Ticket use for sponsored or financially supported events...As a result of the review, the PSC...

Review report

Ticket use for sponsored or financially supported events

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Public Sector Commission Dumas House, 2 Havelock Street, West Perth 6005Locked Bag 3002, West Perth WA 6872Telephone: (08) 6552 8500 Fax: (08) 6552 8810 Email: [email protected]: www.publicsector.wa.gov.au

© State of Western Australia 2016There is no objection to this report being copied in whole or part, provided there is due acknowledgement of any material quoted or reproduced from the report.

Published by the Public Sector Commission (Western Australia), February 2016.

This report is available on the Public Sector Commission website at www.publicsector.wa.gov.au

DisclaimerThe Western Australian Government is committed to quality service to its customers and makes every attempt to ensure accuracy, currency and reliability of the data contained in this document. However, changes in circumstances after time of publication may impact the quality of this information. Confirmation of the information may be sought from originating bodies or departments providing the information.

AccessibilityCopies of this document are available in alternative formats upon request.

Letter of transmittal

Consistent with my functions under section 22E of the Public Sector Management

Act 1994, and in accordance with section 22F, I submit to each House of Parliament

a report on a review of ticket use for sponsored or financially supported events.

The review considered the use of general admission tickets and VIP or corporate

box access for events received in relation to sponsored or financially supported

arrangements during the period 1 July 2013 to April 2015 (the period of reporting), as

reported by 126 government bodies to Parliament in April 2015.

Observations and recommendations arising from the review are considered to be of

such significance as to warrant reporting to Parliament in this manner.

M C Wauchope PUBLIC SECTOR COMMISSIONER 17 February 2016

THE SPEAKER LEGISLATIVE ASSEMBLY

THE PRESIDENT LEGISLATIVE COUNCIL

Contents

Commissioner’s foreword .............................................................................................. 6

Summary of recommendations ..................................................................................... 9

Agency management comments ................................................................................ 11

Detailed report .............................................................................................................. 12

1.0 Introduction ........................................................................................................ 12

2.0 Background ........................................................................................................ 142.1 Terms of reference ........................................................................................... 14

2.2 Scope .............................................................................................................. 14

2.3 Authority to conduct the review ....................................................................... 15

2.4 Assumptions and considerations .................................................................... 15

2.5 Review methodology/approach ....................................................................... 15

3.0 Observations and recommendations ............................................................... 173.1 Agency events activities .................................................................................. 17

3.2 Governance and transparency of event arrangements ................................... 32

Appendixes ................................................................................................................... 46

Appendix A – Review definitions ............................................................................ 46

Appendix B – Parliamentary questions .................................................................. 48

Appendix C – Structure of the WA public sector ................................................... 49

Appendix D – 17 government bodies involved in detailed analysis ..................... 51

Appendix E – Information requested from the 17 government bodies ................ 52

Appendix F – Reasons for attendance at events ................................................... 53

Appendix G – Agency reviews and practice improvements ................................. 56

Appendix H – Agency management comments .................................................... 61

Commissioner’s foreword Ticket use for sponsored or financially supported events Ticket use for sponsored or financially supported events 6

I am pleased to present the report on the review of ticket and VIP and corporate box use by government bodies for sponsored or financially supported events (the review).

This review arose from a written request dated 22 April 2015 from the Premier the Hon Colin Barnett MLA (the Premier), to the Public Sector Commission (PSC) in relation to answers provided to a series of parliamentary questions in April 2015 about the acquisition and provision by all public sector agencies of ticket and box access for sporting and cultural events.

Specifically, the Premier advised the PSC, that in his opinion, the agency responses to Parliament:

… give rise to some questions about the nature of and basis for some of these activities. I would greatly value the Commission’s assessment of the information provided and your advice, both in relation to specific agency activities and generally, as to whether further steps are required to ensure proper governance and transparency around such activities.

To provide advice to the Premier, as Commissioner I determined to undertake a review under section 24B of the Public Sector Management Act 1994 (PSM Act). The review only considered the use of general admission tickets and VIP or corporate box access for events received in relation to sponsored or financially supported arrangements during the period 1 July 2013 to April 2015 (the period of reporting), as reported by 126 government bodies to Parliament in April 2015.

The review did not cover:

• The rationale or decisions of government bodies entering into sponsored or financially supported arrangements. Such decisions may be made from specific reference in enabling legislation or a CEO’s broader general powers.

• Ad hoc hospitality expenditure, or offers involving the use of tickets and VIP or corporate box access that is generally managed by agencies through gifts and benefits and conflicts of interest type policies and procedures, and agency ethical codes such as codes of conduct.

Commissioner’s foreword

7Ticket use for sponsored or financially supported events Commissioner’s foreword

It is relevant to note that in relation to benefits to public employees, the Office of the Auditor General (WA), Public Sector Performance Report 1997 – Sponsorship in the Public Sector stated:

Some sponsorships offer opportunities for travel, hospitality and entertainment. The ethics of the public service require that individual employees should not accept significant benefits to themselves.

The Auditor General’s report recommended that agencies should cautiously investigate the opportunities for sponsorship, but also the risks and difficulties.

Sponsorship is not something new for government bodies, as for the 366 events reported about how long arrangements were in place, the majority (62%) have been in place for a period greater than 5 years. Notwithstanding this, as the Healthway investigation highlighted, agencies need to be mindful of and ensure transparency and proper controls over sponsorship activities.

As a result of the review, the PSC considers that since the Healthway investigation report was tabled, government bodies are more mindful and conservative about the circumstances applying to sponsored or financially supported arrangements and the use of tickets and VIP or corporate box access to events pursuant to these arrangements.

We are also of the view that the oversight applied by agencies in regard to sponsored and financially supported events, has improved significantly. This view is supported by the review observing that:

• 59% of the event arrangements were reported as being reviewed by their government body in the last year, and 30% between 1 to 2 years.

• All government bodies involved in the detailed analysis survey reported having policies, procedures, guidelines and/or checklists in place to assist employees to make and record decisions about the acquisition and use of tickets and VIP or corporate box access. These bodies reported that they use a total of 64 various policy and guidance documents to assist their employees to make and record decisions for the management of sponsored or financially supported events. Of the 64 documents, 77% were reported as being reviewed less than 1 year ago.

• Of the government bodies surveyed, 11 reported processes to register the nature, number, allocation and utilisation of events and tickets used and not used by their agency as 'integrated' in their corporate systems.

8 Commissioner’s foreword Ticket use for sponsored or financially supported events

Of some concern is that 20% (3200 tickets) of the total ticket use was reported as private use. This issue requires addressing to eliminate or, at a minimum, significantly reduce this type of use. On a positive note, it is pleasing to see some government bodies, which were previously involved in sponsored or financially supported events, have reflected on their involvement in this, and made the decision to either cease any such involvement or adopt a more conservative approach in accepting and using tickets to these events. Examples of these include:

• VenuesWest – Conducted an internal review of its Corporate Hospitality and Ticket Allocation policies and practices, as a result of which it now ensures ‘that a conservative and sensitive approach to the management of tickets and an emphasis on the use of such inventory for public benefit at all times’ is adopted.

• Gold Corporation – The Executive Management decided from 3 March 2015 no tickets would be taken up by any employees or officers of Gold Corporation.

• Department of Culture and the Arts (DCA) – Following the release of the Healthway report, DCA introduced an ‘Attendance at Events’ policy and electronic workflow under which Director General approval is required to be gained before events are attended, after meeting certain criteria and only where there are justified business reasons and benefits for attending the event.

The PSC acknowledges the good work done by many agencies to improve their management of event arrangements, and we encourage them to implement the recommendations in this report and continue this work.

Lastly, I would like to thank all of the government bodies who participated in the review for their cooperation and assistance in the review process.

M C Wauchope PUBLIC SECTOR COMMISSIONER

Ticket use for sponsored or financially supported events Summary of recommendations 9

Summary of recommendations

Recommendation 1 – Types of event arrangements

Government bodies should ensure that arrangements for sponsored or financially supported events take into account any government and agency policies and other guidelines, instructions and delegations relevant to each of these arrangements. These include the following:

• Public Sector Management Act 1994, section 7 ‘Public administration and management principles’ and section 9 ‘Principles of conduct’

• State Supply Commission, ‘Sponsorship in government guidelines’ (SSC Sponsorship guidelines)

• Department of Finance, ‘Delivering community services in partnership policy’

• The Integrity Coordinating Group (ICG), ‘Gifts, benefits and hospitality: A guide to good practice’

• The ICG, ‘Conflicts of interest – Guidelines for the WA public sector’

• Public Sector Commission (PSC), Commissioner’s Instruction No. 7 – Code of Ethics

• PSC, Commissioner’s Instruction No. 8 – Codes of conduct and integrity training

• PSC, ‘Tickets and hospitality – Integrity controls checklist’ (Integrity controls checklist)

• Internal policies governing the use of other formal or ad hoc expenditure which may involve attendance at events and ticket use.

Recommendation 2 – Approvals of event arrangements

Where required, appropriate ministerial, CEO or delegate approvals should be obtained for any sponsored or financially supported events.

Recommendation 3 – Reviews of event arrangements

To ensure proper oversight and financial management of any ongoing sponsored or financially supported arrangements, government bodies should make certain the terms of these arrangements are reviewed periodically, and where considered appropriate, this requirement is included in any contractual arrangements, policies and corporate governance systems.

Recommendation 4 – Alignment to core business, and ticket use

All government bodies should have an informed and conservative approach when making decisions about sponsored and financially supported events. The approach used should ensure:

10 Summary of recommendations Ticket use for sponsored or financially supported events

a. there is a defensible public purpose and justifiable alignment between a sponsored or financially supported event and the government body’s core business

b. board members or employees who attend ticketed sponsored or financially supported events do so for a valid and defensible ‘business’ reason, which should be recorded

c. ‘private use’ is eliminated or significantly scrutinised and reduced

d. decisions on the use of tickets stand up to public scrutiny.

