through ANAO governance committees, and the 2025 ANAO APS Census results.

Environment

3.8 Building and enhancing the integrity of the Australian public sector remains a key focus across the public service, including the ongoing suite of APS reforms aimed at addressing integrity related issues within public administration. Our work is shaped by broader trends in the Australian public sector — from a focus on integrity and the delivery of government priorities, to the rapid emergence of new technologies, fiscal pressures, and policies to address climate change. Global developments, including heightened economic uncertainty, shifts in the geopolitical landscape and increased cyber and national security threats, affected risk and activity in the public sector and, therefore, the ANAO in its work as the government’s auditor.

3.9 The ANAO actively considers the integrity environment and sector activities occurring to not only inform our work, but also to ensure our systems and approaches continue to exceed Parliament and community expectations. In 2024–25 this consideration included:

• Integrity Agencies Group (IAG) membership – The Auditor-General and Deputy Auditor-General engage in the IAG, whose purpose is to ensure integrity is at the centre of the work of the public sector, and that the APS approach to integrity is integrated, capable, agile and transparent.
• APS Integrity Taskforce recommendations - Commencing in 2024–25, all APS agencies, including the ANAO, commenced biannual reporting of implementation progress against the 15 recommendations in the Louder Than Words integrity action plan. The action plan acknowledges the importance of integrity institutions in the sector and their respective roles in driving accountability and transparency. As at 30 June 2025, the ANAO is progressing work against seven actions across the recommendations, has completed four, and notes four include interdependencies with other actions or are not applicable to the ANAO.
• Commonwealth Integrity Survey results – considering the results of the first, biennial Commonwealth Integrity Survey, released by the NACC in December 2024. Collating observations and perceptions of integrity and corruption within the Commonwealth public sector from APS employees, the survey supports agencies to measure trends in perceptions of integrity and corruption risks and inform anti-corruption strategies. The overall survey results across entity controls, employee understanding and reporting likelihood were largely positive, however also indicated barriers to reporting potential corruption or fraud. ANAO outcomes analysis is reported in Chapter 2.
• Strengthening Integrity in the APS - the June 2025 strategy outlines the APSC’s approach to administering the employment and integrity framework through working collaboratively with agencies to uphold high standards of integrity and conduct in the APS.
• SES Performance Leadership Framework –implementation of the APSC DRIVE model and a focus on ‘what’ and how’ in SES performance management (ANAO policy takes effect in the new performance cycle in November 2025). The framework and model focus on behaviours that support leadership aligned with the APS Values and Code of Conduct, and ensures the APS embodies integrity in everything it does.

3.10 Community interest in the integrity of the audit profession is also a key focus for the ANAO. In response to the community’s high expectations of the audit profession to perform its functions independently and professionally, integrity, ethics and quality in auditing remain cornerstones of the ANAO’s work.

3.11 Examples of sector engagement on integrity includes:

• 2024 Australian Human Resources Institute (AHRI) convention – the acting Auditor-General was part of a panel discussion, Integrity and leadership in the APS, that explored ethical leadership principles and values that guide decision-making and behaviour in the public sector, including accountability, transparency, fairness, and appreciation of diversity within public sector workforces.
• Australasian Council of Auditors-General (ACAG), for Auditors-General of all audit jurisdictions within Australia, New Zealand, Fiji and Papua New Guinea to promote and strengthen public sector audit through leadership, collaboration, engagement, advocacy and peer support.
• Ongoing partnerships with regional Auditor-General offices, including the Board of Audit and Inspection of Korea, Papua New Guinean Office of the Auditor-General, and through the Prospera program, supporting our relationship with the Audit Board of the Republic of Indonesia.
• Active membership in IntoSAI forums, including the Pacific regional chapter, the Pacific Association of Supreme Audit Institutions (PASAI). Multiple ANAO executive staff engage across the range of forums and events promotes transparent, accountable, effective and efficient use of public sector resources, and serves to share insights across SAIs.

