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Acting on values: an ethical dead end for public servants.

We all want public servants to be ethical (i.e., to do right rather than wrong when faced with hard choices on the job). But how are we to ensure that public servants individually and in groups act ethically?

Traditionally, democratic governments have focused on the development of rule sets (in the form of legislation, regulations, codes of conduct, policy directives, etc.) designed to provide specific guidance to public servants faced with procedural ethical dilemmas (e.g., decisions concerning conflict of interest, confidentiality, and political neutrality) and substantive ethical dilemmas (e.g., decisions affecting the security, safety, and health of citizens). Public servants were expected to adhere to these rule statements and seek direction from superiors if the instructions were not explicit enough. Over the last decade, however, the rules approach to good behaviour in the federal public service has been challenged by the values approach, which argues that fostering core values and building an ethical culture is key for establishing a public service that acts ethically. The central tenet of the values approach, explored in this article, is that a framework of core values can be used directly by public servants to solve ethical dilemmas or to justify more specific rules of behaviour. Other governments in Canada and elsewhere have integrated values and value-based statements of principles into their respective ethics regimes, but few have embraced the values approach with more enthusiasm than the senior bureaucratic cadre in Ottawa.

While the values approach is a superficially attractive and increasingly popular approach, I argue that the claim for the importance of values as a foundation for building good ethical behaviour among public servants cannot be sustained. The values approach is conceptually flawed on a number of levels. Its advocates seem confused about what a value is and how to identify core values. They also seem tolerant of the existence of a large number of core values that are not clearly defined. This inevitably creates a situation in which there is substantial, irresolvable value conflict. Finally, the values approach, at least as structured in Ottawa, subdivides values into groups, making a puzzling distinction between ethical and non-ethical values. After examining these flaws, I explore the need to pay more attention to consequentialist approaches for enhancing ethical behaviour that resonate with the ways in which public servants intuitively approach ethical judgements. The article does not deal in any detail with arguments in favour of enhancing control regimes as an antidote to bad behaviour. (1)

A brief history of the values approach to ethical public service in Canada

Values such as responsibility, accountability and political neutrality have been the currency of debate about Canadian public administration since the discipline was defined. (2) But, generally, such discussions were prefaces to the proposal, construction or evaluation of institutional or procedural vehicles for ensuring the health of the value in question. For example, the predictable fixation with the value of accountability among the commissioners and staff of the Royal Commission on Financial Management and Accountability, in the late 1970s, led not to a call to build a stronger accountability culture in the federal government but to recommendations for changing structures and processes to allow the "electricity" of accountability to flow unimpeded. (3) Similarly, the merit value spawned the merit system. (4) Values were the obvious focus of the report of the federal deputy ministers' Committee on Governing Values, in 1987. The Institute of Public Administration of Canada put forward a values-driven "Statement of Principles Regarding the Conduct of Public Employees," also in 1987. The institute also co-published, in 1990 (with the Institute for Research in Public Policy), The Responsible Public Servant, a volume (of which I am co-author) examining the contemporary meaning of the values and principles contained in the statement. (5) In 1991, the spring issue of this journal was dedicated to the subject of ethics in government and business. But--and this is the important point--none of these publications made much of using core values as a vehicle for directly transforming the behaviour of public servants.

The shift to what I am calling a values approach to ethical public service in Canada is most clearly seen in a 1994 article by Ken Kernaghan, in which he talks about using values as a management tool to effect change in public-service ethical culture and behaviour. (6) In an influential piece also published in 1994, Bev Dewar described values as "standards to help us measure progress, decide perplexing questions and choose between alternative courses of action." (7) The auditor general argued for a variation on the values approach in his 1995 report on ethics and fraud awareness. A year later, the federal Task Force on Public Service Values and Ethics provided the official endorsement for this approach in Ottawa. Building on the work of an earlier deputy ministers' Committee on Governing Values and on the "Public Service 2000" white paper, the purpose of the task force's 1996 report was to "help the public service to rediscover and understand its basic values and assist the public service to recommit to and act upon those values in all its work." (8) This report led to the creation of a values and ethics management education initiative by the Canadian Centre for Management Development (now the Canada School of Public Service), (9) the naming of two deputy minister co-champions of values and ethics, (10) the establishment of the federal Office of Public Service Values and Ethics, with its own assistant deputy minister, (11) and, in September 2003, the release of a "Statement of Public Service Values and Ethics"--a values-based set of principles designed to "guide and support public servants in all their professional activities." (12) In addition, a number of federal departments have taken initiatives to develop values and ethics dialogues, an activity strongly recommended by the task force in 1996. (13)

The explanation for this shift to a values approach to ethical behaviour is undoubtedly a complicated one. At the most general level, the emphasis on values is connected to the increasing popularity of arguments that see great significance in the positive management of the corporate culture of organizations. (14) More specifically, the new public management model of public service, with its rejection of the efficacy of rule-bound bureaucracy and its emphasis on the empowerment of the employee, played an important role in this transformation. (15) If rules won't create good public services, then they are unlikely to create good public servants. Les Pal suggested that the rules approach might also have lost popularity due to the challenge of building more complex edifices of dicta to cover an ever-widening gamut of possible ethical offences. The recent American experience with rule creation can be quite daunting in this respect. (16) Pal also noted how the Charter of Rights and Freedoms' strong focus on values has seeped into all aspects of Canadian life over the last twenty years. He described the Charter as "the elephant at the dinner table," arguing that it was hard for public servants to ignore values such as equity and equality when they became the drivers of so many court decisions concerning government law and policy. (17) Finally, there is the copycat factor. The values approach has been a hot item in public-sector reform in recent years. (18)

Values and ethical behaviour

The intention of the values advocates is "to make values a pervasive influence on the decisions and actions of public servants, (19) and to move from a "rules-bound culture to a values-based culture." (20) But how are value-driven ethics different from rule-based ethics, and how are the former supposed to work?

