Probity in Practice: 10 Lessons on Building Public Sector Integrity

When was the last time someone in your agency used the word “probity” and it wasn’t because something had already gone wrong?

This question sat at the heart of a recent AcademyGlobal webinar that brought together Teresa Scott (Executive Director, APCC), Lewis Rangott (Executive Director of Corruption Prevention, NSW ICAC), Sanaz Mirzabegian (Chief Operating Officer, Digital Canberra, ACT Government) and Paul Vorbach (Director, AcademyGlobal) for an hour of candid, practical discussion on what it actually takes to embed integrity into everyday public sector work.

The conversation moved well beyond policy frameworks and checklists. Here are 10 lessons worth carrying into your next team meeting, procurement planning session or Monday morning.

1. If you are doing procurement well, you are already doing probity

One of the most useful insights from the session came from Lewis Rangott. He pointed out that experienced procurement teams practise probity every day without ever calling it that. They document decisions, manage conflicts, treat suppliers fairly and protect confidential information. It is simply what a good process looks like.

The word “probity” tends to surface only when something breaks down. That creates a perception problem. Staff start to associate probity with failure, investigations and extra paperwork rather than recognising it as the foundation of the work they already do well.

The panel’s message was clear: probity is not a handbrake on decision making. It is the reason decisions hold up under scrutiny.

2. Nobody wakes up planning to breach probity

Sanaz Mirzabegian offered one of the session’s most relatable observations. In her years advising on probity matters across the ACT Government, the vast majority of issues she has dealt with did not start with bad intentions. They started with one small adjustment.

A piece of information shared informally to smooth a supplier relationship. A corner cut to meet a deadline. A conflict left undisclosed because the person genuinely believed nobody would benefit from it. Each decision seemed minor in isolation but each one narrowed the path, making the next compromise a little easier to justify.

The pattern she described will be familiar to anyone who has worked in a high-pressure delivery environment. It is a reminder that probity failures rarely announce themselves. They accumulate quietly.

3. Leaders set the standard in the informal moments, not the formal ones

Paul Vorbach raised a point that deserves more attention than it typically gets. Formal governance documents, Codes of conduct, Compliance manuals, these all matter. But junior and less experienced staff are far more influenced by what they observe in informal moments.

How does a senior leader respond when a timeline is tight and a shortcut is available? What happens when someone raises a concern in a meeting and it is brushed aside? Do leaders model the behaviours they expect, or do their actions quietly contradict the written rules?

When there is a gap between what the policy says and what the culture rewards, staff will follow the culture every time.

4. Contract management is the overlooked probity risk

Much of the probity conversation in the public sector focuses on the sourcing and procurement phase. Evaluation panels, tender documentation, conflict declarations. These are well understood, even if imperfectly practised.

Paul extended the lens into contract management, where he sees a different set of risks that receive far less attention. Granting relief for non-performance without adequate justification. Extending contracts or exercising options when the contractor’s track record does not warrant it. Tolerating poor performance because the relationship is established and comfortable.

These are not dramatic corruption events, but they are probity failures that can erode public value just as effectively. If your training program covers sourcing but skips contract management, there is a gap worth closing.

5. The subtle risks are harder to manage than the obvious ones

Lewis Rangott drew on ICAC’s complaints and investigation experience to sketch out where corruption and probity risks actually sit.

The outright corruption cases tend to follow a pattern: an insider with financial delegation or influence directing contracts to themselves, a family member or an associate. These are serious, but they are also relatively identifiable.

The harder risks are subtler. A supplier who builds a relationship over months or years through hospitality and access before any procurement event takes place. Budget information that gets “socialised” during market sounding conversations. An incumbent supplier who gains an informational advantage simply by being on site. An external consultant running a procurement process without fully internalising public sector probity obligations.

These situations do not always involve bad faith. But they create uneven playing fields, and they are the risks that most agencies find hardest to detect and manage.

6. Staff understand policy but lack confidence to apply it

Sanaz introduced a framework that resonated throughout the session: the four Cs. Capability, culture and confidence are what drive good probity outcomes. But most organisations default to the fourth C, compliance, and wonder why issues persist.

Her observation was pointed. When she delivers probity training, the most common request from participants is “just tell me what I need to check off.” That instinct is understandable, but it misses the point. Probity issues rarely present themselves as clear yes-or-no decisions. They live in the grey areas where the right answer depends on perception, proportionality and context.