Recommendation 5 – Assessment of policies, procedures and guidelines

All government bodies which are involved in sponsored or financially supported events should, at a minimum, ensure that:

a. they integrate all of the elements of the Integrity controls checklist into their policies, systems and guidance documents around the acquisition and provision of tickets

b. a register is maintained in relation to ticket use for sponsored or financially supported events, which includes at a minimum the following fields:

– name and date of the event

– name of the organisation or person offering the tickets and their relationship to the officer or the government body

– reason for the offer

– number and value of the tickets, and the nature of the tickets (i.e. whether they are general admission or VIP)

– name and position of employees of the government body or other persons using the tickets (or whether the tickets were unused)

– reason for attendance (i.e. what is the alignment of the attendance to business purpose, e.g. speech or presentation, collaboration with key business partners etc)

– whether approval of a senior officer has been given for the use of the tickets (including identity of the senior officer).

c. periodic audits of the arrangements in place are undertaken against the Integrity controls checklist

d. where relevant, policy and guidance documents take into account and include reference to the requirements of the SSC Sponsorship guidelines.

Recommendation 6 – Practice improvements

Government bodies which have commenced or completed reviews of event arrangements and ticket policies, procedures and processes, should if not already done, ensure any recommendations from these are adopted and implemented.

Recommendation 7 – Practice improvements

Government bodies which are yet to assess their policies, procedures and processes against the Integrity controls checklist requirements, should ensure this occurs.

Ticket use for sponsored or financially supported events Agency management comments 11

Agency management comments

The government bodies which participated in the review generally accepted the recommendations made, and confirmed they have either already taken, or are in the process of taking, improvement action for managing tickets, VIP access or access to corporate boxes for sponsored or financially supported events.

The management comments received from the 17 agencies in response to the review report are listed in Appendix H.

Detailed report Ticket use for sponsored or financially supported events12

Detailed report

1.0 Introduction

On 19 February 2015, the Acquisition and use of hospitality resources by Healthway – Investigation report (Healthway report)1 was tabled in the Western Australian Parliament. The Healthway report covered the management of sponsorships at Healthway, and included the following ‘main findings’:

• Healthway have a strategic business rationale for the acquisition of some hospitality resources. However, the volume and nature of what was obtained through sponsorship arrangements … is considered excessive and inconsistent with the obligation to be scrupulous in the use of public resources under the accountability principle in the Public Sector Code of Ethics.

• Governance arrangements surrounding the acquisition and use of hospitality resources in sponsorship arrangements were inadequate in the context of State Supply Commission guidelines on public sponsorship.

• The investigation concluded that 43% of hospitality resources obtained (by volume) were used for a legitimate business purpose, 21% were used in a manner considered to represent a private benefit to Healthway officers, their families and friends and 36% could not be properly accounted for.

• Insufficient controls were established around the sponsorship contracts to ensure that hospitality resources were used solely for a public purpose.

The Healthway report also made 15 recommendations about improvements that could be made in the administration of sponsorships. The Public Sector Commission (PSC) subsequently produced and distributed to government bodies a 12 point ‘Tickets and hospitality – Integrity controls checklist’ (Integrity controls checklist)2, to guide ‘ethical and accountable decision making for organisations managing contracting, sponsorship and grants arrangements’.

1 Available on the PSC’s website at: https://publicsector.wa.gov.au/news-events/news/acquisition-and-use-hospitality-resources-healthway-%E2%80%93-investigation-report 2 Available on the PSC’s website at: https://publicsector.wa.gov.au/document/tickets-and-hospitality-integrity-controls-checklist

13Ticket use for sponsored or financially supported events Detailed report

Following the tabling of the Healthway report, two parliamentary questions (listed in Appendix B) were put to the Premier and Government Ministers in relation to the receipt of general admission tickets, VIP or corporate box access for any events sponsored or financially supported by government bodies3 (also referred to as ‘agencies’ in this report) within their portfolios between 1 July 2013 to April 2015.

The information provided by government bodies in response to the two parliamentary questions overlapped somewhat. The review concentrated primarily on the information provided by 126 government bodies in response to the second parliamentary question as this information enabled a more detailed analysis. The wording of the second parliamentary question was adopted to inform the review.

This report has been prepared in response to a request from the Premier, for the Public Sector Commissioner to assess the information provided to Parliament by the government bodies, in regard to the receipt of tickets for events sponsored or financially supported by government bodies within their portfolios between 1 July 2013 to April 2015.

3 See definition of ‘government bodies’ in Appendix A.

14 Detailed report Ticket use for sponsored or financially supported events

2.0 Background

2.1 Terms of reference

The review assessed:

1. specific activities of government bodies in regard to general admission tickets, VIP or corporate box access (tickets), for sponsored or financially supported events (event arrangements)

2. whether further steps are required to ensure proper governance and transparency around such activities.

2.2 Scope

Of the 126 government bodies which provided responses to Parliament, 434 (34%) reported participation in sponsored or financially supported event arrangements involving the use of tickets.

The review covered the 43 government bodies which reported the following information to Parliament for the period 1 July 2013 to April 2015:

• 1204 individual events (the review looked at a sample of 406 actual ‘events’ of 17 government bodies e.g. Hopman Cup treated as one event, does include a number of ‘day’ events), and

• 18 669 tickets (16 000 tickets of 17 government bodies after clarification with those bodies).

The review was not an investigation of the conduct of persons or specific actions, nor was it a forensic audit of transactions, and excluded assessing:

• The rationale or decisions of government bodies entering into sponsored or financially supported arrangements as these are varied (refer to ‘ticket use’ in section 3.1.4 (b)). Such decisions may be made from specific reference in enabling legislation or a CEO’s broader general powers.

• Ad hoc hospitality expenditure, or offers involving the use of tickets and VIP or corporate box access, which is generally managed by government bodies through gifts and benefits and conflicts of interest type policies and procedures, and agency ethical codes such as codes of conduct.

4 Of the 126 responses, 73 government bodies responded in the negative to the second parliamentary question. The 43 government bodies which responded in the affirmative, excludes 9 which reported only events that are awards and conferences. Healthway was also excluded from the review as the PSC has already undertaken the investigation recorded in the Healthway report.


2.3 Authority to conduct the review

In relation to departments, SES organisations and non-SES organisations, the review was conducted under section 24B in subdivision 1, ‘Reviews’5 of the Public Sector Management Act 1994 (PSM Act).

The PSC does not have any compulsory powers under the PSM Act in regard to Government Trading Enterprises (GTE). The GTE identified as within the scope of the review cooperated with the review following a request from the Public Sector Commissioner to the relevant Minister and Chair of each GTE board.

An overview of the structure of the Western Australian public sector is outlined in Appendix C.

2.4 Assumptions and considerations

The review and report only cover the government bodies which provided responses to the two parliamentary questions. There may be government bodies which:

• may be expected to have event arrangements, which responded in the negative to the parliamentary questions, and

• did not provide any data to their Minister or to Parliament.

The review made the assumption that the information reported to Parliament is accurate and complete.

2.5 Review methodology/approach

The review was thematic in nature, covering a particular subject across a number of government bodies. It was not a forensic audit, examination or investigation of any individual or the activities of government bodies in regard to general admission tickets, VIP or corporate box access, for sponsored or financially supported events.

Given the relatively high number of government bodies that reported events and ticket use, the following risk based assessment was undertaken in conducting the review.

Preliminary analysis – 43 government bodies

A preliminary analysis was conducted of the information submitted to Parliament by the 43 government bodies.

From this analysis, the review determined the following:

• 26 government bodies were not required to provide further clarification around the reported event and ticket activity. These bodies were assessed as having few events or tickets, and those reported were considered to be related to the role, business, goals, objectives and image (i.e. business purpose) of the organisation.

5 PSM Act s. 24B – The Commissioner may on his or her own initiative conduct a review in respect of part or all of the functions, management or operations of one or more public sector bodies.


• 17 government bodies (listed in Appendix D) were assessed as requiring minor or significant clarification6 about the reported event and ticket activity.

Detailed analysis – 17 government bodies

The review conducted the following analysis:

• Assessed information (see Appendix E) obtained through a ‘Request for information’ (the survey) from the 17 government bodies.

• Assessed policies from 8 of the 17 government bodies included in the survey to determine to what extent those documents addressed the requirements contained in the Integrity controls checklist.

Discussions were also held with relevant persons from the government bodies participating in the review.

6 ‘Nil’ clarification – very few events or tickets were involved, and these were considered to be directly related to the role, business, goals, objectives and image (i.e. business purpose) of the organisation. ‘Minor’ clarification – a low number of events and tickets were reported and while the events appear related to the business purpose of the organisation, the number of tickets was high; or where a low number of events and tickets were reported, but further clarification of reported information is required, for example, due to a lack of detail. ‘Significant’ clarification – the number of events and/or tickets is high; and/or some or all of the events do not appear relevant to the business purpose of the organisation.


3.0 Observations and recommendations

3.1 Agency events activities

For reasons including the proper management and efficient use of public resources, and maintaining integrity, public trust, and compliance in public sector processes, it is important for government bodies to understand:

• the type of event arrangements being entered into

• if appropriate approvals are in place

• when the arrangements were reviewed.

3.1.1 Types of arrangements

The types of event arrangements entered into by government bodies, may be subject to direct or implied compliance requirements.

To clarify the degree of accuracy and better understand the information reported to Parliament, the PSC requested the 17 government bodies participating in the detailed analysis stage of the review, to inform us about the types of arrangement entered into under the following headings:

Figure 1 Depicts the ‘type of arrangement’ and definition of these for each event reported in detail by the 17 government bodies

Type of arrangement Definition

Sponsorship (incoming) State Supply Commission Sponsorship in government guidelines: When a public authority receives sponsorship monies from another party for an initiative and/or event.

Sponsorship (outgoing) State Supply Commission Sponsorship in government guidelines: When a department provides sponsorship monies to another party for an initiative and/or event.

Financial support (e.g. grants or contractual arrangements)

No known source of a definition: PSC view – Financial support provided or received by the agency, e.g. through direct grants or contractual arrangements or in-kind provision of facilities free or at a discounted rate.

Other formal arrangements

No known source of a definition: PSC view – Formal arrangements outside of sponsorship arrangements or arrangements for financial support.

