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Presentation in the "Leading with a Vision" Workshop

30 March 2000


Launching of the Integrity Programme in the Customs and Excise Department

Mr Eldon, Ladies and Gentlemen,

I am pleased to have the opportunity to share with you my experience in the launching of the Integrity Programme in the Customs and Excise Department.

Customs was among the first batch of departments to participate in the development of an integrated departmental plan under the overall Civil Service Integrity Programme which is jointly organised by the Civil Service Bureau and the Independent Commission Against Corruption. In taking the exercise forward, my primary aim was to devise a plan which would ensure that the ownership of the package of principles that were identified and collated in the process would be readily taken up by the five thousand strong in my Department.

In designing the strategy, I paid particular attention to the lessons learned from the implementation of the first written code of conduct which was cast in stone without any consultation and brought down some mountain in the Middle East a couple of millenniums ago by a bearded man in robes who subsequently introduced the tablets for the first time by throwing them at his people. I think you know the rest of the story.

To avoid committing the same mistakes, we adopted an approach which is best described by the acronym OPEN, with each one of the four letters representing an essential element in our process of implementation. We have O standing for Ownership; P for Participation; E for Effective Communication; and N for Nurturing Environment.

The first element of the OPEN process involves the instilling of ownership of the Programme in the minds of all the staff. Their whole-hearted ownership of the programme is of paramount importance in the spreading of the integrity message to everyone in the organisation. As in the implementation of any successful programme, we must seek to achieve unity of spirit in believing that such a programme would be beneficial ultimately to the operation of the Department now and in future.

Senior staff members were engaged right from the start back in July 1999 in the initial presentation on the Departmental Integrity Programme by representatives of the Civil Service Bureau and the Independent Commission Against Corruption. Together we agreed on the need to strengthen departmental procedures and guidelines which were unique to our operation to help our staff to avoid potential conflict of interest situations and to uphold the highest standard of conduct and discipline in our work. This message cascaded through the organization with general acceptance.

We then picked up on the second element of the OPEN process by encouraging staff participation in the development of the Code. We engaged initially senior staff members in the exercise, and in turn, they were encouraged to ask their subordinates to put their heads together in suggesting living examples to fill in those guidelines which touched on, among others, -

(a)    acceptance of advantages and entertainment;

(b)    proper use of official position or proprietary information;

(c)    handling of conflict of interest situations; and

(d)    handling of investment and outside work.

On collation of all these examples, we produced the first draft. To ensure maximum participation so that all staff members were fully convinced of the acceptability and usefulness of the Code before its promulgation, we circulated the first draft to all Heads of Major Formations for consultation with their own staff. Discussions were then arranged to iron out differences in healthy debates on the yardsticks and standards to be adopted. This part of the process took up a great deal of time and energy, but it was absolutely essential in enhancing staff ownership and in gauging the proper level of standard.

I would like to share with you an example of how staff participation can lead to a happy compromise on a new reporting arrangement which could, otherwise, appear over-zealous. This concerns the acceptance of invitations to meals or entertainment from persons with whom we have official dealings. We reckoned that the excessive acceptance of such invitations could put an officer in an obligatory position. To avoid this from happening and at the same time balancing the need for our staff to make good use of particular invitations for liaison, information gathering and public relations purposes, we agreed to institute a monitoring system to encourage thorough consideration of these invitations by those concerned.

We started off with the stringent requirement for staff to apply for the acceptance of any invitation long before the event. There were adverse comments from the staff on the arrangement citing issues of logistics and trust. In response, we suggested a more relaxed option of serving only verbal notifications to supervisors. This time a large cross section of the supervisors appeared uneasy because verbal notifications could be too casual and inconsistent. To make things clear, the supervisors might even need to keep for themselves some form of written record. This went back and forth for some time, and in the end, the pendulum rested, and we agreed on the submission of simple written notifications by the officers concerned before or immediately after they had attended the functions.

Active staff participation has also led to the setting of ethical standards unique to the operation of an organisation. This concerns respect for intellectual property rights. In recognition of our responsibility for the protection of intellectual property rights, it was suggested by a staff member that a standard of behaviour should be set in this particular area for our own staff. In view of our law enforcement role, we were of the unanimous view that we should go the extra mile to achieve the highest standard possible by including in the Code the strict prohibition of the use of any unauthorised software, and the caution that staff in breach of the rule would be liable to departmental disciplinary action. The message, when it filtered through the ranks, was very well received. That was not surprising because, after all, the initial suggestion had come from our own staff in the first place.


Staff participation was essential in the development of the Code. Yet in taking on these suggestions, we were mindful of the risk of the swinging pendulum, of over-swaying our standards to the extreme of being unreasonably harsh on our staff. After fine-tuning all the revisions in response to staff feedback, we sent an advance draft of the Code to the Civil Service Bureau and the Independent Commission Against Corruption for their comments, drawing their attention particularly to the guidelines and living examples to ensure that in the
overall service-wide context we had not been unrealistically stringent in setting our own standards. The exchange of views thereafter with ensuing modifications of the Code and further notifications to our staff helped enhance the receptiveness of the ethical values contained in the Code.

The finished version of the Code was issued at the end of 1999, having taken some six months to complete.

Throughout the exercise, we sought to ensure that there was effective communication, the third element in the OPEN approach, with all the staff, and we redoubled our effort in the dissemination stage. We arranged distribution of the Code to every staff member, in either English or Chinese, depending on their preference. My Deputy Commissioner organised a seminar for the senior management to reinforce their ownership of the Departmental Integrity Programme. Once assured of their unrelenting support, we then ventured to launch officially the Integrity Programme to cover every layer of the Department.

We started with the staff associations, and we have six altogether with a wide representation of membership, many of whom have already seen the Code in some form wearing their other hats as staff members. We briefed representatives of all these associations of the contents of the Code, explaining to them the importance of setting clear guidelines with living examples to help them understand the standard of behaviour expected of them. We impressed upon them that their compliance would not only bring credit to the Department and the civil service as a whole, but would also help them to stay away from malpractices at early stages. We also asked them to pass the message through to their members. Their response was absolutely positive.


We then directed all Heads of Major Formations to organise briefing sessions to propagate the message of integrity and the contents of the Code to staff at all levels. At around the same time, a press conference was held by my Deputy to disseminate information concerning the Code, and to demonstrate to our staff and to the public at large our determination to uphold the highest standard of conduct and discipline in our work. A large departmental seminar was also organised to facilitate the exchange of views and to address any point of doubt or controversy.

The Departmental Integrity Programme did not end with the issue of the Code. To sustain our effort in reinforcing the concept of integrity, we proceeded to implement the fourth and final element of the OPEN approach in creating a nurturing environment in the Department to further develop the Code, to continuously educate our staff, and to implement timely and effective systemic controls to meet changing circumstances and up-to-date requirements. This nurturing environment includes -

(a)    periodic updating of the contents of the Code and improvement on its provisions;

(b)    organisation of regular awareness seminars;

(c)    continuous conduct of tailor-made training courses unique to Customs operations; and

(d)    conduct of regular reviews of Customs administrative procedures and systems, in consultation with the Civil Service Bureau and the Independent Commission Against Corruption.

Ladies and gentlemen, this is our story, and to sum up, Customs has taken a top-down approach with the senior staff leading from the front in promoting integrity in our organisation, and we have employed the OPEN process of "Ownership, Participation, Effective Communication and Nurturing Environment" to drive and sustain the integrity message among our staff as well as to strengthen our systemic controls to deter possible abuses and to detect malpractices. I hope you find our experience useful.

Thank you.

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