It is easy to understand how ethical rules are designed to affect behaviour. As suggested above, the rule-makers create laws, regulations and codes of conduct designed to deal specifically with the common, difficult choices a public official might confront. Rules about conflict of interest or political neutrality spell out in detail (sometimes for different levels of public servant) how large a gift is allowed, the circumstances in which moonlighting is unacceptable, what partisan political activity is inappropriate, and how many months after leaving office a public official can do business with his or her previous employer, etc. The federal "Conflict of Interest and Post-Employment Code for Public Office Holders" (now part of the recently issued "Values and Ethics Code for the Public Service") is a good example of such detailed rules. (21)

Less visible to the public but often more germane to the day-to-day work of public servants are the detailed policies and regulations designed to solve the tricky ethical problems associated with the application of broad government legislation in areas such as employment insurance, health care and immigration. Employers can use these rule sets to establish standards in the workplace, educate employees about appropriate behaviour in specific circumstances, and hold them to account for their actions. Counsellors, commissioners and ethics officers can be added to the rules-based ethics regime to provide advice and manage the implementation and enforcement, as required. (22) When unforeseen dilemmas emerge or the courts strike down a rule (e.g., with respect to political neutrality standards or the level of risk to which the government can expose a citizen), the employer can amend or expand the rules. This approach to ethical management is mechanistic, paternalistic and often reactive, and the results can be legalistic, burdensome and dull. (23) But rules have the advantage of clearly setting out what the employer will accept as responsible behaviour.

Values, however, are on a higher level of abstraction. Either on their own (e.g., loyalty) or incorporated into statements of principle (e.g., "Public servants shall loyally implement ministerial decisions, lawfully taken." (24)), values are widely seen to have the quality of justification. They reflect a belief in something important and legitimate, something that can be used to justify actions or the establishment of more specific behavioural rules. This legitimacy flows largely from their widespread acceptance, the sense that this is an idea that most people in the organization (and perhaps the wider community) would endorse. Connecting this discussion to the notion of corporate culture, it is argued that the core values of an organization can be discovered like natural laws. They reflect the basic shared beliefs of the members of the organization. This quality of universality is an important component of an ethical defence, as it creates the opportunity to make an argument driven by something more substantial than the personal interests of the individual or group setting the standards.

Advocates of the values approach use core values and principles to enhance public-service ethics in two ways. First, and primarily, they insist on a direct connection between values and principles, on the one hand, and behaviour, on the other. This means that a framework of core values and statements of principles based on them can be used directly by public servants to deal with ethical dilemmas. The federal government advertised its new approach to ethical decision-making in a background paper provided to the OECD: "The Canadian public service began to emphasize the importance of values and principles in the 1990s.... Rather than create rules and regulations, therefore, the federal government provided principles as guidance to public servants in their professional conduct and private interests." (25)

Janice Cochrane, speaking as deputy minister of citizenship and immigration and one of the federal co-champions of values and ethics in the public service, defined values and ethics and made the connection between them: "Workplace values are the standards we set for our interactions with our clients and with each other. They include such things as serving the public interest, excellence, teamwork, integrity and compassion. Ethics is the way we put our values to work in actual decision-making--that is, in doing the right thing." (26)

Catherine MacQuarrie, director of the Office of Public Service Values and Ethics in the federal Treasury Board Secretariat, was even more pointed about the nature of the connection between values and ethical decision-making:

We need to show how values and ethics can deliver concrete results. We need to have methods for making adjustments to the framework (of values) as needs and views change. Fundamentally, a statement of principles must be integrated in the day-today ethical thinking of public employees, which informs their conduct and influences their decision-making in all things. We need to assist people in the early recognition of ethical dilemmas, find ways for people to figure out how to balance competing values, and be a support for those who practice ethical decision-making. (27)

Second, some values advocates see values as justifications for ethical rules. Values are a place to go if an employee asks "why" (beyond fear of disapprobation or punishment) a rule should be obeyed. As Kernaghan put it, "A code of conduct and, indeed, any of the rules for public-service ethics should be firmly rooted in ethical values so that public servants understand the ethical underpinnings of these rules." (28) Since the essence of ethical reasoning is the provision of arguments in favour of or against a certain position, then values are viewed by their supporters as the foundation on which specific rules or more detailed codes of conduct are constructed. To this end, some governments have gone to considerable lengths to make the connection between their rules and their statements of values. (29)

So, to sum up the values approach, a framework of core values that reflects the shared beliefs of the members of the organization is an essential tool for public servants to work out appropriate ethical behaviour in specific instances and can also be used to justify the establishment of rules designed to deal with specific ethical dilemmas.

The identification of values

As attractive as the values approach to ethical reasoning might look at first glance, it is not without significant problems. The first challenge is the identification of core values. As noted, core values are supposed to emerge from the particular government or agency as self-evident representations of the essential beliefs of the members of that organization. Many value advocates portray value identification as a sort of continuous polling exercise in which core values come and go depending on their relative popularity within the organization. (30) Surveys purport to tell us which shared values rise above the noise level of a government or agency at a particular time and which don't. The logic seems to be that if employees don't recognize and identify them, then they aren't shared core values of that organization.

But this position is not universally embraced. The report of the 1996 Task Force on Public Service Values and Ethics, A Strong Foundation, seems to accept the idea that the core values of the federal government are there to be discovered and that they can change over time. On the other hand, the report notes that "certain values emerged spontaneously from our reflections. They are values that come naturally to mind as one thinks about public service, the values without which it is not possible to speak of public service at all." (31) This suggests that the values survey conducted informally among task force members trumped more formal survey findings, to the degree that the latter did not find real-time evidence of values that in the view of task force members were self-evidently core value. In this rather paternalistic view, the values of a public-service organization are to be discovered, but the explorers better find the values that should be there! (32)

Even if you accept the idea that "what you see, is what you get," the survey approach to core value identification is not without its difficulties. Virtually all of these surveys are studies of the perceptions of managers or strategic planning documents produced by managers. As a result, the values may not at all represent the broad spectrum of beliefs in particular governments or public-sector organizations. (33) If this is so, the "universal" quality of the values identified in a particular survey can easily be challenged and their suitability as means of justifying ethical behaviour or rules diminished.

Organizational values also--as Kernaghan notes--represent no more than espoused values; therefore, they may not reflect the operational values of the organization. (34) In view of the high premium most people place on being perceived as "good," you can be sure that management surveys and organizational value statements will not display the prominence of "negative" values or vices (e.g., secrecy, cruelty, intolerance and hypocrisy) in the daily life of the organization under scrutiny. For example, it will come as no surprise that while diversity is trumpeted, racism and hatred are not advertised values in "The Promise of the Ontario Provincial Police." (35)

Finally, the lists of values turned out by the surveys contain entities that do not look much like values. In effect, the term "value" has been expanded to embrace almost every conceivable human and organizational property or aspiration. For example, "integrity," "quality," "professionalism" and "excellence" are cited as prominent values in the data used to illustrate changing public-service values. (36) But are these values similar to "political neutrality" or "respect for the law," or are they merely parking lots for a contestable collection of competencies? If faced with a difficult choice, would a public servant gain much guidance about what to do if she invoked the notion of "integrity," or would she need a more concrete and focused filter through which direction with respect to the choice could potentially be provided?