Ad hoc No known source of a definition: PSC view – Unexpected or impromptu offers of hospitality to attend events, or gifts of tickets.


Sponsorship

The State Supply Commission (SSC) provides guidance about sponsorship within government, and has developed ‘Sponsorship in Government Guidelines’7 (SSC Sponsorship guidelines). These are a useful reference point for all government bodies and state:

Sponsorship is the right to associate the sponsor’s name, products or services with the sponsored organisation’s service, product or activity, in return for negotiated and specific benefits such as cash or in-kind support or promotional opportunities. It involves a negotiated exchange and should result in tangible, material and mutual compensation for the principal parties to the arrangement.

Types of sponsorship include:

In-kind sponsorship is the provision or receipt of goods or services to support or enhance an initiative at a reduced rate or free of charge. These arrangements are also liable for GST.

Incoming sponsorship is when a public authority receives sponsorship monies from another party for an initiative and/or event.

Outgoing sponsorship is when a department provides sponsorship monies to another party for an initiative and/or event.

In regard to ‘outgoing’ sponsorship, the SSC Sponsorship guidelines also state:

Where a public authority engaged in providing sponsorship is also purchasing a good or a service, the State Supply Commission Act 1991 may apply. In this situation the transaction involved with the sponsorship activity may be viewed as a contract under this legislation. However, activities such as the provision of money, naming rights, sponsorship recognition on letterheads or similar will not under normal arrangements, be considered as contracts for goods or services and would be outside the provisions of the State Supply Commission Act 1991.

Under the SSC Sponsorship guidelines the following subjects are not considered to be sponsorship activities:

• grants or funding – monies or goods provided to a recipient through a formally recognised program for a specified purpose. A grant is normally understood as a form of financial assistance that assists an individual or organisation to develop a specific project, with no expectation of a commercial return or benefits

• stand-alone advertising contracts

7 Published in August 2001 and revised in July 2014. As indicated in the Healthway report, core requirements and material issues considered in both versions of the guidelines are entirely consistent.


• joint ventures, consultancies or partnerships in which the organisations share ownership and responsibility for the ultimate outcome or product

• projects such as displays and exhibitions in which the sponsor does not receive genuine and measurable value for money

• gifts, donations, bequests, endowments and prizes.

Arrangements for financial support (grants or contractual arrangements)

In addition to ‘sponsored’ event arrangements, the term ‘financially supported’ in relation to events, was also used in the parliamentary questions in regard to the reporting of ticket use.

For the purpose of the review, ‘financially supported’ was taken to mean ‘financial support provided or received by the government body; for example, through grants or contractual arrangements’.

In regard to policy and guidance for government bodies on the management of grants and contractual arrangements, the Department of Finance ‘Delivering Community Services in Partnership Policy’ (Partnership policy), a ‘policy to achieve better outcomes for Western Australians through the funding and contracting of community services’ states:

Public Authorities must adhere to the following requirements to capture community and service provider input into client and service user needs. Planning should be premised on recognition of investing in building the capacity of the not-for-profit community sector to respond effectively to community needs, through a variety of approaches, including volunteer effort and other community initiatives. As policies applicable to grants are currently formulated by individual Public Authorities (as grants are not subject to the State Supply Commission Act 1991), all policies for grant funding in respect of Community Services must align with this Policy.

The Partnership policy also states the only ‘funding arrangement’ that it relates to is a grant.8

8 Other flexible arrangements may be available to public authorities, but fall outside the scope of the policy.


Survey results – Type of arrangements

The 17 government bodies which participated in the survey were involved in a total of 406 events across the following 5 types of arrangements involving ticket use. For these arrangements, 255 (63%) events were reported as financially supported and 112 (27%) were outgoing sponsorship events.

Figure 2 Depicts the ‘type of arrangement’ reported by the 17 government bodies

1%

27%

63%

6% 3%

Types of arrangement (all bodies)

Figure 3 For the period of reporting, of the 406 events reported, the most significant participants in events and ticket use were the following government bodies

Government bodyNumber of

eventsNumber of

ticketsAverage tickets

per event

Tourism WA 30 6173 206

Lotterywest 80 3238 40

Water Corporation 14 2691 192

Department of Culture and the Arts

190 426 2

1%

27%

63%

6% 3%

Types of arrangement (all bodies)

Sponsorship (incoming)

Sponsorship (outgoing)

Financial support

Other formal arrangements

Ad hoc


Discussion

It is acknowledged that government bodies such as Tourism WA, Lotterywest, the Department of Culture and the Arts and others have business functions which require involvement in event arrangements.

It is important that government bodies which are involved in attending events are aware of what government or internal policy, guidelines and contractual obligations they may need to take into account in making decisions and managing attendance at these events.

The Healthway report made observations, findings and recommendations on the contractual aspects of managing sponsorships, of which the principles may also apply to other types of financially supported events. These included:

• Insufficient controls were established around the sponsorship contracts to ensure that hospitality resources were used solely for a public purpose.

• Establish a risk and assurance checklist to support the process of finalising and authorising sponsorship contracts.

The survey results indicate that 28% of the arrangements reported were incoming or outgoing ‘sponsorship’ i.e. falling within the scope of the requirements of the SSC Sponsorship guidelines.

A significant proportion, in total 72% of the arrangements entered into which include grants, fall outside ‘sponsored’ arrangements and therefore the scope of the SSC Sponsorship guidelines. Under the Partnership policy, grants are not subject to the State Supply Commission Act 1991, and all policies for grant funding in respect of community services must align with the Partnership policy.

Recommendation 1

Government bodies should ensure that arrangements for sponsored or financially supported events take into account any government and agency policies and other guidelines, instructions and delegations relevant to each of these arrangements. These include the following:

• PSM Act, section 7 ‘Public administration and management principles’ and section 9 ‘Principles of conduct’

• State Supply Commission, ‘Sponsorship in government guidelines’

• Department of Finance, ‘Delivering community services in partnership policy’

• The Integrity Coordinating Group (ICG), ‘Gifts, benefits and hospitality: A guide to good practice’

• The ICG, ‘Conflicts of interest – Guidelines for the WA public sector’

• PSC, Commissioner’s Instruction No. 7 – Code of Ethics

• PSC, Commissioner’s Instruction No. 8 – Codes of conduct and integrity training


• PSC, ‘Tickets and hospitality – Integrity controls checklist’ (Integrity controls checklist)

• Internal policies governing the use of other formal or ad hoc expenditure which may involve attendance at events and ticket use.

3.1.2 Approvals

The approval of financial agreements including sponsorships, grants and other arrangements is a critical management responsibility to ensure the proper and effective oversight of the arrangement, and use of agency resources.

For arrangements such as sponsored and financially supported events involving the allocation of funds, government bodies should be aware of where approval is required through compliance instruments and internal delegations.

In regard to sponsorships, the SSC Sponsorship guidelines state:

Public authorities should seek the approval of the Minister responsible (or the Minister’s delegate), for the administration of the public authority before considering entering into any sponsorship arrangements in the following areas:

• tobacco-related sponsorships;

• alcohol or drug-related sponsorship;

• where a potential sponsor could seek to use the sponsorship arrangement to influence legislation, public policy or the legislated role of the public authority concerned;

• events which duplicate or would compete with existing Government sponsorship projects (e.g. a second car rally or second golf tournament);

• projects which are likely to adversely affect the content or interpretation of the public authority’s programs or services or may raise a conflict of interest;

• sponsorship of a political party;

• service organisations which may use the funds to sponsor or make a grant to a third party; and

• areas which have the potential to cause widespread public controversy.

Care should be taken to ensure that a sponsorship arrangement does not involve a public authority specifically endorsing a sponsor’s product. Where a sponsorship arrangement is moving from a situation of acknowledgment of a sponsor’s product to one of specifically endorsing the product, this should be referred by the Chief Executive Officer of the public authority, or in the case of a statutory authority the Board of Management, to the relevant Minister.


Survey results – Ministerial and CEO approval

For the events reported as requiring ministerial or CEO approval, 59% and 98% respectively, were reported as receiving approval.

Figure 4 Ministerial and CEO approval for sponsorship or financial support arrangements

0 50 100 150 200 250 300 350 400

Ministerial approval obtained

CEO approval obtained

Number of events

Ministerial and CEO approval

YesNo

Discussion

Where relevant approval processes are not adhered to, there is an increased risk that inappropriate arrangements may be entered into. This may result in financial and reputational detriment to the agency and government.

While the number of events reported as requiring ministerial approval was relatively low (32), the percentage of these reported as not receiving approval was 41%. This suggests some attention may be necessary to ensure ministerial approval is obtained for certain sponsored or financially supported events.

Recommendation 2

Government bodies should ensure that where required, appropriate ministerial, CEO or delegate approvals are obtained for any sponsored or financially supported events.


3.1.3 Length and reviews of arrangements

Good governance and financial management of event arrangements, should include periodic reviews of any applicable terms and contractual arrangements.

Survey results – Length and reviews of arrangements

Information was provided in regard to how long the type of event arrangement had been in place for 366 events. The majority (62%) were in place for a period greater than 5 years, 14% for 2 to 5 years and 24% for less than 2 years.

Figure 5 Length of time arrangements have been in place – reported by the 17 government bodies

89

51

226

0

50

100

150

200

250

<2 years 2 to 5 years >5 years

Events

Period of arrangement

Length of time arrangementshave been in place

Information was also provided regarding when 356 events were last reviewed. The majority (59%) were reviewed less than 1 year ago, 30% between 1 to 2 years, and 11% for a period greater than 2 years.


Figure 6 When arrangements were last reviewed – reported by the 17 government bodies

212

106

35

30

50

100

150

200

250

<1 year 1 to 2 years 2 to 3 years >3 years

Events

Period last reviewed

When arrangements were last reviewed

Discussion

The majority (62%) of events reported have been in place for a period greater than 5 years. This indicates the subject of sponsored and financially supported arrangements involving tickets to events, is not something new for government bodies.

It is encouraging that 59% of the arrangements reported were reviewed by their government body in the last 12 months, and 30% between 1 to 2 years. This may be partly because of the Healthway report findings and recommendations. However, the action taken by these government bodies provides some confidence the majority are strengthening efforts to monitor their sponsorship and financially supported arrangements.