Governance and committees

3.12 The ANAO’s governance framework supports the organisation to uphold public sector principles and values, including legislative requirements for accountability, leadership, transparency, integrity, efficiency and risk management. The framework ensures that our operations remain compliant with relevant laws, standards and directions. This supports effective management of the organisation to achieve its purpose and meet public and community expectations of probity, accountability and transparency.

3.13 The EBOM advises and supports the Auditor-General in achieving the ANAO’s purpose. EBOM is supported by six subcommittees and three operational committees. In 2024–25, there were no issues raised regarding integrity through the subcommittees to EBOM. However, EBOM continuously monitored areas related to integrity risk as part of its ongoing risk oversight arrangements, including allegations of breaches of the Code of Conduct and ANAO behavioural expectations, through the quality assurance program, and consideration of the ANAO and APS-wide results of the Commonwealth Integrity Survey.

3.14 The importance of integrity in all aspects of the ANAO’s work and operations was emphasised in the Auditor-General’s messages to all staff following EBOM meetings. This included messaging related to maintaining our ongoing focus on our values and leading by example – both as the auditor for the public sector and as public servants.

Australian Public Service (APS) Employee Census 2025

3.15 The APS Employee Census⁴ is an annual survey that collates confidential attitude and opinion information from APS employees on workplace issues. As an opportunity for APS employees to share their experiences of working in the APS, the results provide insight into employees’ views about the APS, their agency, and their workplace.

3.16 The Integrity Advisor reviews ANAO organisation level responses against identified questions related to integrity. This includes a year-on-year comparison to identify emerging trends or vulnerability enhancing factors.

3.17 The select questions included below consider vulnerabilities highlighted in the 2019 IntoSAINT maturity assessment. While recommendations to address vulnerabilities have been closed out, the ANAO continues to monitor staff perceptions, alongside other data points, to ensure vulnerabilities are effectively addressed.

3.18 Table 3.1 below sets out relevant ANAO results from the 2025 APS staff census related to capacity and capability.

Table 3.1: 2025 census results – workgroup capability and capacity

Note 1 - The 2025 APS Census included responses from 436 ANAO staff (93 per cent response rate). The number of staff included in brackets in the tables is an estimated number and was calculated from the percentage results from the overall ANAO responses. Rounding may impact the accuracy of these numbers.

Note 2 - The 2024 APS Census included responses from 400 ANAO staff (93 per cent response rate).

3.19 In the 2019 IntoSAINT report, the need for external expertise and outsourcing primarily related to the engagement of experts in audits, the contracting out of selected audits to industry specialists and the purchase of financial statements audit methodology. The potential impact on integrity is that staff may have a negative perception of choosing outsiders rather than investing in building in-house expertise. The need for external expertise and outsourcing was also linked to staff turnover, with replacement staff often having less audit experience and expertise.

3.20 The ANAO Workforce Plan 2022–25 sets out the ANAO’s commitment to investing in our people, supporting their development as leading audit and public service professionals. The ANAO’s focus on attracting and retaining high performing staff, alongside emphasis on building capability through investment in technical capability development, strengthening leadership and management skills, and targeted professional learning in 2024-25 resulted in lower turnover, with the attrition rate falling to 14.8 percent (2023–24: 22.3 percent).

3.21 The ANAO’s 2019 IntoSAINT assessment report linked elevated workloads to a risk to effective performance management. The 2025 survey results indicate a decrease in perceptions that workloads are well above capacity. Additionally, 2025 responses related to ‘leadership - immediate supervisor’ were largely positive, with all questions responded to with an at least 77 per cent positive rating. The positive response rate to ‘my supervisor provides me with helpful feedback to improve my performance’ at 79 per cent and response to ‘my supervisor is invested in my development’ at 80 per cent is comparative to or above the APS overall. These responses suggests that despite consistent reporting of elevated workloads, performance management has not been compromised.

