Improve transparency of conflicts of interest (NZ0035)

Problem Definition

1. What problem does the commitment aim to address?
The public service must identify and manage conflicts of interest well. This is required to uphold confidence in public sector decision-making and impartiality. Poorly managed conflicts of interest can undermine public trust and damage the integrity of public decision-making. Managing conflicts of interest is particularly important for senior public service leaders, like chief executives or board chairs and members, who often make significant decisions about public spending and setting agency direction.

Currently, under the Public Service Commissioner’s model standard on conflicts of interest, chief executives of agencies must declare any conflict of interest to the Public Service Commission and crown entity board members must disclose any interests in accordance with the Crown Entities Act 2004. However, there is no publication of declared interests or management plans. This limits the transparency of how senior leaders’ conflicts of interest are managed and prevents any public scrutiny of these interests.

The lack of centralised data about senior public servant’s interests was noted as an area for improvement at OGP workshops.

2. What are the causes of the problem?
Elaborate on your understanding of the causes of the problem. As much as possible, identify the root causes. Utilize problem analytical tools (e.g., problem tree, five whys, fishbone diagram, or other related methods) when necessary and provide evidence whenever possible.

There is no requirement in legislation or Public Service Commission guidance that senior public servants’ interests must be published. Although this could happen without any requirement in legislation or guidance, it has not occurred to date. This contrasts with government Ministers, whose interests are published by DPMC, in line with Cabinet Manual requirements.

Commitment Description

1. What has been done so far to solve the problem?
What solutions were made available for this problem in previous years? How successful have they been?

In the past year PSC has strengthened conflict of interest management practices by:

• Strengthening and reissuing the conflict of interest model standards.

• Publishing the one-page guide to conflict of interest conversations.

• Developing a set of examples of conflict of interest management plans, to support public servants and their managers to create effective management plans.

These tools support better management of conflicts of interest across the public service for all employees, but have not focused on the interests of senior leaders.

This year PSC also issued the Action Plan to strengthen integrity 2025 – 2028. A stretch goal in the action plan is to “Explore options to increase transparency of chief executive and board chair interests & management plans – 2026/2027 start”. Work has not commenced on this potential stretch goal.

2. What solution are you proposing?
What will you do to solve the problem? How does this differ from previous efforts? In what way will the solution solve the problem? How will the solution solve the problem? Will it solve the problem in its entirety or partially? What portion of the problem will it solve, if not the whole problem?

PSC will undertake work to better understand the problem, scope possible solutions (including privacy implications) and consult stakeholders. The work will be supported by a reference group that includes agency and civil society representatives. Solutions might include the development of a public register of senior leader’s declared interests and/or management plans, or an independent review process, or other ideas that emerge during research.

3. What results do we want to achieve by implementing this commitment?
What outputs would we like to produce? What changes in knowledge, skills, and capacities do we want to achieve? What changes in behavior, systems, and practices do we want to create?

We want to achieve:

• Improved transparency of information about senior public servants’ conflicts of interest.

• Greater public access to information about senior public servants’ conflicts of interest to give greater confidence that interests are declared and managed well.

1 How will the commitment promote transparency?
Depending on the options scoped, it could provide the public with greater access to information about how senior public servants’ interests are managed. This will need to include a privacy assessment.

2. How will the commitment help foster accountability?
Publishing senior public servants’ interests and management plans supports
How will it help public agencies become more accountable to the public? How will it facilitate citizens’ ability to learn how the implementation is progressing? How will it support transparent monitoring and evaluation systems? accountability by better enabling public and Parliamentary scrutiny. It also demonstrates a proactive approach to risk management by showing how a conflict of interest is being managed.

3. How will the commitment improve citizen participation in defining, implementing, and monitoring solutions?
The perspectives of stakeholders, including relevant civil society organisations, will be part of the policy development process.

Milestones | Expected Outputs | Expected Completion Date

(Milestones are part of a series of actions or events that, when executed, will lead to the achievement of the result the commitment would like to achieve.) | (Outputs are concrete, objectively-verifiable results that are direct products of activities conducted or implemented.)

Refine and scope the project: identify a project lead and key contact point for the work within PSC, develop a high-level project plan, identify key agency and civil society stakeholders to engage with, and draf Terms of Reference for a reference group (by invitation). | Project plan and associated documents (PSC) Terms of Reference for reference group to explore options. | June 2026

Establish reference group (by invitation) | Reference group mem

Desk research and interviews on conflict of interest transparency practices for senior public servants and Board chairs, drawing on international comparisons, which could include Australia, the UK, Canada, Scandinavian nations and Singapore. Consider existing guidance including OCED and World Bank guidance. | Summary of research. | September 2026

Working with reference group, develop an options discussion document for wider engagement. | Discussion document published | September 2026

Engage with stakeholders, including CSOs and senior leaders, on options to enhance transparency of senior leaders’ interests. | Summary of engagement. | December 2026

Advice to the Minister for the Public Service on options to improve transparency | June 2027