Recommendation 3

To ensure proper oversight and financial management of any ongoing sponsored or financially supported arrangements, government bodies should make certain the terms of these arrangements are reviewed periodically, and where considered appropriate, this requirement is included in any contractual arrangements, policies and corporate governance systems.


3.1.4 Alignment to core business, and ticket use

The PSC considers attendance by staff at sponsored or financially supported events should not be justified merely by the fact they work for a government body that is involved in sponsoring or financially supporting an organisation.

The following statements from a number of government oversight bodies and groups provide some perspectives and guidance on this subject.

The SSC Sponsorship guidelines state:

...it is inappropriate for any employee of a public authority to receive a personal benefit from a sponsorship.

The Integrity controls checklist states that government organisations should:

Be able to confidently relate the requirements for tickets and hospitality to a defensible public purpose.

The ICG ‘Gifts, benefits and hospitality’ guide states:

The receipt of gifts, or other non-monetary benefits, including rewards or offers of hospitality, can place a public officer in a position of actual, perceived or potential conflict of interest. Public authorities should develop clear and consistent protocols for all employees to follow in the event that a gift or benefit is offered to them or their employer. This is particularly important where employees are involved in procurement functions, sponsorship or commercial dealings with the private sector.

The ICG ‘Conflicts of interest’ guidelines state:

Public officers have a responsibility to always serve the public interest in performing their duties. Personal interests, whether these are financial, or relate to family, friends or associates, should not influence public duty.

The Independent Commission Against Corruption (NSW) (ICAC) ‘Sponsorship in the public sector’ guide states:

It is inappropriate for any employee of a public sector agency to receive a personal benefit from a sponsorship.

This principle should be included in the agency’s code of conduct. Sponsorship should not benefit individual staff but must be used in the public interest. Where a benefit provided by a sponsor is used by an individual staff member, for example, attendance at a conference, the agency should minimise the possibility of perceptions that a personal benefit was given to an individual public official. …


Personal benefits

• No employee of your agency may seek or receive a personal benefit or be perceived to receive a personal benefit from a sponsorship.

• Any contribution from the sponsor should go to the agency, not directly to an individual, and must be seen to benefit your agency, not an individual.

The PSC considers the key points that should be contemplated in regard to board members or employees attending any proposed sponsored or financially supported events are:

1. there needs to be a defensible public purpose and justified alignment of an event to core business and

2. a valid and defendable ‘business’ reason for attendance at the event.

3.1.4 (a) Alignment of events to core business

We asked the 17 government bodies to report on the alignment of events and use of tickets under the arrangement to core business against the following ratings.

Rating Description Example

High The event is closely aligned to an important business function or objective.

Assessing compliance with sponsorship obligations; monitoring the outcome of a grant.

Medium While not essential, the event is connected to the business functions or objectives.

Attendance at industry showcase events, trade shows, professional association events.

Low While there may be an indirect benefit to the government body, the event is not directly related to a business function or objective.

A ticket reward scheme for staff providing recognition for their contribution to the business.

Nil There is no alignment between the event and a business function or objective.


Survey results – Alignment of events to core business

In regard to the alignment of events to core business, 96% of these were reported in the high/medium categories (74% high and 22% medium), indicating government bodies consider the events are connected to or closely aligned to business functions or objectives.

Figure 7 Alignment of events to core business

8

7

91

300

0 50 100 150 200 250 300 350

Nil

Low

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High

Number of events

Rating

Alignment of events to core business

Discussion

It is encouraging to note that a high percentage of the government bodies sampled, reported in the high/medium range of alignment of events to core business. It is also pleasing to see some government bodies, previously involved in sponsored or financially supported events, have reflected on their involvement in this, and made the decision to either cease any such involvement or adopt a more conservative approach in accepting and using tickets to these events. Examples of these include:

• VenuesWest – Conducted an internal review of its Corporate Hospitality and Ticket Allocation policies and practices, as a result of which it ensures ‘that a conservative and sensitive approach to the management of tickets and an emphasis on the use of such inventory for public benefit at all times’ is adopted.

• Gold Corporation – The Executive Management decided from 3 March 2015 no tickets would be taken up by any employees or officers of Gold Corporation.

• Southern Ports Authority (SPA) – Since March 2015 the SPA policy states:


The SPA will not accept gracious favours from an Applicant, free invitations from applicants to attend an event will not be distributed among Staff and those wanting to attend the event for personal reasons must pay the fee at their own expense as per other guests attending the event.

• Department of Culture and the Arts (DCA) – Following the release of the Healthway report, DCA introduced an ‘Attendance at Events’ policy and electronic workflow under which Director General approval is required before events are attended, after meeting certain criteria and only where there are justified business reasons and benefits for attending the event.

The review scope does not include considering the rationale or decisions of government bodies entering into sponsored or financially supported arrangements. However, on the information assessed, it is suggested that it would be prudent for agencies to review their involvement in sponsored or financially supported events to determine:

1. the degree of alignment of the arrangement to their core business, and

2. whether having the arrangement meets the public purpose test.

A low level of a valid and defendable ‘business’ reason for attendance at the event may justify taking a more conservative approach in accepting and using tickets to these events or ceasing any such arrangement.

3.1.4 (b) Ticket use

We asked the sample of 17 government bodies to indicate the proportion of the total tickets used for the event against the following ratings.

Rating Description

Business use • Board members, including deputies, or committee members on official duty, or

• Agency staff on official duty

External stakeholders/parties

• Ticket competition prize winners• Representatives from the agency’s campaign partner

organisations or other sponsored organisations • Media personnel• Political stakeholder• Professional associates

Private • Agency staff, or member of board or committee not performing official duties

• Family member (including partner) of agency staff or member of board or committee

• Friends of agency staff or member of board or committee

Unused • Tickets or proportion of tickets remaining unused

Unknown • Unrecorded• Not accounted for


Reported reasons (see Appendix F for the full list by government body) for why board members and employees attend sponsored or financially supported events were varied, and included:

• representing the government body or the Government

• ensuring compliance with grant agreements

• contributing to local communities

• creating opportunities for customer relationship building

• engaging with customers to understand their needs

• helping to build positive relationships with stakeholders and customers

• enhancing reputation as a good corporate citizen

• increasing awareness, understanding and support for the agency business

• creating opportunities for communication and interaction

• facilitating targeted promotion.

Survey results – Ticket use

On whether there is a valid and defendable ‘business’ reason for a board member or employee’s attendance at the event, ticket use was reported as 47% business use, and 20% private use.

Figure 8 Ticket use – categories

2%

14%

20%

17%

47%

Ticket use - categories

UnknownUnusedPrivateExternal stakeholders/partiesBusiness use

2%

14%

20%

17%

47%

Ticket use - categories

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The 17 government bodies were also asked to indicate:

Whether any tickets were allocated to or used by family members, friends or acquaintances of board members or agency staff that were outside circumstances where social protocol would dictate that an invitation to an event may be extended to the partner of a Chair, board member or senior staff member.

The responses to this were: 4 ‘yes’, 11 ‘no’, and 2 ‘not indicated’. The explanations for the ‘not indicated’ responses were:

• the information was not contained within the sponsorship register

• staff were representing the agency, however as they did not have an official role this was marked as private.

Discussion

Sponsorship or financial support for an event may be closely aligned to a government body’s core business, however it does not follow that all tickets received by that government body for the event would always meet public expectations that the tickets are used in an appropriate manner, i.e. for a public purpose.

In general, attendance by board members or employees at events without a specific ‘public purpose’ or ‘business focussed’ role should not occur. Staff or board members should ask themselves, is there any essential benefit to the business in me attending the event? If not, then they should strongly consider whether it would be appropriate for them to attend the event.

It is concerning that:

• 4 of 17 responses from government bodies indicated tickets were used or allocated outside circumstances where social protocol would dictate this should occur

• 20% (approx. 3200 tickets) of the total ticket use reported was as private use. This issue requires addressing to eliminate or, at a minimum, significantly reduce this type of use.

As a comparison, while not implicitly relating to sponsorship and financially supported events, some examples of positions taken in managing benefits and hospitality in the private sector9 include:

• Employees may accept event tickets which includes private box access to events but must reimburse the giving party for the face value of the ticket. Also, if the gift is an access ticket with no indicated face value, reimbursement should be based upon the fair market value of the ticket.

9 United Nations Office on Drugs and Crime (UNODC) in cooperation with PricewaterhouseCoopers Austria – ‘Anti-corruption policies & measures of the Fortune Global 500’ report, available at: http://www.unodc.org/unodc/en/corruption/publications.html


• An employee should not accept gifts or personal benefits in connection with a business relationship as a result of which he or she might appear to be under an obligation.

• An employee may not sponsor or participate in business entertainment or work-related events that could reasonably result in an actual or apparent conflict of interest or that could embarrass you or the firm. The cost and nature of business entertainment must be reasonable and consistent with the client relationship and the firm’s policies.

Recommendation 4

All government bodies should have an informed and conservative approach when making decisions about sponsored and financially supported events. The approach used should ensure:

a. there is a defensible public purpose and justifiable alignment between a sponsored or financially supported event and the government body’s core business

b. board members or employees who attend ticketed sponsored or financially supported events do so for a valid and defensible ‘business’ reason, which should be recorded

c. ‘private use’ is eliminated or significantly scrutinised and reduced

d. decisions on the use of tickets stand up to public scrutiny.

3.2 Governance and transparency of event arrangements

Sixteen government bodies10 reported on the following subjects about their views, internal information used, and any action taken to improve the management of sponsored and financially supported events:

1. Maturity of their policies and systems in regard to the acquisition and provisions of tickets.

2. Any policies, procedures, guidelines and/or checklists which are in place to assist employees to make and record decisions about the acquisition and use of general admission tickets, VIP or corporate box access.

3. Reviews and/or practice improvements initiated for sponsorship activities since the Healthway report was tabled.

3.2.1 Maturity of policies and systems

Following the Healthway investigation, the Public Sector Commissioner wrote to all public sector agencies on 26 February 2015 and attached the Integrity controls checklist. The purpose of this communication was to ask CEOs to ‘reflect on the contracting, sponsorship and grants arrangements’ and use the checklist to ‘check for reviewing existing approaches, identifying possible gaps and in providing assurance to your Board or Minister’.