Policies can set the guardrails, but if staff do not have the confidence to exercise judgment within those guardrails, the policies are not doing their job. The challenge is not knowledge. It is the ability to act on that knowledge when the situation is ambiguous and the pressure is real.

7. “Insinuation anxiety” is silently undermining conflict management

One of the session’s standout contributions came from Lewis, who introduced a concept from Professor Sunita Sah at Cornell University. She calls it “insinuation anxiety,” which explains a pattern that most procurement professionals will recognise.

When someone on an evaluation panel honestly discloses a conflict of interest, the natural human response is to reward that honesty. The thinking goes: they have been transparent, they are clearly a person of integrity, it would be rude to suggest they might be biased. So the panel leaves them in their roles, feeling good about the disclosure process.

The problem is that disclosure alone does not manage the conflict. It simply makes it visible. The appropriate response is to thank the person, make clear that they are not being accused of wrongdoing, and then adjust their involvement to protect both the individual and the process. That takes confidence, and many panels lack it.

Lewis also noted a related issue: evaluation committees that avoid the difficult “gold-plated versus fit-for-purpose” conversation before going to market. When that discussion is deferred, panels end up opening bids at wildly different price points with no shared framework for choosing between them.

8. Scenario-based learning builds the muscle that e-learning cannot

The panel was united on one point: e-learning modules have a place in explaining frameworks, but they do not build the confidence to navigate real-world probity challenges. That requires practice, conversation and social learning.

Paul Vorbach outlined two approaches that have proven effective. The first approach is the “pre-mortem,” where a team imagines that an upcoming procurement has already failed due to a probity breach and works backwards to identify what could have caused it. The second approach draws on Albert Bandura’s Social Learning Theory, which demonstrates that ethical conduct is learned most effectively through small-group observation and discussion, not through individual study.

Sanaz shared practical examples from her own organisation: monthly “probity clinics” where staff bring real (or hypothetical) scenarios into group discussion, supplier debriefing rehearsals that practise the fine line between helpful feedback and inappropriate disclosure, and ministerial briefing exercises that explore how to inform without enabling undue influence.

Lewis framed it simply. Practising in a calm, low-stakes environment prepares you for the high-stakes, emotionally charged moments when your judgment is most likely to fail. The same principle that applies to sport or emergency response also applies to probity.

9. Probity and good outcomes are not mutually exclusive

An audience asked how professionals can maintain probity standards while still securing the best deal for their department. Sanaz challenged the assumption behind the question: the idea that probity and “winning” pull in opposite directions.

Her argument was that probity should be woven into the process, not applied on top of it. You can still achieve strong outcomes while being transparent about your constraints and bringing stakeholders along with you.

Paul added that the public sector needs to define “winning” on its own terms. Private sector firms may deploy aggressive commercial tactics and consider that normal practice. Public servants operate under a different set of obligations. The playing field is not level, and it was never meant to be. Winning in the public sector means achieving a sound outcome through a process that can withstand scrutiny. These two are not in tension. They are the same thing.

10. What agencies can do tomorrow

The session closed with a question that cut through the complexity: if your agency could do one thing better tomorrow to strengthen probity in practice, what should it be?

Paul Vorbach: Create deliberate opportunities for small groups to come together and talk openly about the probity challenges they have seen and the risks they anticipate. It signals that leadership values these conversations, and it opens channels for people to contribute in some less formal ways.

Sanaz Mirzabegian: Empower people to stop, reflect and seek guidance without fear. Informal probity check-ins where staff can raise ambiguous matters do more for integrity than any policy, tool or training program. Her three words: stop, reflect, seek advice.

Lewis Rangott: Give unempowered people a path to be heard. The person raising a probity concern is often not the project manager or the senior executive. They may have no positional authority at all. If their concerns get stuck in a local echo chamber, noted and filed with no visible action, the system has failed them. They need a clear route to someone who can make a difference.

Teresa Scott’s closing reflection

Probity and corruption prevention apply across every phase of the procurement lifecycle: going to market, assessing bids and managing contracts. The issues range from small and unintentional to large and deliberate, and they extend into areas like ministerial briefings that sit outside traditional procurement training.

At its core, probity is about leadership and culture, supported by training and education. It needs to be part of an organisation’s DNA, not a bolt-on.

Procurement is the gateway between public funds and public outcomes. When procurement gets it right, public trust is strengthened. When it does not, that trust erodes, and it is very difficult to rebuild.