Public sector urged to establish procedures to deal with improper conduct

Jamaica Information Service (JIS)

The public sector is being encouraged to adopt high ethical standards as outlined under the Protected Disclosures Act, 2011.

This urging comes from Bank of Jamaica (BOJ) Deputy Governor, George Roper who stated that public officers should seek to build a culture that promotes “ethical conduct and transparency”.

“If you want to create that kind of environment, that kind of culture in your organisation, you should welcome the legislation and you should get on board with developing the required policies and procedures,” Roper said.

The Act was established to regulate the receipt and investigation of disclosures of improper conduct as well as protect employees reporting these from being victimised through disciplinary action and/or dismissal, or being denied transfer or promotion.

It stipulates that all government entities should appoint at least one person as a designated officer with responsibility for receiving and investigating disclosures or improper conduct in the workplace.

Designated officers are also tasked with providing updates on the progress of the investigation to the person making the disclosure and communicating any findings and recommendations to that individual, their employer, and the designated authority.

Roper said it is important that persons being appointed designated officers be trained prior to assuming the role.

This, he explained, is to ensure they know how to handle disclosures in a confidential manner, develop an investigation plan, and keep the person who made the disclosure aware of the progress of the probe.

“If improper conduct does occur, then there needs to be recommendations that are made to the head of the entity. The head of entity will then give directions for appropriate remedial actions to take place,” the deputy Governor added.

Roper, who is responsible for finance, technology and administration at the BOJ, said the entity has been conforming with requirements under the Protected Disclosures Act.

He further notes that the bank, named as a ‘Prescribed Person’ under the Act, can accept reports of improper conduct from external parties in certain circumstances.

Disclosures can be made to a prescribed person if the employee believes that the subject matter of the improper conduct falls within the portfolio of that designation.

A disclosure could also be made to a Minister with responsibility for the relevant portfolio, or to the Prime Minister if the matters involve national security, defence or international relations.

The deputy governor reveals that he and other designated officers at the BOJ have participated in training and certification programmes offered by the Integrity Commission (IC) through the Management Institute for National Development (MIND).

“We found the training session to be very constructive, very insightful and one of the best that I have been on. You did not only get the theory delivered in an engaging manner but you had to apply the knowledge gained in case studies and a group project,” he added.

Roper noted that the BOJ has a policy, as outlined under the Protected Disclosures Act, and sensitisation and awareness training sessions are held with staff members to keep them au fait with the policy and the disclosure form rolled out for use in the reporting of improper conduct to a designated officer.

“This is very important because the bank treats matters relating to ethics as being very important. Ethical conduct is key to us because our reputation is vital to us. Central banks have to be seen as being credible institutions; and so the people who are in the institution need to have sound ethical conduct,” he stated.

Senior Protected Disclosures Officer, Information and Complaints Division at the IC, Tanesha Fagan, tells JIS that a major responsibility for the agency as the designated authority is to publish Protected Disclosures procedural guidelines for public bodies to review and implement within their operations.

“These guidelines outline the processes and procedures on how to make reports of improper conduct and how to assess and investigate these matters,” she explained.

Fagan said the commission has, so far, reviewed Protected Disclosures procedural guidelines from more than 100 public bodies.

In addition, she said that the commission has partnered with the Management Institute for National Development to deliver training for designated officers so that they are equipped with the requisite skills and functions to carry out their duties.