10 Gold Corporation did not submit its policy or procedure for review as it advised the PSC that from 3 March 2015 no tickets would be taken up by any employees or officers of Gold Corporation.


To assess what action agencies had taken on addressing the points covered in the Integrity controls checklist, the review:

1. Requested 16 government bodies report on the maturity of their policies and systems ‘around the acquisition and provision of tickets’ for the 12 elements of the checklist, listed under the following 4 headings:

– Public purpose: Be able to confidently relate the requirements for tickets to a defensible public purpose.

– Conservative approach: Take a conservative approach to minimise the risk that the use of tickets will be seen as providing a private benefit for officers involved.

– Record decisions: Record decisions and transactional information about arrangements to ensure open and transparent processes with the organisation and externally.

– Authorisations and controls: Ensure that appropriate authorisations and controls are in place.

2. Assessed the policy documents provided to the review on request from 8 of the 16 government bodies, to determine if they had suitable policies to assist employees to make and record decisions about the use of tickets.


Survey results – Maturity of policies and systems against the Integrity controls checklist – 16 government bodies

The options for rating the maturity of policies and systems against each element of the Integrity controls checklist were ‘recognised’, ‘defined’ and ‘integrated’, defined as follows:

• Recognised – Recognition of the importance of effective governance in this area, some measures have been taken, but the government body’s approach is not yet fully coordinated.

• Defined – Centrally defined policies and processes are in place, there is general staff awareness but there is little monitoring or review of systems. E.g. policy and procedures are not up to date and recordkeeping is not current.

• Integrated – Staff confidence in systems is high, there is regular monitoring to refine policies and processes and any measures taken are reported to corporate executive.

Figure 9 Summary of a self reported assessment by the sample of 16 government bodies on the maturity of their policies and systems in regard to each element of the Integrity controls checklist

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Discussion

It is pleasing the results reported indicate:

• that generally for the checklist criteria, there is a relatively high level of reported ‘integration’ across policies and systems for all the Integrity controls checklist elements (Figure 9)

• the government bodies involved in the higher volume use of tickets category, have generally reported a high level of ‘integration’ across policies and systems for all the Integrity controls checklist elements (Figure 10).

Notwithstanding the positive results reported, 12 government bodies require further action to improve aspects of their policies and systems from recognised/defined into the integrated category.

3.2.2 Assessment of policies, procedures and guidelines

Sixteen government bodies reported various policy and process documents they use to assist their employees to make and record decisions for the management of sponsored or financially supported events. Examples of these include the following from 8 of the bodies.

Figure 11 Examples of agency policies and process documents reported as used to assist their employees to make and record decisions for the management of sponsored or financially supported events

Government body Policy, procedures and other documents reported

Lotterywest Engagement Policy and Invitation Register

Tourism WA Event Sponsorship Framework and Corporate Hospitality Process

Fremantle Port Authority Sponsorship and donations policy and procedures

Western Power Sponsorship Management Standard

Synergy Synergy management plan. Energy Markets’ Market Strategy and Business Plan. Strategy and Corporate affairs VIP register

Racing and Wagering WA Hospitality and Corporate Sponsorship policy

Metropolitan Redevelopment Authority

MRA Place Management Policy - SponsorshipMRA Sponsorship Register


Gifts and Hospitality and Attendance at Events Policies. Electronic approval workflow for gifts, hospitality or attendance at events


3.2.2 (a) Policies – Assessed against the Integrity controls checklist

The PSC assessed the policy documents provided to the review from the 8 listed government bodies (Figure 11), considered as in the high end of ticket/event or ticket use reported to Parliament, to determine if they had suitable policies to assist employees to make and record decisions about the use of tickets.

The assessment involved:

1. a PSC assessment, using a ‘fully met’, ‘partially met’ or ‘not met’ rating, to determine the extent to which the agency policy documents were considered to cover the elements of the Integrity controls checklist (Figure 12), and

2. a comparison of the observations from (1), to the government bodies’ self-reported maturity rating of policy documents (Figure 13).


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Discussion

With proper and clear reference points, board members and employees are more likely to make better informed and correct decisions about sponsored or financially supported events and the use of tickets.

Relevant to this review, the Office of the Auditor General (WA) Audit Results Report – Annual 2013-14 Financial Audits stated:

Issues we found mostly related to the need to record the attendees/recipients of the hospitality and to document the purpose of the hospitality so as to provide transparency and accountability for the expenditure.

It is encouraging that all 16 government bodies reported having policies, procedures, guidelines and/or checklists which are in place to assist employees to make and record decisions about the acquisition and use of general admission tickets, VIP or corporate box access. Notwithstanding this, some of the documents reported by the agencies were considered general by nature and lacking relevance to the subjects of sponsored or financially supported events and ticket use.

The assessment of policies and guidance documents from 8 government bodies, against the Integrity controls checklist, indicated some of these documents covered aspects of the checklist adequately. However, as indicated in Figure 12, it was concluded that all of the government bodies assessed require, to some degree, additional work to further improve their policy and guidance documents to address important accountability and integrity requirements such as those detailed in the Integrity controls checklist. Some of these include:

• the evaluation of ticket use

• being mindful of public perception about the class of ticket used

• registering details of ticket usage

• having separate decision making associated with the negotiation of any tickets from the receipt and allocation of any tickets

• importantly, conducting periodic audits of event arrangements against the elements of the Integrity controls checklist.

All of the points covered in the Integrity controls checklist are considered integral to the effective management of event arrangements. In particular, from a governance, accountability, and transparency perspective, recording details in a register about each event and any attendance, and the periodic audit of event arrangements, are seen as critical. On these points, it is important that information about ticket use is recorded by government bodies to ensure open and transparent processes are maintained. Strong recordkeeping also assists government bodies to effectively conduct periodic reviews of their ticket use in relation to sponsored and financially supported events.


Periodic audits

Nine of the 16 government bodies surveyed (Figure 9), and 5 of the 8 agencies which self-reported on the maturity of their policies (Figure 13), did not consider the periodic audit of sponsored or financially supported event arrangements as an ‘integrated’ element in their policy and guideline documents. The PSC’s own assessment of the 8 agency policies identified 4 (Figure 12) as not considered to have the periodic audit of sponsored or financially supported event arrangements integrated in their policy and guideline documents.

Recording details about event arrangements

The eighth element of the Integrity controls checklist indicates that government bodies should 'Register the nature, number, allocation and utilisation of all tickets, hospitality and other similar resources used (and not used) by the organisation'. In regards to this element of the checklist, the review observed:

• Of the 16 government bodies surveyed, 3 reported this element as 'recognised', 2 as 'defined' and 11 as 'integrated' (Figure 9).

• Of the smaller sample of 8 government bodies' policies and procedures assessed by the PSC against the Integrity controls checklist (Figure 12):

– 2 did not have registers relating to ticket use and therefore we assessed that they did not meet the eighth element. One of those is currently developing a sponsorship register.

– The other 6 bodies provided us with copies of their registers. We assessed that of these, 2 'fully met' the requirements of the eighth element.

– The remaining 4 bodies 'partially met' the eighth element, and we made recommendations about how their registers could be improved.

The PSC suggests that all government bodies should maintain a register in relation to ticket use for sponsored or financially supported events, including the following fields:

• name and date of the event

• name of the organisation or person offering the tickets and their relationship to the officer or the government body

• reason for the offer

• number and value of the tickets, and the nature of the tickets (i.e. whether they are general admission or VIP)

• name and position of employees of the government body or other persons using the tickets (or whether the tickets were unused)

• reason for attendance (i.e. what is the alignment of the attendance to business purpose, e.g. speech or presentation, collaboration with key business partners etc)

• whether approval of a senior officer has been given for the use of the tickets (including identity of the senior officer).

It was also noted that of the 8 agencies reporting sponsorship activity, 6 of their policies made no reference to the SSC Sponsorship guidelines.


3.2.2 (b) Policy review

Clear and current policies should assist employees to make informed and appropriate decisions when they are involved in sponsored or financially supported events, which may include tickets.

Survey results – When were policies reviewed

Sixteen agencies reported that they use a total of 64 various policy and guidance documents to assist their employees to make and record decisions for the management of sponsored or financially supported events. Of the 64 documents, 77% were reported as being reviewed less than 1 year ago.

Figure 14 When were policies and procedures last reviewed

49

7 7

10

10

20

30

40

50

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<1 year 1 to 2 years 2 to 3 years >3 years

Number of documents

Period since last reviewed

When were policies and procedures last reviewed

Discussion

It is important that government bodies ensure their policy and guidance documents are current and relevant, and it is pleasing to see the review’s sample of government bodies reported they had recently reviewed many policy, procedure, and guidance type documents, the majority within the last 12 months.


Recommendation 5

All government bodies which are involved in sponsored or financially supported events should, at a minimum, ensure that:

a. They integrate all of the elements of the Integrity controls checklist into their policies, systems, and guidance documents around the acquisition and provision of tickets.

b. A register is maintained in relation to ticket use for sponsorships or financially supported events, which includes at a minimum the following fields:

• name and date of the event

• name of the organisation or person offering the tickets and their relationship to the officer or the government body

• reason for the offer

• number and value of the tickets, and the nature of the tickets (i.e. whether they are general admission or VIP)

• name and position of employees of the government body or other persons using the tickets (or whether the tickets were unused)

• reason for attendance (i.e. what is the alignment of the attendance to business purpose, e.g. speech or presentation, collaboration with key business partners etc)

• whether approval of a senior officer has been given for the use of the tickets (including identity of the senior officer).

c. Periodic audits of the arrangements in place are undertaken against the Integrity controls checklist.

d. Where relevant, policy and guidance documents take into account and include reference to the requirements of the SSC Sponsorship guidelines.


