Everyone benefits from the new focus on integrity within the CBP
AirCargo archive stories issue 233
Tuesday, 18 November 2014
The Australian Customs & Border Protection Service (CBP) has, as is well known, been tackling the inter-related issues of criminal infiltration, corruption and serious misconduct within the agency. It’s a campaign that is bearing fruit, according to CBP chief executive Mike Pezzullo, and some useful lessons have been learned along the way, writes Kelvin King.
Speaking to the Security in Government conference held in Canberra recently, Pezzullo said that CBP’s integrity problem was a global issue and not one limited to Australia.
“In our direct experience, an increasing value is being placed by transnational organised crime groups on border-related law enforcement intelligence and operational information.”
Other problems included the “inherently high exposure to corruption risks” in the work undertaken by border officers in facilitating the movement of cargo and people and the formation within agencies of “sub-cultures of misplaced loyalty”.
He suggested the risk of compromise could well have increased “through the proliferation of social networks which devalue the collective good and the power of the state to ensure this collective good, along with increased tolerance in relation to illicit and anti-social behaviour – including recreational drug use”.
Other border agencies could learn from the CBP’s discoveries during the past two years, Pezzullo believes.
“I cannot stress enough the need for a positive integrity regime that is greater than the elements of rules and regulations that are put in place. It is about creating a strong culture as the fabric that binds the rules and the processes; it means tackling integrity risks before they become a material problem; and truly holding people to account for integrity and professional standards, from the chief executive down.”
Another lesson was that investigators found that criminal conspiracy within the CBP “grew out of a combination of circumstances, including an organisational culture that was frankly naive to key elements of the corruption and infiltration risk environment, notwithstanding the best endeavours of the management team of the day”.
Pezzullo outlined to the conference the actions of CBP, the Australian Federal Police and other investigating bodies – AirCargo AP has covered these in earlier reports. He also stressed yet again that the integrity issues have involved a small minority of staff and that the vast majority were delighted with CBP’s clean-up as well as hugely supportive.
Formation of an integrity and professional standards branch within the integrity, security and assurance division was another step worthy of consideration by border services elsewhere. “This now provides a more integrated approach to managing end-to-end professional contact in our workplaces, from fighting corruption and criminal infiltration, and dealing with misconduct, through to drawing the attention of local management to issues that require early intervention.”
Pezzullo said that ‘by combining protective security with integrity, risk and assurance functions, we have been able to build a stronger security culture through policy and education, which are backed up by technical controls that protect our information holdings regarding traders and travellers, and our partners’ intelligence data.
“Aligning our systems integrity with personal integrity has meant that it is now much more difficult for corrupt officers to use our systems for personal advantage or hide their activities from observation. “It also means we are better protected from information handling accidents.”
Among other lessons learnt, he added, was the need for restrictions on the use of personal mobile and electronic devices in operational workplaces, a strong outside employment policy identifying “high-risk secondary employment situations which could potentially compromise officers or create perceived or actual conflicts of interest,” tightening procedures for reporting misconduct and strengthening protection, a new employment screening model known as organisational screening assessments, and a “declarable associations” policy that requires officers to avoid or at least mitigate integrity risks associated with contact of individuals, groups or activities presenting a conflict of interest to CBP’s mission.
Pezzullo explained too that CBP had developed a set of “core behaviours” to support the process of cultural change. “The values and behaviours constitute a body of norms that bind us and show that, no matter at what level an officer is or which area they work in, there are fundamental cultural settings that bind all officers in the way they approach their work and perform their duties.”
And, he said, “the service is building a culture of transparent decision making which has clear lines of accountability and responsibility within a strong governance framework. This includes revitalising our approach to risk management and generating a better understanding of overall compliance and management oversight needs.
“By critically examining the effectiveness of control frameworks, we are able to generate improvements in efficiency, support resource allocation decisions and feed into the planning processes to allow the executive enhanced visibility over emerging risks.”
