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Last updated: 4 September 1991
Circular 1991/11: Frequent flyer schemes
This publication remains current but needs to be read taking into account the repeal of the old Act and the proclamation of the new Act
Background
1. I wrote on 22 July 1991 to Heads of Management in the Australian Public Service to convey guidelines on the acceptance of official gifts. Another issue relating to the acceptance of gifts has arisen. Domestic airlines have commenced high proflle bonus schemes for frequent flyers. These schemes offer benefits such as free travel, consumer goods and holidays to individuals who accumulate bonus points by flying with the airline concerned, as well as through the use of nominated hotels, rental cars and credit cards.
Conflict of interest
2. The schemes create an immediate and continuing conflict of interest for officers and employees of the Australian Public Service.
3. Broadly, regulation 37 of the Public Service Regulations requires that:
- an officer must not take advantage of an officer's functions in order to obtain a benefit; AND
- an officer must not, unless they have the written approval of the Secretary of the Department, accept a benefit from any person concerned with any matter connected with the officer's functions.
This provision also applies to employees.
4. An officer or employee of the Australian Public Service who breaches regulation 37 may have committed misconduct, and could be subject to disciplinary action under the Public Service Act.
Policy on frequent flyer schemes
5. It is Government policy that official travel and assoc-iated arrangements (accommodation, car rental etc.) should not be used to accumulate bonus points for "frequent flyer" benefits for private purposes. Further, it is Government policy that where an officer or employee of the Australian Public Service has already accumulated bonus points which would otherwise entitle them to obtain a benefit, they should not accept such a benefit.
6. Officers and employees should not accept lottery-type prizes which they may have won under other schemes relating to official travel.
7. The advantages offered by airlines to customers should, however, be utilised by agencies, and it is suggested that agencies negotiate with the airlines to enable bonus points arising out of official travel to accumulate towards other official travel, or to be converted to a discount on official travel costs.
8. There is no prohibition on officers or employees accumulating points and accepting benefits when flying or using nominated hotels and rental cars privately, or for private use of credit cards.
Denis J Ives
Public Service Commissioner
4 September 1991