3.2.3 Review and/or practice improvements of sponsorship activities

Fifteen11 of the sample of 17 government bodies reported they had initiated a review and/or practice improvements of their sponsorship activities in regard to general admission tickets, VIP and corporate box access since the Healthway report was tabled. These actions included the following examples (refer to Appendix G for the full list):

Government body

Examples of review and/or practice improvements reported for sponsorship activities

Lotterywest Reviewed its Engagement Policy and Grant Communications Plans approach to ensure alignment to business benefit if general admission tickets are provided, and also reviewed and centralised its Invitation Register.

Tourism WA The Board initiated an ‘Evaluation of Tourism WA’s Use and Management of Corporate Hospitality’ in February 2015, which made recommendations for improvement approved by the Board in July 2015.

Western Power

Western Power is currently reviewing its Sponsorship Management Standard. The recommendations contained within the Healthway report will be considered as part of the review.

Synergy Synergy did not provide any information about a review and/or practice improvements reported for sponsorship activities. In response to this question, Synergy advised the review that ‘it must comply with its enabling legislation, as well as other relevant state and Commonwealth laws, however, it is exempt from the Financial Management Act 2006. Synergy is not an agent of the state, nor is it a public sector organisation under Schedule 1 of the Public Sector Management Act 1994’.

Department of Culture and the Arts (DCA)

Post the Healthway report, DCA introduced an Attendance at Events policy and electronic workflow under which Director General approval is required to be gained before events are attended, after meeting certain criteria and only where there are justified business reasons and benefits for attending the event. Guidelines are being developed to support this policy. As a result of separating out the Attendance at Events, the Gifts and Hospitality policy is also being reviewed.

VenuesWest VenuesWest conducted an internal review of its Corporate Hospitality and Ticket Allocation policies and practices and submitted this to the PSC, which subsequently conducted a peer review of the organisation's review and policies, procedures and practices. The revised documentation articulates the priorities for ticket allocation and ensures a conservative and sensitive approach to the management of tickets and an emphasis on the use of such inventory for public benefit at all times. The Sponsorships and Donations Policy is due for review this year and work is underway but not yet complete.

Water Corporation

The Water Corporation's Partnership Process and policy has been reviewed internally by Management Review and Audit (March 2015), and peer-reviewed by the PSC (May 2015).

11 Synergy provided no indication of any review or practice improvement and Gold Corporation no longer accepts tickets to events.


Discussion

The review recognises that GTE and public sector agencies operate in different environments – with GTE being profit driven and operating in a competitive environment – and therefore the assessment of circumstances around sponsored and financially supported sporting and cultural events for each type of government body is different.

It is pleasing to see from the information provided to the review that since the Healthway report was tabled, a significant number of government bodies have taken action, including detailed reviews and evaluations, to improve processes for managing events and tickets. Importantly, this includes Tourism WA, Lotterywest, VenuesWest, the Department of Culture and the Arts and the Water Corporation which have a high level of involvement in this area.

While the PSC recognises the different environment that GTE operate in, it is also noted that GTE are government owned bodies which report and are responsible to a Minister, and are also subject to public scrutiny and comment about the appropriate and ethical use of public resources. At a minimum, it is suggested all government bodies, including GTE, should ensure their policies, procedures and processes reflect and address the requirements of the Integrity controls checklist.

Recommendation 6

Government bodies which have commenced or completed reviews of event arrangements and ticket policies, procedures and processes etc, should if not already done, ensure any recommendations from these are adopted and implemented.

Recommendation 7

Government bodies which are yet to assess their event arrangement policies, procedures and processes against the Integrity controls checklist requirements, should ensure this occurs.

Appendixes Ticket use for sponsored or financially supported events46

Appendixes

Appendix A – Review definitions

Term Definition

Agency Used interchangeably with the term ‘government bodies’.

Arrangement(s)

Covers all the types of events the government body was involved in which were categorised as either sponsorship (incoming), sponsorship (outgoing), financial support, other formal arrangements or ad hoc.

Awards and conferences

In the responses to the second parliamentary question, agencies included the type or name of events. On the information provided, events which were awards or conferences i.e. considered closely aligned with an agency’s core business were separated from those which were sporting, cultural or other events.

Event(s)Categorised as either sponsorship (incoming), sponsorship (outgoing), financial support, other formal arrangements or ad hoc.

Financially supported or financial support

Financial support provided or received by the agency, e.g. through grants or contractual arrangements.

First parliamentary question

Set out in Appendix B.

Government bodies (also referred to as ‘agencies’ in the report)

For the purposes of the review, ‘government bodies’ is defined to mean:• ‘agencies’ and ‘non-SES organisations’ under the Public

Sector Management Act 1994, and• Schedule 1 entities which are statutory authorities

(includes Government Trading Enterprises such as Gold Corporation, the Water Corporation and Western Power) and which were identified in the answers to the parliamentary questions as having significant activities in the sponsorship space.

47Ticket use for sponsored or financially supported events Appendixes

Term Definition

Government Trading Enterprises (GTE)

GTE are public non-financial and financial corporations that have commercial objectives (often alongside other policy objectives). Most of these entities are required by their enabling legislation to produce Strategic Development Plans and Statements of Corporate Intent, or similar accountability documents for the approval of Government. (Department of Treasury, Strategic Asset Management Framework).

Healthway report

Acquisition and use of hospitality resources by Healthway – Investigation report, tabled in Parliament on 19 February 2015 and available at: https://publicsector.wa.gov.au/document/acquisition-and-use-hospitality-resources-healthway-%E2%80%93-investigation-report

Second parliamentary question

Set out in Appendix B.

TicketsGeneral admission tickets and VIP or corporate box access to sponsored or financially supported events.

48 Appendixes Ticket use for sponsored or financially supported events

Appendix B – Parliamentary questions

126 government bodies submitted information in response to the following parliamentary questions.

First parliamentary question

For each department, agency, Commission or Government Trading Enterprise within the Minister’s portfolio of responsibilities:

a. does the organisation hold a contract, sponsorship or any other financial arrangement with any outside body which specifies the provision of hospitality, VIP or corporate box access or general admission tickets to an event as part of that contract, sponsorship or financial arrangement; and

b. if yes to (a), what is the name of the outside body for which the provision of hospitality, VIP or corporate box access or general admission tickets to an events [sic] is part of any contract, sponsorship or any other financial arrangement?

Second parliamentary question

For each department, agency, Commission or Government Trading Enterprise within the Minister’s portfolio of responsibilities for the financial year 2013-14, and for the period 1 July 2014 to date:

a. did the organisation receive any general admission tickets, VIP access or access to a corporate box for any events sponsored or financially supported by the organisation; and

b. for each event outlined in (a):

(i) how many tickets for general admission were provided;

(ii) what was the date of the event for which general admission tickets were provided;

(iii) what was the nature of the event for which general admission tickets were provided;

(iv) how many tickets for VIP access or corporate box access were provided;

(v) what was the date of the event for which VIP access or corporate box access was provided; and

(vi) what was the nature of the event for which VIP access or corporate box access was provided?


Appendix C – Structure of the WA public sector12

The WA public sector is a composite of a number of different publicly funded bodies, these being:

• departments

• statutory authorities comprised of:

– Schedule 2 SES (Senior Executive Service) organisations

– non-SES organisations

• boards and committees.

Departments

WA Government departments are established under section 35 of the Public Sector Management Act 1994 (PSM Act). Under this section of the Act, the Governor may, on the recommendation of the Public Sector Commissioner:

• establish

• amalgamate

• divide

• abolish, or

• change the titles of departments of State.

Under section 35(4) of the PSM Act, the Minister responsible for administration of the Act may direct the Commissioner as regards the establishment of a department.

The primary roles of departments are to assist the Minister to administer legislation and develop and implement government policies. There are currently approximately 30 departments. The Department of Education and the Department of Health are the largest with approximately 30 000 Full Time Equivalent (FTE) staff, and the next largest are WA Police, the Department of Corrective Services, and the Department of Environment and Conservation.

Statutory authorities

Statutory authorities are government entities which are established by separate Acts of Parliament and they are overseen by boards of management or Commissioners.

There are about 200 statutory authorities in the WA public sector and their functions range from:

• commercial, e.g. Western Power, the Water Corporation and Gold Corporation

• regulatory, e.g. Worksafe, Office of the Information Commissioner, the Corruption and Crime Commission and the Office of Equal Employment Opportunity

12 Public Sector Commission, Machinery of Government Structural Changes Manual.


• marketing, e.g. the Potato Marketing Board

• educational, e.g. the universities and TAFE colleges

• administrative, e.g. the Mid-West Development Commission.

There are some statutory authorities which are also constituted in other ways. For example, the Disability Services Commission is simultaneously a statutory authority and a department. The Public Sector Commission (PSC) is established by statute and constituted as a department. In some cases a department is established to support a particular statutory office holder, such as the Director of Public Prosecutions, Auditor General, and Commissioner of Police.

The PSM Act categorises statutory authorities in one of three ways:

1. statutory authorities listed under Schedule 1 of the Act, which are not subject to the Act (e.g. Government Trading Enterprises such as Western Power) and are not included in the public sector as defined in the Act. The PSM Act is least applicable to Schedule 1 entities and PSC has minimal involvement with them from the machinery of government perspective because they are operationally independent of the Public Sector Commissioner

2. SES organisations – statutory authorities listed under Schedule 2 of the PSM Act. SES organisations are subject to the Act (e.g. Small Business Development Corporation), have Chief Executive Officers (CEOs) employed by the Public Sector Commissioner and may also have SES officers appointed under Part 3 of the Act, and

3. non-SES organisations – statutory authorities which are not listed under either Schedule 1 or 2 (e.g. Potato Marketing Corporation). While they are still State Government bodies they are not part of the Public Sector as defined in the PSM Act; however, they are subject to the Act. The CEO is employed by the board of management rather than by the Public Sector Commissioner and non SES organisations do not have SES members appointed under Part 3 of the Act.

The PSM Act uses the terms department, agency, organisation and non-SES organisation with specific meanings and this report uses these terms as they are used in the Act unless otherwise specified.

Boards and committees

There are approximately 318 boards and committees in the public sector which are created variously by statute, Cabinet, Ministers or departments. The functions of boards and committees are quite varied and can include:

• advisory, e.g. Aged Care Advisory Council

• managerial, e.g. Rottnest Island Authority

• regulatory or registration, e.g. Dental Board of WA, Medical Board of WA and Architects Board of WA.