Everyone benefits from the new focus on integrity within the CBP
AirCargo archive stories issue 233
Tuesday, 18 November 2014
The Australian Customs & Border Protection Service (CBP) has, as is well known, been tackling the inter-related issues of criminal infiltration, corruption and serious misconduct within the agency. It’s a campaign that is bearing fruit, according to CBP chief executive Mike Pezzullo, and some useful lessons have been learned along the way, writes Kelvin King.
Speaking to the Security in Government conference held in Canberra recently, Pezzullo said that CBP’s integrity problem was a global issue and not one limited to Australia.
“In our direct experience, an increasing value is being placed by transnational organised crime groups on border-related law enforcement intelligence and operational information.”
Other problems included the “inherently high exposure to corruption risks” in the work undertaken by border officers in facilitating the movement of cargo and people and the formation within agencies of “sub-cultures of misplaced loyalty”.
He suggested the risk of compromise could well have increased “through the proliferation of social networks which devalue the collective good and the power of the state to ensure this collective good, along with increased tolerance in relation to illicit and anti-social behaviour – including recreational drug use”.
Other border agencies could learn from the CBP’s discoveries during the past two years, Pezzullo believes.
“I cannot stress enough the need for a positive integrity regime that is greater than the elements of rules and regulations that are put in place. It is about creating a strong culture as the fabric that binds the rules and the processes; it means tackling integrity risks before they become a material problem; and truly holding people to account for integrity and professional standards, from the chief executive down.”
Another lesson was that investigators found that criminal conspiracy within the CBP “grew out of a combination of circumstances, including an organisational culture that was frankly naive to key elements of the corruption and infiltration risk environment, notwithstanding the best endeavours of the management team of the day”.
Pezzullo outlined to the conference the actions of CBP, the Australian Federal Police and other investigating bodies – AirCargo AP has covered these in earlier reports. He also stressed yet again that the integrity issues have involved a small minority of staff and that the vast majority were delighted with CBP’s clean-up as well as hugely supportive.
Formation of an integrity and professional standards branch within the integrity, security and assurance division was another step worthy of consideration by border services elsewhere. “This now provides a more integrated approach to managing end-to-end professional contact in our workplaces, from fighting corruption and criminal infiltration, and dealing with misconduct, through to drawing the attention of local management to issues that require early intervention.”
Pezzullo said that ‘by combining protective security with integrity, risk and assurance functions, we have been able to build a stronger security culture through policy and education, which are backed up by technical controls that protect our information holdings regarding traders and travellers, and our partners’ intelligence data.
“Aligning our systems integrity with personal integrity has meant that it is now much more difficult for corrupt officers to use our systems for personal advantage or hide their activities from observation. “It also means we are better protected from information handling accidents.”
Among other lessons learnt, he added, was the need for restrictions on the use of personal mobile and electronic devices in operational workplaces, a strong outside employment policy identifying “high-risk secondary employment situations which could potentially compromise officers or create perceived or actual conflicts of interest,” tightening procedures for reporting misconduct and strengthening protection, a new employment screening model known as organisational screening assessments, and a “declarable associations” policy that requires officers to avoid or at least mitigate integrity risks associated with contact of individuals, groups or activities presenting a conflict of interest to CBP’s mission.
Pezzullo explained too that CBP had developed a set of “core behaviours” to support the process of cultural change. “The values and behaviours constitute a body of norms that bind us and show that, no matter at what level an officer is or which area they work in, there are fundamental cultural settings that bind all officers in the way they approach their work and perform their duties.”
And, he said, “the service is building a culture of transparent decision making which has clear lines of accountability and responsibility within a strong governance framework. This includes revitalising our approach to risk management and generating a better understanding of overall compliance and management oversight needs.
“By critically examining the effectiveness of control frameworks, we are able to generate improvements in efficiency, support resource allocation decisions and feed into the planning processes to allow the executive enhanced visibility over emerging risks.”
