Corruption Prevention Tips on Kindergartens' Operations
Kindergartens should operate with integrity and avoid risks of corruption and abuse. To help kindergartens strengthen the anti-corruption measures in their daily operations, the Corruption Prevention Advisory Service (CPAS) of the ICAC will publish, in five series, corruption prevention tips on kindergartens’ governance and various operations.
Series No. 1 – Admission of Students
With keen competition for places in the preferred kindergartens, the mechanism for student admission is of prime concern and is easily subject to allegations of conflict of interest, abuse of powers, favouritism to applicants, etc. Here are some scenarios which give rise to risks or allegations of corruption and abuse.
- A teacher having access to the student admission assessment criteria, which are not publicised, leaks such information to his good friend to assist the latter’s son to better prepare for the kindergarten’s admission interview.
- A teacher tasked to be one of the assessors arranges the assessment of his nephew, who has applied for admission to his kindergarten, to be conducted by himself and improperly accords high priority to his nephew in drawing up the priority list of successful applicants.
- A teacher responsible for shortlisting applicants screens in an ineligible applicant to attend the admission assessment.
- The kindergarten’s clerk offers an untaken place to a waitlisted applicant out of turn.
To prevent corruption and abuse, it is of paramount importance for kindergartens to ensure that their student admission processes are open, fair and transparent. Below are some quick tips for admission of students from corruption prevention perspective.
- Lay down in detail the application procedures, assessment mechanism and basis for according admission priority to applicants.
- Remind all personnel involved to declare whether or not they have any relation with any applicant, and if any, to follow the mitigating measures.
- Publicise critical application information such as application procedures, assessment criteria, basis for according admission priority, and date of releasing admission results.
- Inform parents of the kindergarten’s policy on prohibiting its managers/staff from soliciting and accepting advantages and remind them that they should not offer advantages to its managers/staff.
Shortlisting and Assessment
- Ensure that assessors clearly understand the shortlisting and assessment procedures and criteria and comply with them.
- Require assessors to record and sign against their assessment and the admission results in a standard assessment form; and if there is any revision, sign against it for confirmation.
Review and Announcement
- Conduct supervisory review on the admission results to ascertain compliance with the laid down assessment criteria and subject exceptional cases (e.g. admit students on compassionate grounds) to approval by an appropriate authority, with proper justifications and documentation.
- Notify applicants’ parents of the admission results as soon as possible and re-allocate the untaken places to waitlisted applicants according to the priority order.
Series No. 2 – Governance Framework of a Kindergarten
Good governance is pivotal to the effective management of a kindergarten. From the corruption prevention perspective, sound integrity management system (IMS) and internal control system (ICS) are the essentials to build up the foundation to good governance.
Integrity Management System
An effective IMS helps raise the awareness of managers and staff of kindergartens on the anti-bribery legal requirements they are subject to and other integrity requirements. Among various integrity issues, conflict of interest has been increasingly under the spotlight. Here are some scenarios involving conflict of interest which, if improperly managed, may give rise to criticism of favouritism, abuse of authority or even allegations of corruption.
- A newly appointed teacher owns a tutorial centre with many students of the kindergarten attending the classes of her tutorial centre.
- A staff member is responsible for sourcing properties for rental by the kindergarten and he is the landlord of one of the properties.
- In a tender exercise for the kindergarten’s computer system, one of the tenderers is the personal friend of the kindergarten’s technician who is responsible for the assessment of tenders.
- A clerk is responsible for receiving applications in a recruitment exercise for teachers and an applicant is her relative.
To effectively manage any conflict of interest, kindergartens should adopt the following “three-step mechanism”:
- Alert and Avoid: All managers/staff should remain alert to and avoid any actual, potential or perceived conflict of interest situation.
- Declare: If the conflict is unavoidable, the manager/staff should report it to the designated authority e.g. principal.
- Mitigate: The approving authority, after assessing the impact of the conflict and the risk of impropriety, takes appropriate mitigating actions.
To demonstrate the management’s commitment to anti-corruption practices and assist the managers/staff to uphold integrity in daily operations, kindergartens should issue to the managers/staff comprehensive integrity guidelines (e.g. by way of a code of conduct), clearly setting out the standard of behavior expected of them.
Internal Control System
Committed to upholding integrity aside, kindergartens should observe the following guiding principles under each of the components in setting out the ICS of various major operations:
Policies and Operational Procedures
- Lay down clear policies and procedures of kindergartens’ major operations (e.g. procurement, student admission).
- Ensure that managers and staff understand the policies and operational procedures of the kindergarten through effective communication.
- Regularly review the policies and operational procedures and update them as necessary to suit current operational needs.
Checks and Balances
- Put in place appropriate control measures in operational procedures that are commensurate with the corruption risks involved to mitigate the risks, including:
- Preventive measures: for example, segregation of critical duties in a process as far as practicable; approval of important decisions by persons of appropriate ranks;
- Detective/deterrent measures: for example, random supervisory checks on important operational procedures, collection of feedback/complaints, independent audit.
- Make transparent key information in relation to operational procedures.
- Establish effective communication channels to disseminate key information to the stakeholders concerned.
- Lay down policies and adopt effective administrative/technical measures to control access to and retrieval of confidential information.
Accountability and Management Oversight
- Require managers/staff to properly document and keep proper records of key operational procedures.
- Submit management reports to the School Management Committee.