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Appendix E – Information requested from the 17 government bodies

The additional information provided by the 17 government bodies addressed the following areas:

• Types of arrangements reported – whether the events reported to Parliament were sponsored or financially supported by the government body, arranged pursuant to other formal arrangements, or of an ad hoc nature.

• Term of arrangements – the length of time the arrangements were in place, and when the arrangements were last reviewed.

• To what extent the events align with the government body’s core business.

• How the tickets were used – categorising the use of the tickets for each event into a percentage proportion of unknown, unused, private, external stakeholders or business use.

• Whether approval from the accountable authority for the arrangements was obtained – including approval by the government body’s Minister, where relevant, and approval by the CEO or delegate officer.

• Approach or rationale employed when deciding the volume of tickets to be accepted, and when deciding to accept VIP or corporate box access.

• Whether any tickets were allocated to or used by family members, friends or acquaintances of board members or staff that were outside circumstances where social protocol would dictate that an invitation may extend to the partner of a Chair, board member or senior staff member; and if so, what policy, procedure or guidance assists the government body to make such decisions.

• Legislation, policies, procedures and guidelines which are used to assist employees to make and record decisions about acquisition and use of tickets, VIP or corporate box access.

• Reviews and/or practice improvements initiated since the tabling of the Healthway report.

• A self-assessment of the maturity of governance and transparency around sponsorship activities based upon the 12 elements of the Integrity controls checklist.


Appendix F – Reasons for attendance at events

The following reasons were provided by government bodies in either communication with the PSC or within their policies about why they attend events either sponsored or financially supported by them.


• Senior Officers may attend significant events to represent the Department or the Government.

• DCA is invited to most events staged by organisations or individuals that receive funding. Generally the project officer (or a delegate) attend the event to ensure compliance with Grant agreement. Senior Officers may attend significant events to represent the Department or the Government.

• Arts organisations invite and expect senior officers from the Department to attend events to represent the Department or Government. DCA selectively accepts these invitations depending on the event.

Fremantle Ports Authority

Its sponsorship program is aimed at:

• contributing to local communities.

• creating opportunities for customer relationship building.

• growing our reputation as a good corporate citizen.

The Sponsorships and Donations policy dated 18 June 2015 states sponsorship benefits are:

• Helps to build positive relationships with stakeholders and customers

• Enhances Fremantle Ports’ reputation as a good corporate citizen

• Increases awareness, understanding and support for Fremantle Ports

• Creates opportunities for communication and interaction

• Facilitates targeted promotion.

WA Museum

• A small number of free tickets to these events may be requested so the Museum can assess the success of the activities organised on Museum grounds.

• Building of stakeholder and partnership relationships.


Lotterywest – grants

The Lotterywest Engagement Policy states:

All Lotterywest Board and staff accepting invitations from stakeholders must define a business benefit for accepting the invitation and accept the invitation in accordance with the invitation management process coordinated and recorded by Information Services.

The policy also states that it identifies:

• appropriate opportunities to engage our stakeholders, both external and internal (Board and staff), to build an understanding of the Lotterywest business

• acknowledge the contribution of others in the WA community

• engagement aims to support Lotterywest’s vision of ‘building a better Western Australia together’

• present activities that enable interaction with invited stakeholders

• accept invitations that provide an opportunity to build relationships with stakeholders

• utilise opportunities from organisations we support to align to the Lotterywest Brand Strategy and our marketing and communication strategies.

As an example the Lotterywest Event Brief – WASO The Music of James Bond states the following under ‘Purpose’:

• Relationship building and networking opportunity for Lotterywest retailers, grant groups, Board, staff and other stakeholders.

• Reinforce Lotterywest’s support for WA’s cultural sector.

• Lotterywest acceptances to VIP access is limited to a representative from the Board and/or Executive to maintain a positive stakeholder relationship with the organisation, often a Lotterywest Grant Recipient.

• Lotterywest is often requested to address guests or present awards at such events as a community supporter.

• Host guests during the pre-show function and interval hospitality.

Perth Theatre Trust

Reasons provided for one event included:

• An opportunity for the Board to meet with our stakeholders - past and present.

• Allowed for the Chair and General Manager to make speeches and discuss the new management modelling.

• The first programmed event under the new management model allowed the Board to assess how well the new Food and Beverage contractor was working, what their offering to clients was, and how they coped with an evening when large demands would be placed on them.


ScreenWest

Decision making regarding the quantum of contra items within an agreement is based on:

• Level of contract governance required Viewing screen content and attending events/conferences/workshops enables ScreenWest to evaluate the work of the organisations/practitioners it funds.

• The benefit to the agency It is important that ScreenWest Board and staff maintain up to date knowledge of screen industry content, trends, information and networks.

• The benefit to the screen industry For a number of key events there is additional benefit to the event or activity due to the involvement of ScreenWest staff and Board. The best examples are Revelation and Cinefest film festivals, where the event holders have worked collaboratively with ScreenWest to further the direct industry benefits, and ScreenWest has held workshops, networking events and meetings that directly assist the events and also the industry.

VenuesWest

• Key part of our business to leverage our own corporate hospitality resources to generate business to deliver commercial revenue and engage stakeholders.

• Board members and staff attend to represent VenuesWest, as part of this strategy.

• This strategy has proven to be successful with growth in commercial revenues enabling the subsidisation of community activities, elite sports, and enabling substantial reinvestment back into the State's facilities within our portfolio.

Synergy

• Expenditure on corporate hospitality is responsible and is focussed on customer engagement.

• Engage with customers to understand their needs.


Appendix G – Agency reviews and practice improvements

Government body

Examples reported of review and/or practice improvements for sponsorship activities

Lotterywest Lotterywest Grants support not-for-profit and local government organisations. Lotterywest has reviewed its Engagement Policy and Grant Communications Plans to ensure alignment to business benefit if general admission tickets are provided. Lotterywest has reviewed and centralised our Invitation Register to ensure we capture all activity across the organisation.

Racing and Wagering WA

When establishing sponsorship agreements a conservative approach should be taken when negotiating tickets and hospitality, with the intent to ensure only customers or stakeholders are the beneficiary. Should a corporate sponsorship be agreed, the contract should contain the dollar value for all tickets and other resources being provided. Where sponsorship is involved host numbers should be limited in accordance with the size of the event and the associated costs of providing hosts. For instance regional based events would involve a smaller number of hosts than larger metropolitan based events.

All customer events will have a target host to guest ratio percentage.

All hosting duties will first be offered to members of the Executive team. Due to availability it may be necessary to offer hosting duties to the leadership group and their staff based on individual suitability and the requirements for the particular event. All offers of hosting opportunities will be approved by the relevant General Manager.

Hosting duties may not be transferred to another person without the agreement of the Customer Relationship Coordinator and the approval of the relevant General Manager. Under no circumstances should any hospitality, or tickets provided as part of a sponsorship arrangement, be transferred to anyone other than a RWWA employee.

Where there is a requirement for one or more RWWA Board members to host a customer event, or be invited as a guest, this will be approved by the Chief Executive Officer.

Fremantle Port Authority

A review of our sponsorship policy and procedures was undertaken to assess compliance with the State Supply Commission Sponsorship in Government Guidelines and the Public Sector Commission’s Tickets and Hospitality - Integrity Controls Checklist. As a result of the review, Fremantle Ports sponsorship procedures were updated to strengthen particular aspects of the procedures relating to the negotiation, receipt and use of tickets consistent with the Integrity Controls Checklist.


Government body


Southern Ports Authority

Southern Ports Authority (SPA) initiated a review after parliamentary questions PQ’s 3761 and 3778 in March 2015. SPA Policy includes: ‘The SPA will not accept gracious favours from the Applicant as a result of the sponsoring.’ ‘Free invitations from the Applicant to attend the event will not be distributed among Staff and the invitations will be returned to the Applicant.’ ‘SPA Staff wanting to attend the event for personal reasons must pay the fee at their own expense as per other guests attending the event.’ ‘SPA Staff wanting to attend the event for professional reasons on behalf of the SPA must apply for approval from their Line Manager and if approved, purchase a ticket using SPA’s procurement guidelines.’

Tourism WA The Tourism WA Board initiated an ‘Evaluation of Tourism WA’s Use and Management of Corporate Hospitality’ in February 2015. The evaluation makes a range of recommendations for improvement approved by the Board in July 2015.

Western Power Western Power is currently reviewing its Sponsorship Management Standard. The recommendations contained within the Healthway report will considered as part of the review.

Synergy Synergy is a WA government trading enterprise established under the Electricity Corporations Act 2005, which specifies its powers, functions and operational restrictions. Synergy must comply with its enabling legislation, as well as other relevant state and Commonwealth laws, however, it is exempt from the Financial Management Act 2006. Synergy is not an agent of the State, nor is it a public sector organisation under Schedule 1 of the Public Sector Management Act 1994.

Perth Theatre Trust

Perth Theatre Trust has been working with the PSC to update the House Seat Policy which defines the use of seats which are allocated to Perth Theatre Trust by right as the venue owner. This has been extended to include seats used for sponsorship. Staff are currently reviewing and updating all gift registers and working with the Board and Staff to create clear policies surrounding support of performances and the use and registration of tickets allocated under these arrangements. New programming and sponsorship guidelines are being drafted to ensure appropriate allocations to PTT in exchange for support.


Government body



The MRA conducted a review of its Sponsorship Program in 2015 to ensure it aligned with, amongst other things, the State Supply Commission’s Sponsorship in Government Guidelines, the Public Sector Commissioner’s Circular 2009-18 and the PSC’s Instructions No. 7 and No. 8. The MRA Board endorsed the strategy to improve MRA’s sponsorship policies and procedures. All documents and agreements related to the Program were reviewed and an internal Sponsorship Committee, Chaired by the Executive Director Place Management, has been established to assess all sponsorship applications. Any acceptance and allocation of tickets as part of a sponsorship arrangement is endorsed by the Executive Director, Place Management to ensure they are being used for a defined business purpose.

