APGRA Code of Conduct
The individual and firm members of the Association believe that government relations practitioners must be honest, open and transparent at all times in their dealings with government and clients, and are committed to high standards of integrity in the conduct of their businesses and activities.
This Code of Conduct has been developed by the Association to clearly articulate the professional and ethical framework for the way in which members relate to government in Australia. Members’ primary obligations are to abide by the relevant legislation and government codes in place around Australia. It is intended that this Code will operate alongside those schemes, but in all cases of inconsistency, relevant legislation and government codes will prevail to the extent of that inconsistency.
Membership of the Association is open to any firm or person for whom the making of representations to government in Australia constitutes part of their professional activities, and who is prepared to abide by and implement this Code of Conduct and Membership Rules and continues to comply with them on an ongoing basis.
This Code of Conduct covers the activities of members in their interaction with Australian governments at all levels. Members can include specialist government relations firms and their staff, professional communications firms that also offer government relations support as part of their services, ‘in-house’ and individual government relations practitioners as well as any other professionals who make representations to government.
It is a pre-requisite and condition of membership of the Association that members adopt and abide by this Code of Conduct, and that all practitioners involved in providing government relations services and making representations to government observe the duties and principles set out in the Code. Members will be required to renew their commitment to the Code each year as a condition of membership.
Failure to adopt and abide by this Code of Conduct and Membership Rules will be grounds for declining or cancelling membership of the Association, or other sanctions deemed appropriate and proportionate.
More information about the APGRA can be found at www.apgra.org.au.
Definitions
“Consulting Practitioner” means a Government Relations Practitioner who is engaged as a third party to Make Representations on behalf of an individual, a company or an organisation.
“Client” an individual, association, organisation or business who:
A: Has engaged the Practitioner, or the organisation for whom the Practitioner works, on a professional basis to Make Representations to an Government Representative; or
B. in relation to an ‘in-house’ Practitioner, means the Practitioner’s employer.
“Executive Role” is any leadership, office-bearer, fundraising or decision making role in a registered political party or associated entity but does not include ordinary membership of a political party.
“Government Institutions” includes Parliament, local government, the ministry, the bureaucracy, and government owned trading organisations.
“Government Relations Practitioner” or “Practitioner” “Practitioner” is an individual who may be a person, body corporate, unincorporated association, or partnership who Makes Representations.
“Government Relations Practitioner” or “Practitioner” “Practitioner” is an individual who may be a person, body corporate, unincorporated association, or partnership who Makes Representations.
“Government Representative” means a Government Institution or a person elected to be a member of a Government Institution such as a Member of Parliament or local councillor as well as their staff, such as Ministerial staff, staff employed by a Member of Parliament, staff employed by a local or shire council, or staff employed in the public sector.
“Lobbying Rules” means rules established by legislation or a Government Institution to regulate lobbying or government relations practitioners or their activities. For an up to date list, see the Association’s website.
“Making Representations” includes substantive contact with a Government Representative for the purpose of influencing government decision-making including making or changing legislation, developing or amending policy or programs, the awarding of a tender, a grant or allocation of funding, and meeting or other requests, but does not include non-substantive matters such as requests for publicly available information or modifying logistical arrangements for a meeting.
“Management Committee” means the Management Committee of the Association or their designate.
Operation of this Code
- This Code applies in respect of all circumstances in which a Government Relations Practitioner is Making Representations on behalf of a Client.
- Any breach of this Code of Conduct will be dealt with in accordance with the Membership Rules and it is an obligation of membership that each member (and their relevant staff) is bound by those Rules.
- This Code commences on 1 July 2014.
Professionalism
- Practitioners will act with honesty and decency at all times towards Government Representatives.
- Practitioners will not act in a manner detrimental to the reputation of the Association or the professional practice of government relations in general.
- Practitioners will not engage in any conduct that is corrupt, dishonest or illegal.
- Practitioners will use reasonable endeavours to satisfy themselves of the truth or accuracy of all statements made or information provided to Government Representatives and will exercise proper care to avoid giving false or misleading information.
- Practitioners will diligently advance and advocate their Client’s interest.
- Practitioners will devote time, attention, and resources to the Client’s interests that are commensurate with Client expectations, agreements, and compensation.
Interactions with Government
- When interacting with Government Representatives, Practitioners will disclose on whose behalf they are acting, and will not misrepresent their interests.
- Where the proposed or actual activities of a Client may be illegal, unethical or otherwise contrary to a Lobbying Rule or this Code, Practitioners will advise the Client accordingly and refuse to act in relation to the relevant activity.
- Practitioners will not make misleading, exaggerated or extravagant claims regarding, or misrepresent, the nature or extent of their access to, or relationship with, Government Representatives, political parties, or members of political parties. This clause extends to claims of ‘guaranteed’ access to, or outcomes from, particular Government Representatives.
- Practitioners will not offer or give, or cause a Client to offer or give, any financial or other incentive to any Government Representative that could be construed as a bribe or inducement.
Personal Political Activity
- Practitioners will keep strictly separate their professional activities and any personal activity or involvement on behalf, or as a member, of a political party.
- Practitioners will not serve in an Executive Role with a political party.
- Practitioners will not play a senior management role in the conduct of an election campaign.
Employment of Government Representatives
- Practitioners will keep strictly separate their professional activities and any personal activity or involvement on behalf, or as a member, of a political party.
- Practitioners will not serve in an Executive Role with a political party.
- Practitioners will not play a senior management role in the conduct of an election campaign.
Compliance with Laws, Regulations and Rules
- Practitioners will comply with any relevant Lobbying Rules and with this Code. Where any conflict exists between this Code and a Lobbying Rule, Practitioners must abide by the Lobbying Rule.
- Practitioners will comply with any legislation, government resolution or rule relating to donations to political parties and any other matter.
- Practitioners will conduct themselves in accordance with the rules of parliament or any other Institution of Government while within their precincts (including rules relating to any access pass that might have been issued to them).
- Practitioners will abide by the rules for obtaining, distribution and release of parliamentary and governmental documents.
- Practitioners will not obtain information from Government Representatives by improper or unlawful means.
- Practitioners will not cause a Government Representative to breach any law, regulation or rule applicable to them.
Obligations Only Applying to Consulting Practitioners
- Consulting Practitioners will have a written agreement with their Client regarding the terms and conditions for their services, including the amount of and basis for compensation.
- The fees charged by a Consulting Practitioner will be reasonable, taking into account the facts and circumstances of the engagement.
- Upon termination of their relationship, Consulting Practitioners will take steps to the extent reasonably practicable to protect a Client’s interests, such as giving reasonable notice to the Client, allowing time for employment of another Practitioner, and surrendering papers and property to which the Client is entitled.
- Consulting Practitioners will indicate to their Clients their membership of the Association, and the existence of obligations under this Code and the Lobbying Rules.
- Consulting Practitioners will indicate to their Clients their membership of the Association, and the existence of obligations under this Code and the Lobbying Rules.
- Consulting Practitioners will indicate to their Clients their membership of the Association, and the existence of obligations under this Code and the Lobbying Rules.