To sum up, this mixture of apples and oranges under the title of values makes it difficult to sort out what the values advocates mean by the term and how to distinguish a value from something else. As a result, a number of the so-called values identified by surveys and embraced by values advocates provide little assistance to a public servant seeking the right course of action in difficult circumstances. Moreover, even if values advocates were more discerning about what a value is, a puzzle remains about the appropriate way in which to identify the core values of a government or agency such that the claim that they reflect widely accepted beliefs can be sustained. After all, this claim represents their primary source of legitimacy as tools of ethical justification.

Ultimately, the most disarming point concerning the identification of core values focuses on this issue of legitimacy. The fact that many or even all members of a government organization (or the Task Force on Public Service Values and Ethics) when surveyed expressed the belief that following the dictates of values a, b, c, etc. would result in good ethical behaviour does not constitute a compelling argument for subscribing to those values. As Philip Pettit puts it, "It is one thing to make a list of values which allegedly require honouring.... It is another to say why these values are so very different from the ordinary run of desirable properties." (37) Some or all of the values identified by advocates of the values approach could ultimately be defensible as guides to right action, but as presented they are little more than "an incoherent jumble of ideas and principles." (38)

Too many core values

A related problem is the sheer number of values to which public servants can attach an argument for or against a proposed action or a particular rule. The federal task force identified four "clusters" of core public-service values (ethical, democratic, professional and people--on which more later) and within these clusters set out a confusing, repetitive and lengthy shopping list of values ranging from accountability, loyalty, equity, fairness and primacy of law, to excellence, competence, merit, effectiveness, creativity, service, discretion, probity, courage, decency, tolerance, openness and caring. Depending on the allowances made for duplication, there are as many as fifty to sixty federal government "core" values featured in A Strong Foundation. (39) An analysis of the value statements of ninety-three Canadian public organizations identified 164 core values. (40) The new federal code uses the same four value clusters as in A Strong Foundation but reduces the "core" to around twenty-five different values. (41) Kernaghan's recent work provides a table of thirty-two values in the familiar four clusters, indicating that four of these values are repeated. (42) Because this is the clearest of the various statements of core values, I include it here (Table 1). (The repeated values are in italics.)

Finally, value advocates see no problem with individual departments and agencies within a particular government supplementing the core value list for their organizations by adding values that are "core" to their particular responsibilities. Kernaghan gives the example of a finance department adding the value of "fiscal prudence." (43) Even more disturbing, if you are concerned about the open-ended character of public-service values, are the expansionary prospects of establishing the core values for a department or agency that is dominated by members of a particular profession (e.g., foresters, social workers, accountants), which quite naturally would give voice to the core values of their respective professions. (44)

The obvious problem here is that by allowing a large number of values to be described as "core," the notion of "core" becomes empty. If everything is important, then nothing is important. How are we to focus employees and new recruits on the meaning of public service and provide a practical platform for ethical problem-solving when we hold up twenty or more values for their consideration?

A self-evident answer would be to narrow the range of so-called core values. Commenting on A Strong Foundation shortly after its publication, Peter Aucoin reduced the field to three core values that he argues are the "fundamental values that should guide and inform public-service practice within a non-partisan, professional public service operating under our system of responsible parliamentary government." His three chosen values are the primacy of the rule of law, impartiality in administering public services, and public service as a public trust. Without reference to the task force report, Ian Greene and David Shugarman proposed a similar short list in their 1997 book on public-sector ethics. (45)

But these opinions are swimming against the stream. Clearly, the contemporary trend has been to expand the core value set. The various inclusiveness movements, for instance, have successfully promoted the addition of values such as representativeness and equity and provoked something of a crisis in the meaning of merit. (46) Close working relationships with First Nations communities open up the possibility that kinship will be accepted as a value. (47) The combination of the neo-liberal and business invasions of traditional public administration has led to the highlighting of values such as efficiency, effectiveness and service and, more recently, values such as innovation, excellence and leadership. Similarly, values such as horizontality, collaboration, teamwork and cooperation have become more visible with the increasing attention being paid to network-based models of organization. (48) Non-secular values can creep into the mix through partnerships between government agencies and faith-based organizations. (49) The task force noted the "degree and rapidity with which a new range of values has entered the public service, and the way in which they may have displaced or affected the prominence of some older public service values." (50) But neither the task force nor any other values advocate seems concerned enough about the negative consequences of having so many core values to make their reduction a high priority.

Value-shopping and conflict

Beyond the inherent silliness of valuing anything and everything, lies the spectre of endless value conflict. For the cynical, a long list of core values affords an opportunity to "value shop." The longer the list, the more likely it is that a federal public servant, facing a hard choice or questions from superiors about an action taken, could rationalize any position or rule interpretation by adhering to one core value rather than to another. What is an opportunity for the cynical is a nightmare for more responsible public servants. Where one sees the obligation to advance the value of service in a particular situation, another might see the value of accountability as dominant, and another might feel compelled by the demands of fairness. Value conflict is the inevitable result of large core-value sets.

This problem of duelling rights and values has long been a recognized shortcoming of most values- or rights-based moral reasoning. If a large number of values are all recognized as "core" values, then how can the claim based on one value be more significant than the claim based on another? The contemporary advocates of a values approach talk about dialogue and applying a "balanced framework" of values to the solution of ethical dilemmas but, beyond fostering dialogue, offer no sustained leadership in the resolution of value clashes. (51) Except for sending the vague message that a serious public service can't exist without adhering to certain values, I can find no guidance that would assist a public servant in understanding how some values might have a higher priority than others. (52) Moreover, a number of traditionally "intrinsic values" (53) (e.g., equality, responsibility, the public interest, trust), which, it might be argued, would trump more ephemeral values in an ethical dispute, aren't even found on some of the more prominent value lists.

