large pile of paperwork

Ordinarily, corruption, misconduct and maladministration risks emerge because of a lack of policy and procedural guidance. However, the opposite can also be the case.

Circumstances where policy and procedure are too burdensome, overly complex, confusing, contradictory, disorganised and hard to access, also create a corruption risk. In such environments staff respond by simply ignoring, circumventing or disconnecting from the policies and procedures that should guide their work. This problem is known as policy fatigue.

If your agency’s policy and procedural environment is overburdened, inconsistent, or not fit for purpose, you run the risk of your staff suffering from policy fatigue.
One may well lament, “What can we do about this accursed policy fatigue! There must be some type of policy that can help us manage it?”

Well there isn’t; that would be ridiculous.

What is policy fatigue?

Policy fatigue is a condition whereby the number, complexity, coverage, consistency and rate of variation of an agency’s policies, standards, procedures, instructions and processes results in confusion, frustration and reduced levels of compliance by staff.  
Poor policy environments encourage inappropriate or misguided behaviours, and reduce the likelihood of an agency detecting corruption, misconduct and maladministration.

Signs

These are some of the telling signs that your agency may be suffering from policy fatigue:

  • staff developing their own methods and procedures
  • taking shortcuts, bypassing controls
  • staff resorting to asking ‘trusted colleagues’ rather than navigating policy
  • ignoring procedures
  • confusion about job roles
  • disgruntled and/or apathetic staff

Symptoms

Practices that diverge from documented policies and procedures create work environments where corruption, misconduct and maladministration can grow. This is particularly the case if key controls are disregarded, missing or defunct.

Policy fatigue is also contagious. The more that staff disregard policy and procedure, the more they signal to other staff it is acceptable to do so. The more that non-compliance becomes acceptable, the greater risk the agency runs of other inappropriate behaviours becoming tolerated or tacitly approved.

Causes

The ultimate cause of policy fatigue in staff is a poorly constructed and maintained policy environment. This can occur for a number of reasons:

  • Confusion about who is responsible for the policy environment generally, and who has carriage of individual policies
  • Inattention or neglect of policy by management and senior staff
  • Policies that restrict staff and prevent them from using and applying good judgement
  • Lack of communication about the reasons for a policy existing
  • A lack of enforcement of rules, even when they are known by staff
  • The existence of rules and policies that needlessly get in the way of staff productivity
  • Changed / cancelled policies and procedures not being reflected in written policy documents

Managing policy fatigue in the workplace

There are a number of things that agencies can do to manage policy fatigue in the workplace; these include:

Formulating policy

  • Policy and procedure documents should be concise, accurate, relevant and written in plain English
  • Define abbreviations and technical terms
  • Clearly identify to whom the particular policy document applies
  • Ensure policies are consistent with existing legislation and regulations
  • List related policy documents to enable staff members to locate all applicable policies on a particular topic
  • Avoid ‘over engineering’ policy documents that could encourage avoidance
  • Refer to other documents or legislation, but don’t repeat or attach them, as policy documents should be readable as stand-alone documents

Policy in practice

  • Use a records management system to store policy documents and ensure accurate version control
  • Staff should be regularly trained in all policies relevant to their work
  • Clearly identify who is responsible for establishing the policy framework, as well as maintaining, updating, reviewing and approving policy documents
  • Ensure policies are regularly reviewed and updated on a clearly defined basis

This article was published in the ICAC's newsletter - Integrity Matters

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