ScreenWest An internal review was undertaken by ScreenWest. This included analysing ScreenWest’s Screen Culture Fund and Sponsorship funding contracts for the past 9 years, looking at level of funding provided, contracted benefits, benefits taken up, and reason for accepting the benefits. A new policy titled ‘ScreenWest Board Policy “Contracted Contra” Allocations and the Acceptance Of Benefits Under ScreenWest Agreements and From Third Parties’ was drafted, along with a revised register and new approval processes. The ScreenWest Board endorsed that policy and associated governance processes at the 30 March 2015 Board meeting. This was then implemented and all staff trained in the new policy and procedures.

WA Museum Following the release of the Healthway Report, the Museum reviewed its existing practices. A recommendation to implement PSC Guidelines (Tickets and Hospitality Integrity Controls Checklist) was approved by the Museum’s Executive Risk Management Committee, the Finance and Audit Committee (a sub-committee of the Board of Trustees) and the Board of Trustees. The Guidelines have been communicated to senior managers for implementation. The need for tickets provided under an outgoing sponsorship or other formal arrangement (such as a partnership) to be provided for in a written contract or agreement has been noted.


Government body



Following the release of the Healthways report, DCA introduced an Attendance at Events policy and electronic workflow in which Director General approval is required to be gained before events are attended, after meeting certain criteria and only where there are justified business reasons and benefits for attending the event. Guidelines are being developed to support this policy. As a result of separating out the Attendance at Events, the Gifts and Hospitality policy is also being reviewed.

West Coast Institute of Training

Given that the majority of sponsorship requests involve the attendance at functions and the ability to promote the Institute’s core business, the Institute’s Governance Committee has been tasked with reviewing the internal processes to ensure greater confidence in the decision making process surrounding the undertaking of sponsorship activity. Following this review of the Institute’s internal process/procedures, the Sponsorship guidelines will be revised.

VenuesWest VenuesWest conducted an internal review of its Corporate Hospitality and Ticket Allocation policies and practices. This review was approved by the Board and provided to the Public Sector Commission who subsequently conducted a peer review of the organisation’s review and policies, procedures and practices. The revised suite of documentation clearly articulates the priorities for ticket allocation and ensures that a conservative and sensitive approach to the management of tickets and an emphasis on the use of such inventory for public benefit at all times.

The organisation has also improved its Sponsorships and Donations Tracking of Obligation Procedures, however the Sponsorships and Donations Policy is due for review this year and work is underway but not yet complete.


Government body


Water Corporation

Since the Healthway report was tabled, Water Corporation’s partnership process and policy has been reviewed internally by Management Review and Audit (MR&A) (March 2015), and peer-reviewed by the PSC (May 2015). The recommendations set out in MR&A and PSC Peer reviews have since been implemented and updates to key governance documents have been made to reflect these recommendations, mainly in relation to ticket allocation and corporate hospitality principles, and partnership and sponsorship assessment criteria, ensuring all arrangements represent value-for-money, openness and fairness and business alignment; and have been assessed for risk, probity and conflict of interest. Several documents have been developed to ensure the updated policy is easily and accurately followed and have been submitted to the Board for approval. Those documents are as follows: Updated documents: Partnership and Sponsorship Policy (PCY457), Partnership and Sponsorship Work Flow New documents: Partnership and Sponsorship Evaluation Business Case, Sponsor Observation Report.

LandCorp The Board’s Planning, Development and Communications Committee reviewed LandCorp’s management of Sponsorship Benefits and Corporate Hospitality in March 2015 and made management improvements around recording and reviewing the acceptance of invitations and hospitality, as well as the preparation of an information flyer to provide guidelines for staff which has just been published.


Appendix H – Agency management comments

Government body

Comments received about the report observations and recommendations

Lotterywest Lotterywest supports the range of recommendations offered in this report to ensure transparency and appropriate reporting is in place. As part of the review, we have extensively reviewed our events, ticketing, communication plans approach and engagement programs and will continue to align to PSC recommendations.

Racing and Wagering WA

Racing & Wagering WA had already commenced a review of our policies and procedures relating to Sponsorships earlier this year and since the Healthway report was tabled the organisation has continued to review our existing policy to ensure we meet our compliance requirements and obligations based on the recommendations provided by PSC.

Fremantle Port Authority

Fremantle Ports policy and procedures in relation to Sponsorships already include provisions addressing virtually all of the matters covered in the Recommendations. There are some minor amendments that will further strengthen these that we will progress.

Southern Ports Authority

Southern Ports Authority’s corporate sponsorship policy and procedure meets virtually all the suggested recommendations and our registers have been amended to also meet requirements. SPA will use this report to further clarify our gift and hospitality policy and procedure.

Tourism WA Tourism WA is responsible for promoting Western Australia as a holiday, event and convention destination, and for the promotion of tourism generally.

Sponsorship of events to attract visitors to Western Australia is a key component of the Government’s strategy for tourism in Western Australia. Tourism WA’s Sponsorship of events (and contracted Corporate Hospitality arrangements) is tightly managed, regularly reviewed and takes into account all relevant government and agency policies, guidelines, instructions and delegations.

Use of negotiated corporate hospitality is carefully planned and managed to ensure alignment with Tourism WA’s Stakeholder Engagement Strategy, business outcomes and value for the government. A targeted individual engagement strategy is developed for all major events.

Tourism WA’s Event Sponsorship Framework and Corporate Hospitality Policy, Guidelines and Processes are aligned with all of the recommendations in this report.


Government body


Western Power It was pleasing for Western Power that among the responses outlined in the PSC Review its processes were among the strongest of all Government Agencies. The Review has provided Western Power with an opportunity to strengthen its existing integrity controls regarding sponsored or financially supported events. Western Power is pleased to report that it has reviewed its existing sponsorship standard and approved a revised Community Investment and Partnership Standard (Standard). The revised Standard reaffirms Western Power’s long standing expectation that Board members and staff act in accordance with our code of conduct and corporate values. Importantly, Western Power has taken the position that no tickets or hospitality are to be permitted in any partnership agreement unless approval by the Chief Executive Officer or Executive Manager, Corporate Services has been given. In addition, the new Standard has also enabled Western Power to incorporate the PSC’s ticket and hospitality integrity control checklist into internal procedures.

The revised Standard has been robustly endorsed by the Western Power Executive, and is in the process of being integrated across the organisation. Western Power will continue to monitor compliance and review the Standard at appropriate intervals.

Synergy Synergy supports the Public Sector Commission’s review into sponsored and financially supported events involving tickets and VIP or corporate box use by government bodies and recognises the importance of the ‘confidential draft report – review of ticket and VIP or corporate box use by government bodies’.

Following recommendations made during the compiling of the report, Synergy is in the process of reviewing its sponsorship policy and is implementing a gift register to be maintained company-wide. The gift register will provide integrity controls for monitoring tickets, gifts or hospitality received and ensure they comply with Synergy policy and business objectives.

Synergy continues to exercise caution in its approach to hospitality and VIP or corporate box use, ensuring this use is aligned to business objectives.

Perth Theatre Trust

We accept the outcomes of the review and have been working closely with the PSC to ensure that the relevant PTT policies are appropriate. Where PTT’s policies differ from those of the Department of Culture and the Arts (DCA), PTT will ensure alignment with the Public Sector Commission recommendations.


Government body



The MRA found the review to be beneficial and enabled a refining in its practices and has now updated its Sponsorship policy, procedures and supporting documentation in response to the Commission’s recommendations.

ScreenWest ScreenWest welcomes the Ticket use for sponsored or financially supported events report. The agency will use the findings outlined in the report to review its current policies, practices and corporate governance systems to ensure the proper oversight and financial management of all ongoing sponsored or financially supported arrangements.

WA Museum As noted in the report the WA Museum has conducted its own review and has adopted the use of the PSC Integrity Checklist earlier this year. In addition, the WA Museum has amended its ticket register to include all fields recommended in the draft report and we are in the process of developing a policy on sponsorship. This will cover incoming and outgoing sponsorship. It will also take account of the State Supply Commission’s ‘Sponsorship in government guidelines’ (2014) and other policies and guidelines as recommended by the PSC.


The Department of Culture and the Arts is checking its policies and other documents and will amend those to reflect PSC’s recommendations.

West Coast Institute of Training

West Coast Institute supports and is seeking to implement the recommendations of the report through which improved oversight and transparency will assist to ensure that any sponsoring or financial support for events will stand the test of public scrutiny and that the alignment of the activity to the core purpose of the Institute is clear and justifiable. WCI is in the process of reviewing arrangements, policies and procedures in line with a conservative approach as outlined in the report, building on the work that has been undertaken since the matter was highlighted by the Healthway example.

VenuesWest The report itself was comprehensive and provided a clear overview of the differing agency event, sponsorship and other financial support activities currently being undertaken. The recommendations contained within the report are clear and affirm this organisation’s understanding of the compliance framework and parameters that we work within.


Government body


Water Corporation

The Water Corporation is pleased to note that the Public Sector Commission Ticket use for sponsored or financially supported events report has acknowledged that we have already taken action, including detailed reviews and evaluations, to augment our processes for managing events and tickets since the Healthway – Investigation report was tabled in Parliament on 19 February 2015. We support all the Commission’s recommendations and we have either already implemented them, or will take steps to do so as soon as practicable.

LandCorp In March this year, LandCorp reviewed its approach to the management of sponsorship benefits and corporate hospitality and integrated a number of improvements to relevant policies, procedures and processes. We recognise this is an area which requires ongoing oversight and review to ensure the appropriate sponsored event and ticket arrangements are in place and continue to improve our approach. This week, the Board endorsed two key policy documents, our Code of Conduct and Conflicts of Interest (including Gifts and hospitality) policy, which incorporated your recommendations for improvement.

Gold Corporation

Management note the findings in the report and agree with the thrust of the observations and recommendations contained therein. Notwithstanding that Gold Corporation’s practices were already broadly in line with the report’s recommendations, the Corporation has reviewed its policies and procedures and where necessary has taken the opportunity for further improvement.

Ticket use for sponsored or financially supported events...As a result of the review, the PSC...

Documents

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