John Rawls and others see this notion of balancing values or principles as the greatest weakness of value pluralism. Such approaches, Rawls argues,

consist of a plurality of first principles which may conflict to give contrary directives in particular types of cases: and second, they include no explicit method, no priority rules for weighing these principles against one another: we are simply to strike a balance by intuition, by what seems to us most nearly right. Or if there are priority rules, these are thought to be more or less trivial and of no substantial assistance in reaching a judgment. (54)

The problem of value conflict does not end here. Clustering has the tendency to group values around different public-service paradigms (e.g., traditional hierarchical, representative, and new public management models). This enhances the tendency of public servants and academic observers to see themselves as adherents of one paradigm or the other and establishes the foundation for the argument that actions and rules can be rationalized with reference to the values of one paradigm while downplaying the values of others. (55) There is a strong suggestion of this development in the task force's establishment of its four value clusters. Unfortunately, there is no sign that the task force or its supporters recognized that clustering can reflect adherence to a specific belief system (e.g., the "professional" cluster is made up of values that owe their provenance to business or new public management) and an implicit or explicit rejection of the importance of other belief systems and their values. We need to be alert to the potential for the values approach becoming a divisive and possibly ideologically driven exercise, allowing (or forcing) public servants to subscribe to individual values or clusters of values, rather than a means of achieving consensus around a universally accepted and manageable set of core values. By way of example, many public officials working within the fundamentalist Christian value structure of the Bush administration would need no persuading of the saliency of the concern about forced adherence to a particular value cluster.

But there is worse to come yet with respect to value conflict. Not only are public-service values seemingly infinitely expandable, thereby creating fertile ground for values gang warfare, but certain value sets might be particular to certain types of public services. For instance, the values of a public service in a Westminster tradition would be different from those of public services connected to municipal or republican governments. Since values emerge from specific organizational cultures, it does not stretch logic to argue that even within the circle of Westminster governments the core values of each government will be different. In fact, Kernaghan's recent review of the efforts of Australia, New Zealand, the United Kingdom and Canada illustrates this reality quite clearly. While there are commonalities in core value statements in the four Westminster jurisdictions, they are far from being the same. (56) This creates the potential problem of public servants defending actions or rules by appealing to values that have little or no resonance in other communities of public servants or with the wider public. In a federal state in which much governmental activity takes place across jurisdictional boundaries, this is inevitably a cause for concern. All of this represents a further assault on the notion that any so-called core values would have enough ethical "traction" to justify specific rules or behaviour.

The plasticity of specific values

Even if we were to create a consensus around the priority of a smaller number of core values, public servants attempting to use them would find all core values ambiguous in nature and subject to a wide array of interpretations. Look at the contemporary debates about the meaning of "merit" and the capacity of this seemingly straightforward value to embrace not only the notion of "the most qualified" but also the lesser meaning of the merely "qualified," as well as more complex ideas of "equity" and "representation." Consider the variety of interpretations of "political neutrality" or "accountability." As Donald Savoie has argued recently, all elements of the traditional notion of political neutrality, from loyalty to anonymity and permanence, are being questioned and redefined. (57) Similarly, the contemporary debate about accountability divides those who subscribe to the traditional and narrowly construed hierarchical notion of the value from those who tend to see "outward" and "downward" accountability as more important in modern public service than "upward" accountability. (58) Unfortunately, such debates are not ended by publishing an official dictionary of values and ethics terms. (59)

This kind of squabbling is deadly for the values approach. Even if a group of public servants agrees that merit, for example, is the key core value in a particular situation, that group can still encounter major difficulties in arriving at a collective decision about whether an action or rule is defensible. Ethical arguments are supposed to feature good reasons, reasons that can be understood and responded to by other disinterested people. The capacity to deflate or inflate the meaning of individual core values diminishes the possibility that disinterested people can narrow the range of appropriate actions that should flow from that value, even where the identification of the dominant value is not in question in a particular situation. Ironically, the values-based ethics advocates argue that core values will be a unifying factor in a more culturally diverse public service. (60) This seems to fly in the face of logic. The more diverse the make-up of the public service, the more difficult it will be to paper over divisions in the meanings that different individuals and groups attach to core values.

Ethical versus other values

As noted, values advocates at the federal level in Canada have made the connection between values and ethical action even more confusing by creating four clusters of values (ethical, democratic, professional and people) and insisting that only one cluster contains ethical values. As Kernaghan put it, "Clearly, not all values are ethical values, that is, not all values relate to questions of right and wrong, good or evil. It is helpful, therefore, to distinguish ethical values from other types of values." (61)

Before setting out the problem afflicting this position, it has to be noted that even the advocates of this clustering seem uncertain about it. The new federal code, copying from A Strong Foundation, admits that these "families of values are not distinct but overlap," then puzzlingly adds that "[t]hey are perspectives from which to observe the universe of Public Service values." (62) Kernaghan himself recognizes that the clusters aren't watertight categories, as Table 1 reflects.

The problem here is not the uncontestable fact that different values trace their provenance to different theoretical or ideological roots. As noted earlier, it is an interesting and harmless occupation to connect the value of political neutrality to the theory of responsible cabinet government, or the value of service to the theory of new public management. The confusion emerges from the attempt to segregate ethical values from the rest. The distinction is meaningless and misleading. You cannot narrow the field of ethical conflict by declaring that some values are ethical values and some are not. A public-sector ethical dilemma is simply a situation in which an official is faced with a choice that seriously affects the well-being of colleagues, superiors, citizens or foreigners (and, possibly even more widely, the life of the flora or fauna for which the official is responsible). (63) In this context, virtually every value--whatever its prescribed cluster--can become implicated in an ethical choice if that value can be used as a rationale for a particular action. Subscribing to the value of "efficiency" in a particular situation will have an ethical dimension if your decision is more likely to affect individuals or society differently than if you had subscribed to another value. Furthermore, a number of the values listed in non-ethical clusters (e.g., courage, benevolence, service) are obvious mainstays of Aristotelian-style virtue ethics. (64)

In my experience, this segregation of values has proven to be a very puzzling development for public servants. They cannot see in practical terms what the difference is between an ethical value and values labelled as "democratic," "professional" and "people," and they are confused about the appropriateness of referring to so-called non-ethical values when dealing with ethical choices.

The values approach and the real world of public-service ethical choice

After more than twenty years of facilitating ethics workshops for public servants at all levels, my experience is that they are perplexed by the seemingly simple appeal to values as arbiters of what is good, on the one hand, and, on the other, the confusion about the nature of a value, the proliferation of values, the plasticity of their meaning, the resulting potential for value conflict, and the puzzling notion that some values are ethical and others are not. In other words, they don't see how value pluralism does much to help them solve ethical dilemmas.