3.22 The following APS Census results relate directly to integrity matters.

Table 3.2: Census results related to integrity matters

3.23 The 2025 APS Census responses to the questions related to bullying, harassment and discrimination show that the percentage of discrimination has slightly decreased and the percentage of bullying has slightly increased. The increase in the percentage of discrimination reported in the survey as occurring in the ANAO (current agency), as opposed to a previous agency, did not result in an increase in actual instances, although remains unacceptable. The basis of discrimination changed from the prior year, with age and race being the highest responses followed by gender discrimination.

3.24 A positive improvement in reporting bullying and harassment is noted, with 45 per cent of respondents reporting in line with ANAO policies. This is a substantive increase on the 2024 result of 17 per cent and in real terms. As noted in Chapter 2, the HRBP team received 2 formal reports of bullying and harassment, a decrease on the prior year (2023–24: 3), suggesting matters may have been resolved through reporting to supervisors and through informal advice from the People Team without requiring escalation to formal reporting.

3.25 Further work on improving awareness of reporting pathways and supporting a speak up culture, alongside the existing leadership messaging to raise and report inappropriate behaviour is required, noting the majority of respondents who experienced unacceptable behaviours (including discrimination) did not report the instance.

3.26 In 2025, the ANAO response related to the integrity culture and stewardship remained above the APS overall result (7 per cent higher), although the stewardship response decreased and was only one point higher than the APS overall. The response to stewardship may be an indicator of different understanding of stewardship in practice, however overall, results are a positive reflection on the culture and people within the ANAO.

3.27 The following questions relate to employee engagement.

Table 3.3: Census results related to employee engagement.

3.28 The overall ANAO employee engagement index score remained comparable to the prior year. While results related to employee’s willingness to go the extra mile and understanding of the contribution of their role to the APS dipped slightly, the ANAO is comfortable the results demonstrate that staff continue to have strong values and commitment to the purpose, objective and goals of the ANAO.

Maturity Assessment of the ANAO Integrity Framework

3.29 The NACC-developed Commonwealth Integrity Maturity Framework supports APS agencies and entities to assess and implement effective integrity frameworks tailored to risk profile, size and operating context, and establish action plans to uplift integrity maturity. The Framework includes eight integrity principles and four levels of maturity indicators, derived from key Commonwealth integrity laws, policies and procedures.

Source: NACC Commonwealth Integrity principles

3.30 To support the 2024-25 Integrity Report, the Integrity Advisor assessed the ANAO Integrity Framework against the eight principles in the Commonwealth Integrity Maturity Framework. Data and information informing the assessment includes information captured in Chapter 2 of this report, alongside review of ANAO policies, processes and guidance, strategic documents, internal communication, and activities undertaken to close out the 2019 IntoSAINT assessment recommendations.

3.31 Overall, the ANAO demonstrates a mature and embedded approach to integrity, with expectations clearly articulated and integrated into its strategic and operational frameworks. As a foundational principle of auditing, integrity is consistently considered across ANAO activities, even when not explicitly referenced. This assessment considers the ANAO’s position as a specialist agency, its size and resource profile; and that within its operating context, integrity risks are understood and effectively managed under current arrangements, consistent with the ANAO’s risk appetite and with mandatory obligations

3.32 The ANAO demonstrates a well-developed and proactive approach to promoting values and expected behaviours, managing fraud, corruption and protective security, reflecting a robust stance in these integrity domains. This includes a strong and proactive commitment to integrity through consistent communication of values and expected behaviours, integration of integrity principles across the employee lifecycle, and the implementation of robust systems for managing misconduct. Staff survey results further affirm that executive leadership supports staff awareness and understanding of integrity expectations, contributing to a culture of ethical conduct and continuous improvement.

3.33 The establishment of an Integrity Framework, closure of IntoSAINT recommendations, and ongoing monitoring and reporting reflect a mature posture that promotes transparency and accountability. The ANAO has actively sought to enhance the maturity of its monitoring and reporting of organisational integrity. Ongoing initiatives to strengthen the evaluation of integrity performance include review of integrity metrics and periodic assessments of the maturity of integrity risk management, including consideration of SAI and Commonwealth public sector requirements. These efforts are underpinned by regular review of Integrity Framework alignment with public sector expectations and the allocation of dedicated integrity resources, including the appointment of an Integrity Advisor and Public Interest Disclosure (PID) officers.

