The Lifestyle Audit Investigation Pilot Team

On 18 May 2023, the Public Administration Ethics Integrity and Disciplinary Technical Assistance Unit (PAEIDTAU) conducted the first pilot training on lifestyle investigation procedures at Batho Pele House. The training was piloted to investigators selected from four national departments: Correctional Services, Government Communication Information System, Home Affairs and Statistics South Africa. The pilot aimed to fine-tune the developed training material for investigators to conduct proper lifestyle investigations.

When lifestyle audits became compulsory in April 2021, departments in the Public Service proceeded to conduct the three-step lifestyle audit process, as outlined in the Guide to Implement Lifestyle Audits in the Public Service as follows:

The first step is a lifestyle review is conducted by Ethics Officers during the financial disclosure process when they evaluate the financial declarations of public service employees that are submitted via the e-Disclosure system (an electronic disclosure system). The aim is to validate submitted information and assess it for possible conflicts of interest or unexplained wealth. The second step kicks in should the Ethics Officer find something untoward during the validation process, such as a conflict of interest or unexplained wealth.

The second step is an investigation that seeks to establish the facts of a situation. The process uses legally sound methods to corroborate information independently by collecting evidence on a suspicious case. It involves identifying undeclared sources of income, such as remunerative work outside the Public Service and receipt of gifts. Or to determine whether a person lives beyond their means by identifying debt, assets, income, criminal records, trusts, hidden assets, and undeclared income.

The third step is lifestyle audit/objective evaluation that begins when a case grows complicated. Step three involves an auditing process to find assets that may explain the employee’s riches or reveal illegal gains. Audit sampling and audit standards determine the auditor’s opinion.

To assist with the rollout of lifestyle audits in national and provincial departments, the PAEIDTAU initially focused on lifestyle reviews and developed a specialist course for Ethics Officers to review financial disclosures. This course was designed with the help of the World Bank, the United Nations Office on Drugs and Crime, and the Strengthening Ethics and Integrity Project (SEIP), which the Canadian Government supports.

Since their introduction in April 2021, the provincial uptake of lifestyle audits has increased thanks to the Department of Public Service and Administration’s awareness campaign and the technical support of the PAEIDTAU.

In January 2022, 47 provincial departments across all nine provinces conducted lifestyle audits and the number for national departments was 27.

Towards the end of March 2023, the number of provincial departments conducting lifestyle audits increased to 89 (from 103 provincial departments). In the same period, 36 (out of 44) national departments reported completing lifestyle audits. These departments also submitted reports on lifestyle audits to the PAEIDTAU.

KwaZulu-Natal and the Western Cape obtained a 100% compliance rate, as all their departments concluded the lifestyle audit process.

Increasingly, more departments detected possible conflicts of interest and unexplained wealth in the 2022/2023 financial year, compared to the 2021/2022 financial year, when only the Western Cape referred cases for further investigation. To date, several departments have referred cases for further investigations. These include Western Cape agriculture; Western Cape: Health and Wellness; Gauteng: Transport and Logistics; North West: Health; KwaZulu-Natal: Health; Free State: Cooperative Governance and Traditional Affairs; and Gauteng: Office of the Premier. The PAEIDTAU is monitoring these investigations as departments are required to report issues of misconduct emanating from criminal investigations to the Unit in terms of section 15(5)(b) of the Public Administration Management Act, 2016.

During this financial year, the PAEIDTAU will strengthen the investigations part of the lifestyle audit process by developing training material for investigators. For this reason, the pilot session held on 18 May 2023 at the DPSA covered the preliminary analysis done during lifestyle investigations to screen incidents upon receipt by the screening administrator before an investigation can be conducted. Moreover, the pilot addressed the lifestyle investigation workflow and related documents. The pilot was developed under the SEIP, with the support of CoWater International.

Along with the following initiatives to strengthen the implementation of lifestyle investigations, pilot training will be rolled out to the rest of the Public Service when refined in the area of pilot/workshop on the implementation of professional standards for lifestyle investigators; The development of operational procedures to assist departments with lifestyle investigations; The distribution of a questionnaire to investigators performing lifestyle investigations; and the development of tools and forms.

These initiatives standardise and professionalise lifestyle audits to combat public service corruption. This will help the PAEIDTAU monitor and evaluate lifestyle audits in the public service as prioritised by the President and the Minister for Public Service and Administration.

Mr Isaac Kabini is the Director of Monitoring and Evaluation, Oversight, and Interventions Management at the Department of Public Service and Administration.