My further experience is that most public servants, when faced with an ethical dilemma, rapidly turn away from value balancing as a means of defending or attacking an action or a rule. When I ask public servants in ethics workshops why they would choose a certain course of action or enforce a certain rule when faced with an ethical dilemma, their first "gut" reaction may be value-based (e.g., "that action violates the client's right of privacy"). However, a follow-up question (e.g., "why is protecting privacy important, or at least more important than servicing another value like effectiveness?") leads inevitably to an analysis of the negative and positive consequences for a range of stakeholders of taking a particular action or defending a specific rule. Surprisingly, this is consistently so even in discussions of cases that relate to a value such as political neutrality that might more readily be defended by reference to the perpetuation of the wider value system of responsible cabinet government of which it is part. The fact is, public servants are intuitively consequentialists and pragmatic in their everyday ethical reasoning. (65) Since it serves no purpose to end up in a values bun fight that can't be resolved, they move on to some form of consequential analysis. As F.N. Brady puts it, "Particulars do make a difference in ethics. Indeed, as one's outlook becomes increasingly attentive to concrete details, ethical universals seem less able to justify one's action." (66)

In contemporary philosophical discourse, consequentialism can take a wide variety of forms, and the debates about the pros and cons of these different forms are spirited and complex. (67) Nevertheless, consequentialism remains a defensible approach to ethical decision-making that is particularly suited to circumstances in which public officials are faced with the responsibility of helping to determine what action is right for a large group of employees, a whole community or even the whole country. Thomas Nagel famously argued that the demand that public officials be impartial and treat the interests of all relevant stakeholders equally justifies according a greater weight to the consideration of outcomes in public morality than would be the case in private morality. Peter Singer, looking at a series of difficult social policy issues, echoes this point, arguing that the imperative attached to treating the interests of every affected citizen equally, "requires me to weigh up all these interests and adopt the course of action most likely to maximize the interests of those affected. Thus I must choose the course of action which has the best consequences, on balance, for all affected." (68)

While undoubtedly removed from contemporary philosophical debates about consequentialism, virtually all public servants intuitively resort to the premium attached in democratic societies to being able to defend actions or rules in terms of their impacts on all affected stakeholders in specific situations. The consequentialist approach to establishing the public good and testing specific rules of conduct fits nicely with the roles of public servants as impartial advisers to political superiors, providers of services to the public, enforcers of laws and evaluators of state action. Brady argues that a public servant "may like to act on principle, but her experience tells her the situations she has encountered are so rich with relevant detail that acting on principle just feels too stubborn." R.E. Goodin supports this argument and has harsh words for those who would ignore this reality:

It would be simply irresponsible of public officials (in any broadly secular society, at least) to adhere mindlessly to moral precepts read off some sacred list, literally "whatever the consequences." Doing right though the heavens may fall is not (nowadays, anyway) a particularly attractive posture for public officials to adopt. (69)

Ironically, the inevitable resort to consequential analysis is illustrated even in the ethical dialogues sponsored by the federal advocates of the values approach. (70) But while such advocates may recognize that consequential ethical analysis goes on, they don't pay any real attention to it. So, we are faced with a situation in which the approach adopted by senior public servants in Ottawa to enhance ethical behaviour simply fails to address the way in which most public servants intuitively think about ethical dilemmas. As it stands, then, there is a very substantial disconnect between the prescribed approach to ethical decision-making and the way in which most public servants struggle to make ethical decisions.

Conclusion

According to the advocates of what I have characterized as the values approach, the most effective route to good ethical behaviour in a public service is to establish the core values of the organization and empower employees to "be guided in their work and their professional conduct by a balanced framework of public service values." (71) As Don Johnston, the Canadian secretary-general of the OECD, SO neatly put the thesis, "We believe principles are better than rules because anybody can wriggle their way around rules. But you can't get around principles." (72) Rules aren't discarded in the values approach, but they become an archeological layer in the history of public service ethical development, covered over by core values and statements of principle, the new drivers and arbiters of appropriate public conduct.

Unfortunately, as this article has argued, you can get around values and principles. There is no evidence that the values approach, as it is being developed in Ottawa and other capitals, provides public servants with the tools they need to make good ethical decisions. (73) The problem is not primarily the effectiveness of the implementation; rather, it is the nature of the approach itself. Ironically, A Strong Foundation recognized at the outset a number of the potential problems associated with the development of a values approach. (74) Regrettably, the initiative it spawned appears to have succumbed to those problems and others as well.

So where do we go from here? The most obvious step would be for those responsible for the values approach to make a concerted effort to rescue their project from its shortcomings. To do this they would need to clarify what a core value is and how we identify its existence in an organization, explain why a value's popularity gives it ethical legitimacy, establish a much smaller range of core values for public servants, define them clearly, rethink the distinction between ethical and non-ethical values, and provide more substantial and defensible guidance about how public servants are supposed to deal with value conflict when solving ethical dilemmas or creating and defending specific ethical rules. In no small part, this would involve coming to grips with widely employed consequential approaches to public-sector ethical dilemmas. Similarly, establishing a much smaller circle of core values will entail dealing with the claims of supporters of those "core" values left on the cutting-room floor. There are many proposals made in the contemporary moral and political philosophy literature for getting past the quandaries of value pluralism, and these ideas need to be given due consideration if we are to address the failings of the values approach and provide something more than specific (and, often, seemingly arbitrary) rules to public servants to help them solve ethical dilemmas confronted on the job.
Table 1. Categories of Public-Service Values

Ethical Democratic Professional People

Integrity Rule of law Effectiveness Caring
Fairness Neutrality Efficiency Fairness
Accountability Accountability Service Tolerance
Loyalty Loyalty Leadership Decency
Excellence Openness Excellence Compassion
Respect Responsiveness Innovation Courage
Honesty Representativeness Quality Benevolence
Probity Legality Creativity Humanity


Notes

(1) Sharon Sutherland pointed out the need to rebuild control systems, especially in the area of financial management (personal communication, 17 February 2004). See, also, Association of Public Service Financial Administrators, "Checks and Balances: Rebalancing the Service and Control Features of the Government of Canada (GOC) Financial Control Framework, December 2003," Association of Canadian Financial Officers [web site] ([Ottawa]: APSFA, [2004]), at http://www.acfo-acaf.com/news/check.

(2) See J.E. Hodgetts, "Implicit values in the administration of public affairs," CANADIAN PUBLIC ADMINISTRATION 25, no. 4 (Winter 1982), pp. 471-83.

(3) Canada, Royal Commission on Financial Management and Accountability (Lambert Commission), Final Report (Ottawa: Supply and Services Canada, 1979), p. 9.

(4) See K. Kernaghan and P.K. Kuruvilla, "Merit and motivation: public personnel management in Canada," CANADIAN PUBLIC ADMINISTRATION 25, no. 4 (Winter 1982), pp. 696-713.