3.34 Areas that the ANAO could target for further maturation include enhancement of organisational knowledge, awareness, and communication, particularly in relation to integrity risks that may emerge during high volume work periods. As noted at paragraph 3.21, sustained, elevated workloads can present to an integrity risk to effective performance management, and create conditions for poor judgement.

3.35 Current integrity training provides a strong foundation for staff. However, there is an opportunity to improve our offering. This includes tailoring content for high-risk roles, supporting staff resilience during peak operational periods and adapting learning for different career stages to better manage integrity risks. This would foster deeper engagement and move beyond a compliance-based mindset, particularly in staff undertaking refresher modules. Embedding consistent feedback mechanisms will further support continuous improvement and ensure the relevance and impact of integrity education over time.

3.36 A further integrity aspect to mature relates to contract management practices. Effective, efficient, ethical and economical public resource management are cornerstones of public sector operations. ANAO policies and procedures support integrity and due diligence in resource management, including having mature systems in place to identify, monitor and respond to potential fraud, corruption and Code of Conduct breaches across its operations. However, targeted activities to mature contract management practices and enhance training through establishing a more structured risk management approach and comprehensive guidelines to support oversight across the full contract lifecycle could further mature ANAO operations.

3.37 Through implementation of the Integrity Framework, the ANAO will continue to focus on opportunities to continually strengthen and maintain its pro-integrity culture across its operations in 2025-26.

4.1 As set out in the ANAO Corporate Plan 2025–26, integrity and ethics remain an ongoing focus area for the ANAO, not only in our audit work, but also in performance of our mandate and functions. This ensures we maintain independence, professionalism, integrity, ethics and quality in our work.

4.2 The Parliament is increasingly seeking insights from the ANAO on the relationship between compliance and organisational culture. Compliance — not just with mandatory requirements, but also the intent — is a hallmark of integrity, and essential to public administration craft. The ANAO will continue to focus on providing transparency and accountability on regulatory frameworks, and the relationship with organisational culture, through our audit work.

4.3 Audit work has demonstrated that a culture of integrity in an organisation flows from the standards set by its leaders, including expectation setting through regular communications. The ANAO will continue to focus on the ethical aspect of proper use and management of public resources, including entity governance and ethical frameworks.

4.4 In 2025–26, the ANAO will continue to advance integrity maturity across its frameworks, processes, and capabilities to uphold independence and the highest ethical standards. As a strategic enabler, integrity will guide continuous improvement efforts aligned with the 2025–26 Corporate Plan and 2025-26 strategy on a page (SoAP), focusing on impact where it matters, driving performance through innovation, and inspiring and developing our people.

4.5 In addition to the ongoing support and advisory role of the Integrity Advisor, the following table sets out the Integrity strategy and plan for 2025–26.

4.6 The Integrity Advisor will report on the status of these actions to EBOM on a six-monthly basis in line with ANAO business plan reporting.

5.1 The ANAO is satisfied that the matters noted in this report do not represent systemic or structural integrity issues in the organisation.

5.2 While the ANAO faces challenges, risks and integrity vulnerabilities, it is positive that the risk to integrity has not been realised. The ANAO is a professional organisation of curious and critical thinkers with strong analytical capabilities who act with the highest integrity. ANAO staff believe strongly in the purpose and objectives of the ANAO and are committed to ANAO goals. The ANAO attracts people who want to make a difference and demonstrate the ANAO values. The matters raised in this report do not indicate that there are gaps in the resilience of the policies, procedures and controls that make up the ANAO Integrity Framework.

5.3 In 2025–26, the ANAO will continue to enhance integrity maturity across its frameworks, processes, and capabilities to safeguard independence and uphold the highest ethical standards. This will include a strong focus on identifying and monitoring potential risks and vulnerabilities, while actively supporting staff to build awareness, capability, and accountability through the ongoing embedding of a pro-integrity culture.