(5) Canada, Committee on Governing Values, Governing Values (Ottawa: Supply and Services Canada, 1987); [n.a.], "The IPAC Statement of Principles Regarding the Conduct of Public Employees," Institute of Public Administration of Canada [web site] ([Toronto]: IPAC, [2004]), at http://www.ipac.ca/ethics/index.html. This statement is presently being updated by IPAC in consultation with its members; Kenneth Kernaghan and John W. Langford, The Responsible Public Servant (Toronto and Halifax: Institute of Public Administration of Canada/Institute for Research in Public Policy, 1990).

(6) Kenneth Kernaghan, "The emerging public service culture: values, ethics and reform," CANADIAN PUBLIC ADMINISTRATION 37, no. 4 (Winter 1994), pp. 614-30. Kernaghan pointed out earlier more general efforts to link values and administrative behaviour, in Kenneth Kernaghan, "Shaking the Foundations: New versus Traditional Public-Service Values," in Mohamed Charih and Arthur Daniels, eds., New Public Management and Public Administration in Canada. Monographs on Canadian Public Administration--No. 20 (Toronto: Institute of Public Administration of Canada, 1997), pp. 52-3. Kernaghan continued to explore, celebrate and foster the role of values in the enhancement of ethical behaviour in a series of chapters and articles over the last decade. See, for instance, Kenneth Kernaghan, "Valeurs, ethique et fonction publique," in J. Bourgault, M. Demers et C. Williams, eds., Administration Publique et Management Publique : Experiences Canadiennes (Ste-Foy: Les publications du Quebec, 1997), pp. 107-19; Kenneth Kernaghan, "The post-bureaucratic organization and public service values," International Review of Administrative Sciences 66, no. 1 (March 2000), pp. 91-101; Kenneth Kernaghan, "Integrating values into public service: The values statement as centerpiece," Public Administration Review 63, no. 6 (November/December 2003), pp. 711-19.

(7) D.B. Dewar, "Public Service Values: How To Navigate in Rough Waters," in Canadian Centre for Management Development, Values in the Public Service (Ottawa: Supply and Services Canada, 1994), p. 1 (emphasis added).

(8) Canada, Office of the Auditor General, Report to the House of Commons (Ottawa: Public Works and Government Services Canada, 1995), Chapter 1; Canada, Task Force on Public Service Values and Ethics, A Strong Foundation (Ottawa: CCMD, 1996), p. 1 (emphasis added).

(9) Office of Public Service Values and Ethics, "Who does what? A Framework of Responsibilities on Values and Ethics within the Federal Government," Public Service Human Resources Management Canada [web site] ([Ottawa]: [Public Works and Government Services Canada], [2004]), at http://www.hrma-agrh.gc.ca/veo-bve/who_e.asp; Canadian Centre for Management Development, Building on a Strong Foundation--The Dialogue Continues, Volume I: A Case Study Approach to Values and Ethics in the Public Service (Ottawa: CCMD, 2000); Canadian Centre for Management Development, Building on a Strong Foundation--The Dialogue Continues, Volume II: Further Case Studies on Values and Ethics in the Public Service (Ottawa: CCMD, 2000). See http://www.csps-efpc.gc.ca/research/publications/complete_list_e.html.

(10) See Office of Public Service Values and Ethics, "Who does what? A Framework of Responsibilities on Values and Ethics within the Federal Government," Public Service Human Resources Management Canada [web site].

(11) The Office of Public Service Values and Ethics, http://www.hrma-agrh.gc.ca/veo-bve/ index-sm_e.asp, has grown to twenty-three professional staff since its inception in 1999. It has taken a number of initiatives to foster the values approach.

(12) [n.a.], "Values and Ethics Code for the Public Service," Public Service Human Resources Management Canada [web site] ([Ottawa]: [Public Works and Government Services Canada], [2004]), at http:/ /www.hrma-agrh.gc.ca/veo-be/vec-cve/vec/cve_e.asp, p. 6.

(13) See Janice Cochrane, "How To Best Develop and Support Ethics Programs. Institute for International Relations Conference, Ottawa, October 3-5, 2000," Public Service Human Resources Management Canada [web site] ([Ottawa]: [Public Works and Government Services Canada], [2004]), at http://www.hrma-agrh.gc.ca/veo-bve/speeches/intlrelationconf_ e.asp. For examples of federal departments that have embraced the values approach, see http://www.hrma-agrh.gc.ca/veo-bve/best_practices/best1_e.asp. I helped the B.C. and Yukon Region of HRDC develop an on-line values and ethics dialogue for its 2,500 employees in 2001-02.

(14) See Gareth Morgan, Images of Organization (Newbury Park, Calif.: Sage Publications, 1986), Chapter 5; Henry Mintzberg's discussion of the "normative-control model" in Henry Mintzberg and Jacques Bourgault, Managing Publicly. Monographs on Canadian Public Administration--No. 25 (Toronto: Institute of Public Administration of Canada, 2000), Chapter 3; and O.P. Dwivedi and J.I. Gow, From Bureaucracy to Public Management: The Administrative Culture of the Government of Canada (Toronto and Peterborough: IPAC/Broadview Press, 1999).

(15) See Canada, Office of the Auditor General, Report to the House of Commons (Ottawa: Public Works and Government Services Canada, 2000), pp. 12.86-12.96. See http://www.oag-bvg. gc.ca/domino/reports.nsf/html/0012ce.html#0.2.0AKH9E.78C5D1.5 5582G.UF.

(16) See G.C. Mackenzie, Scandal Proof: Do Ethics Laws Make Government Ethical? (Washington, D.C.: Brookings Institution Press, 2002).

(17) Les Pal, personal communication, 9 March 2004. For an alarming account of the degree to which the values approach has come to dominate Charter-based decision-making by the Supreme Court, see R.I. Martin, The Most Dangerous Branch: How the Supreme Court of Canada Has Undermined Our Law and Our Democracy (Montreal and Kingston: McGill-Queen's University Press, 2003).

(18) See Kernaghan, "Integrating values into public service," Public Administration Review, pp. 712-13. For an example of the degree to which the same values approach is being used in Australia, see Andrew Podger [Public Service Commissioner, Australian Public Service Commission], "The Ethical Challenges in the Public Service, Leadership Forum 2002--Ethical Challenges for Business and Government Leaders, December 12, 2002," The Government of the Hong Kong Special Administrative Region, Civil Service Bureau [web site] ([Hong Kong]: [Government of the Hong Kong Special Administrative Region], [2004]), at http:// www.csb.gov.hk/hkgcsb/doclib/podger-speech-e.pdf.

(19) Kernaghan, "Integrating values into public service," Public Administration Review, p. 711.

(20) Cochrane, "How To Best Develop and Support Ethics Programs. Institute for International Relations Conference, Ottawa, October 3-5, 2000," Public Service Human Resources Management Canada [web site].

(21) [n.a.], "Values and Ethics Code for the Public Service," Public Service Human Resources Management Agency [web site], Chapters 2 and 3. A very useful attempt to catalogue the various rules of conduct for federal public servants is found in Dwivedi and Gow, From Bureaucracy to Public Management, pp. 76-8.

(22) The various components of a full public-sector ethics regime are well set out in [n.a.], "Principles for Managing Ethics in the Public Service. Puma Policy Brief No. 4, May 1998," Organisation for Economic Co-operation and Development [web site] ([Paris]: OECD, [2004]), at http:// www.oecd.org/dataoecd/60/13/1899138.pdf.

(23) Kernaghan and Langford, The Responsible Public Servant, Chapter 8.

(24) [n.a.], "Values and Ethics Code for the Public Service," Public Service Human Resources Management Canada [web site], p. 7.

(25) [n.a.], "The Conflict of Interest and Post Employment Code: Canada's Principle-Based Approach," Organisation for Economic Co-operation and Development [web site] ([Paris]: OECD, [2004]), is a background document provided by the Government of Canada for the Brasilia Forum on Ensuring Transparency and Accountability in the Public Sector, 12 November 2001, at http://www.oecd.org/dataoecd/59/41/2664237.pdf.

(26) Cochrane, "How To Best Develop and Support Ethics Programs. Institute for International Relations Conference, Ottawa, October 3-5, 2000," Public Service Human Resources Management Canada [web site].

(27) Catherine MacQuarrie, "'Creating a Value Based Public Service.' Remarks by Catharine MacQuarrie, Director, Office of Values and Ethics, Treasury Board Secretariat, July 11, 2001," Treasury Board of Canada Secretariat [web site] ([Ottawa]: [Public Works and Government Services Canada], [2004]), at http://www.tbs-sct.gc.ca/veo-bve/speeches/ creatingavaluebasedpublicservice_e.asp.

(28) Kenneth Kernaghan, "Towards a public-service code of conduct--and beyond," CANADIAN PUBLIC ADMINISTRATION 40, no. 1 (Spring 1997), p. 41.

(29) Kernaghan, "Integrating values into public service," Public Administration Review, p. 713.

(30) See D. Zussman and J. Jabes, The Vertical Solitude: Managing in the Public Sector (Halifax: Institute for Research in Public Policy, 1989); Kenneth Kernaghan, "The emerging public service culture: values, ethics and reform," CANADIAN PUBLIC ADMINISTRATION; and G. Julien, "Les valeurs collectives de gestion dans la function publique quebecoise : la perception des cadres," CANADIAN PUBLIC ADMINISTRATION 36, no. 3 (Fall 1993), pp. 319-48.

(31) Canada, Task Force on Public Service Values and Ethics, A Strong Foundation, p. 53 (emphasis added).

(32) In this vein, it would be interesting to discover how the creators of the federal government's "Statement of Public Service Values and Ethics" arrived at the final version of that statement. There was a draft statement put forward and public servants were invited to discuss it online, but there wasn't much participation and the discussion did not seem to have much impact on the final version.

(33) There have been a number of useful efforts made to describe the various cultural divisions that can afflict Canadian public-sector organizations. See, for example, D.J. Savoie, Breaking the Bargain: Public Servants, Ministers and Parliament (Toronto: University of Toronto Press, 2003), pp. 152-59; and Zussman and Jabes, The Vertical Solitude. The task force report itself recognized this problem. See Canada, Task Force on Public Service Values and Ethics, A Strong Foundation, pp. 45-6.

(34) Kernaghan, "The emerging public service culture: values, ethics and reform," CANADIAN PUBLIC ADMINISTRATION, p. 619.

(35) See [n.a.], "The Promise of the O.P.P. (Values and Ethics)," O.P.P. [web site] ([Toronto]: Queen's Printer, [2004]), at http://www.gov.on.ca/opp/organization/english/ promise.htm.

(36) Kernaghan, "The emerging public service culture: values, ethics and reform," CANADIAN PUBLIC ADMINISTRATION, p. 620.

(37) Philip Pettit, "Consequentialism," in Peter Singer, ed., A Companion to Ethics (Oxford: Basil Blackwell, 1991), p. 238.

(38) Will Kymlicka, Contemporary Political Philosophy, 2nd edition (New York: Oxford University Press, 2002), p. 53.

(39) Canada, Task Force on Public Service Values and Ethics, A Strong Foundation, pp. 53-8.

(40) Kernaghan, "The emerging public service culture: values, ethics and reform," CANADIAN PUBLIC ADMINISTRATION, p. 630.

(41) [n.a.], "Values and Ethics Code for the Public Service," Public Service Human Resources Management Canada [web site], pp. 7-10.

(42) Kernaghan, "Integrating values into public service," Public Administration Review, p. 712.

(43) Ibid., p. 717.

(44) Dwivedi and Gow, From Bureaucracy to Public Management, p. 22.

(45) Peter Aucoin, "A profession of public administration?: A commentary on A Strong Foundation," CANADIAN PUBLIC ADMINISTRATION 40, no. 1 (Spring 1997), p. 37; Ian Greene and David P. Shugarman, Honest Politics (Toronto: James Lorimer and Company Publishers, 1997), pp. 22-30.

(46) See E. Lindquist, J. Langford and D. Good, "The Evolution of the Merit Principle." Paper prepared for the B.C. Public Service Employee Relations Commission, 2001.

(47) See T. Pocklington and S. Pocklington, "Aboriginal Political Ethics," in J. Langford and A. Tupper, eds., Corruption, Character and Conduct (Don Mills, Ont.: Oxford University Press Canada, 1993), p. 51.

(48) See W. Powell, "Neither markets nor hierarchy: Network forms of organization," Research in Organizational Behavior 12 (1990), pp. 295-336.

(49) See John Langford, "The Ethics of Alternative Service Delivery." Paper prepared for the OECD Conference on Government Ethics, Paris, November 1997.

(50) Canada, Task Force on Public Service Values and Ethics, A Strong Foundation, p. 30.

(51) Paul Thomas refers to this as the "happy face" model of conflict resolution, in which "you never have to sacrifice one cherished value at the expense of another." Personal communication, 19 February 2004. The auditor general warned the government of this very problem four years ago. See Canada, Office of the Auditor General, Report to the House of Commons, pp. 12.86-12.96.

(52) By way of example, consider the March 2004 "ethics challenge" on the Values and Ethics Branch web site. It poses the following dilemma: Martin believes strongly in rigor in all things. At the office, he does not wantonly waste supplies and he takes great care with equipment. For example, every Friday morning, he dusts his workstation and that of some of his colleagues whom he considers negligent. Addle believes that Martin is going too far and wasting precious, expensive time. She made some pointed comments to this effect. Martin is angry and Addle frustrated. What are the conflicting values? The potential respondent is then given a choice of three possible answers: a) Honesty, economy, respect and civility/courtesy; b) Probity, equity, courage and moderation; c) Resourcefulness, prudence, tolerance and open-mindedness. But the respondent is given no indication of how to "balance" these multiple value sets or how to work out what action might flow from the answer she has chosen.

(53) See R.D. Ellis, Just Results: Ethical Foundations for Policy Analysis (Washington, D.C.: Georgetown University Press, 1998), pp. 12-14.

(54) John Rawls, A Theory of Justice (London: Oxford University Press, 1971), p. 34.

(55) Read the value cluster conflict between the lines of the now famous debate between Sandford Borins and Donald Savoie about the benefits of NPM. See D. Savoie, "What is wrong with the new public management?" CANADIAN PUBLIC ADMINISTRATION 38, no. 1 (Spring 1995), pp. 112-21; and S. Borins, "The new public management is here to stay," CANADIAN PUBLIC ADMINISTRATION 38, no. 1 (Spring 1995) pp. 122-32.

(56) Kernaghan, "Integrating values into public service," Public Administration Review, pp. 713-14.

(57) Savoie, Breaking the Bargain.

(58) See Paul Thomas, "The Changing Nature of Accountability," in B.G. Peters and D.J. Savoie, eds., Taking Stock: Assessing Public Sector Reforms (Ottawa/Montreal and Kingston: Canadian Centre for Management Development and McGill-Queen's University Press, 1998), pp. 348-93.

(59) See Eric Charette, "Glossary of Management Values and Ethics, September 2000," Translation Bureau [web site] ([Ottawa]: [Public Works and Government Services Canada], [2004]), at http://www.translationbureau.gc.ca/pwgsc_internet/en/publications/ documents/ethics.pdf.

(60) Canada, Canadian Centre for Management Development, Building On A Strong Foundation--the Dialogue Continues, Volume 1 (Ottawa: CCMD, 2000), p. 1.

(61) Kernaghan, "The post-bureaucratic organization and public service values," International Review of Administrative Sciences, p. 95; Kernaghan, "The emerging public service culture: values, ethics and reform," CANADIAN PUBLIC ADMINISTRATION, pp. 621-22.

(62) Canada, Task Force on Public Service Values and Ethics, A Strong Foundation, p. 1.

(63) This definition of a public-sector ethical dilemma is adapted from D. Thompson's discussion of moral principles. See D. Thompson, "The possibility of administrative ethics," Public Administration Review 45, no. 5 (September/October 1985), p. 555.

(64) See Greg Pence, "Virtue Theory," in Singer, A Companion to Ethics, Chapter 21.

(65) While there is little formal research on this issue, at least one available study appears to support the prominence of the consequential approach to ethical choice among public servants. See Guido von Grumbkow, De Rede Groep, Jasper von Grumbkow, "The public manager as juggler: balancing with moral dilemmas in varying contexts," Beleidswetenschap (Policy Sciences) 35, 3 (September 2002)." Universiteit Twente [Netherlands]. Abstract was available in English at http://www.bsk.utwente.nl/bw/1997_eng.htm (accessed 23 March 2004).

(66) F.N. Brady, "'Publics' administration and the ethics of particularity," Public Administration Review 63, no. 6 (November/December 2003), p. 526.

(67) See, for example, Kymlicka, Contemporary Political Philosophy, Chapter 2.

(68) Thomas Nagel, "Ruthlessness in Public Life," in Stuart Hampshire, ed., Public and Private Morality (Cambridge: Cambridge University Press, 1987), p. 84; Peter Singer, Practical Ethics (Cambridge: Cambridge University Press, 1979), p. 12.

(69) Brady, "'Publics' administration and the ethics of particularity," Public Administration Review, p. 531; R.E. Goodin, Utilitarianism as a Public Philosophy (Cambridge: Cambridge University Press, 1995), p. 10.

(70) See the references to consequential factors in the case notes in Canadian Centre for Management Development, Building on a Strong Foundation--The Dialogue Continues, volumes I and II.

(71) [n.a.], "Values and Ethics Code for the Public Service," Public Service Human Resources Management Canada [web site], p. 7; Canada, Task Force for Public Service Values and Ethics, A Strong Foundation, p. 41.

(72) Cited in Diane Francis, "The Russians aren't coming," National Post (Toronto), 23 January 2004, FP4.

(73) The auditor general did a preliminary evaluation of the values and ethics initiative (see Canada, Office of the Auditor General, Report to the House of Commons [2000], Chapter 12), but it would be useful to have a more thorough evaluation of the initiative to see what its impact has actually been on the federal public service. The Australian Public Service Commission did an evaluation of its extensive values initiative and the results reflect a number of the concerns I raise in this article. See the [n.a.],"State of the Service Report, 2002-2003, Chapter 3: Embedding the APS Values and Code of Conduct," Australian Public Service Commission [web site] ([Barton, A.C.T.]: Commonwealth of Australia, 2003), at http://www.apsc.gov. au/stateoftheservice/0203/chapter3.htm; and [n.a.], "Embedding the APS Values: Supporting Evidence--Results of Agency Studies, August 2003," Australian Public Service Commission [web site] ([Barton, A.C.T.]: Commonwealth of Australia, 2003), at http://www.apsc. gov.au/values/values6.htm.

(74) Canada, Task Force on Public Service Values and Ethics, A Strong Foundation, pp. 1-3.

The author is professor, School of Public Administration, University of Victoria. He would like to acknowledge with gratitude the generous comments provided by Peter Aucoin, Ted Hodgetts, Ken Kernaghan, Martha Langford, Evert Lindquist, Colin MacLeod, Michael McConkey, Les Pal, Sharon Sutherland, Paul Thomas, and John Uhr. The editor of the Journal, Allan Tupper, and the Journal's anonymous reviewers also provided extremely helpful comments.
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