The core substantive concepts populated through Schedule 1 are legal and behavioural duties for councillors, expressed as mandatory obligations, discretionary judgments and procedural immediacies. The Schedule organises the code around eight focal concepts.

1. Decision making. Councillors must approach decisions with an open and unprejudiced mind and make decisions solely on merit, not taking irrelevant matters into account. The code requires genuine and impartial consideration of all relevant information known or reasonably available to the councillor, see Schedule 1 Part 1 cls 1-4. The operative tests are factual: "open and unprejudiced", "free from personal bias or prejudgement" and "solely on merit".

2. Non‑pecuniary conflicts of interest. The code requires councillors to avoid being unduly influenced by personal or private interests and to declare actual, potential or perceived conflicts at meetings, workshops and meetings of bodies to which they are appointed, see Schedule 1 Part 2 cls 1, 3 and 6. Councillors must act openly and honestly in the public interest, and to exercise reasonable judgement about whether a conflict requires leaving the room during discussion, using a "reasonable person" benchmark, see Part 2 cls 2, 4 and 6(b). The code expressly states that Part 2 does not apply to pecuniary interests, so pecuniary interest rules are excluded from this Part, see Part 2 cl 7.

3. Use of office. The code prohibits councillors from bringing the council or office into disrepute and from using their office to influence others improperly to gain an undue or unauthorised benefit or detriment, see Schedule 1 Part 3 cls 1-3. It also prohibits councillors, in personal dealings with the council, from expecting preferential treatment.

4. Use of resources. Councillors must use council resources appropriately and not for private purposes except as permitted by council policies and procedures. The code also requires that councillors do not allow others to misuse council resources, see Schedule 1 Part 4 cls 1-3.

5. Use of information. Access to council information is limited to what is needed to perform councillor duties. Release of council information must be in accordance with established council policies and relevant legislation, see Schedule 1 Part 5 cls 1-2. These provisions anchor information use to council procedural rules and statutory compliance.

6. Gifts and benefits. The code permits acceptance of gifts only if they directly relate to carrying out public duties, are appropriate in the circumstances and are not contrary to relevant legislation. It also instructs councillors to avoid situations where gifts might reasonably be seen as securing influence, see Schedule 1 Part 6 cls 1-2.

7. Relationships and conduct. Councillors must treat persons fairly, avoid causing offence or embarrassment to a reasonable person and must not bully or harass. They must listen to other councillors and focus on issues rather than personalities. There are restrictions on contacting contractors, tenderers and council employees without appropriate authorisation, see Schedule 1 Part 7 cls 1-5.

8. Representation. Councillors must accurately represent council policies and decisions, must not speak on behalf of the council unless authorised by the mayor, must indicate when views are personal and must not express personal views publicly in a manner that undermines council decisions or brings the council into disrepute, see Schedule 1 Part 8 cls 1-7. Councillors appointed to external bodies must understand the basis of appointment and be aware of attached legal and ethical responsibilities, see Part 8 cl 8.

Cross‑cutting concepts include reliance on council policies and procedures (for use of resources, information and external contacts), use of standard objective benchmarks ("reasonable person", "reasonable judgement") and exclusion of pecuniary interest rules from Part 2. The order establishes a textual standard but leaves several key interpretive and operational details to local policy and the Act via the statutory reference in s 4 and the interpretive application of the Acts Interpretation Act 1931 in s 3(2).

The order explicitly affects councillors by identifying the Schedule 1 text as the code of conduct relating to councillor conduct for the purposes of the Act, see s 4 and Schedule 1 title. The obligations in Schedule 1 employ the second person singular "A councillor must" and "A councillor must not", which signals direct application to individual officeholders across the state's local government entities that operate under the Act and the declared code.

Beyond councillors, the order creates interaction points with other actors and officeholders who will have roles that affect compliance and operationalisation:

• The mayor. The code restricts who may speak on behalf of the council and assigns the mayor the exclusive power to authorise a councillor to speak for the council, see Schedule 1 Part 8 cl 3. That places the mayor in a gatekeeper role for official representation.

• The general manager. Councillors are prohibited from contacting council employees in relation to council matters unless authorised by the general manager, see Schedule 1 Part 7 cl 4. This assigns the general manager administrative control over councillor-employee communications.

• Councils themselves (corporate entities). Multiple clauses require actions "in accordance with established council policies and procedures" or allow exceptions "as provided by council policies and procedures" (for example, Schedule 1 Part 4 cl 2; Part 5 cl 2(a); Part 6 cl 1(c)). That imports councils as decisionmakers about permissible resource use, information release and gift administration.

• External bodies, contractors and tenderers. The code restricts councillor contact with contractors or tenderers without appropriate authorisation, see Schedule 1 Part 7 cl 3. This impacts councillors’ engagement with market participants.

• The Department of Premier and Cabinet. The source notes that the instrument is administered by that Department. While administration does not itself define enforcement mechanisms in the order, it signals which department will handle instrument-level matters, see final line.

The code also interacts with statutory frameworks external to this order. The order makes the code subject to "relevant legislation" in several places (for example, Schedule 1 Part 5 cl 2(b); Part 6 cl 1(c)). The interpretive statement in s 3(1) defines "Act" to mean the Local Government Act 1993. The order also instructs that the Acts Interpretation Act 1931 applies to its interpretation as if it were by‑laws, see s 3(2). These references create a legal matrix where councillor duties sit within the Act, council policies and other statutory obligations.

Who pays and who bears the operational cost. The immediate compliance cost and behavioural adjustment burden fall on councillors and councils. Councils must adopt operational policies and procedures (for information, resource use, authorisations, gift handling and training) to implement the code’s requirements. The order itself does not allocate funding or prescribe administrative structures; those are local council responsibilities to resource. Councils therefore bear administrative costs associated with training, policy drafting, authorisation registers, conflict declaration procedures and potential disciplinary proceedings, to the extent those arise under the Act or local policy.

The order sets out mandatory behavioural duties for councillors and identifies discrete decision rights and procedural prerogatives held by the mayor and the general manager. The duties are largely found in Schedule 1 and are phrased as "must" or "must not". Rights are limited and specific.

Key duties

• Open, impartial decision making: Councillors are required to bring an open and unprejudiced mind to decisions, make decisions free from personal bias or prejudgement and to make decisions solely on merit while not taking irrelevant matters into account, see Schedule 1 Part 1 cls 1-4. These are duties of mental approach and evidentiary consideration when participating in council decision processes.

• Disclosure and management of non‑pecuniary conflicts: Councillors must declare actual, potential or perceived non‑pecuniary conflicts at formal council meetings, workshops and meetings of appointed bodies, act openly and honestly in the public interest and exercise reasonable judgement to determine whether to withdraw from participation. The test for withdrawal is whether a reasonable person would consider that leaving the room is required, see Schedule 1 Part 2 cls 1-6. Notably, this Part excludes pecuniary interests, see Part 2 cl 7.

• Use of office restrictions: Councillors must not bring the council or the office into disrepute, must not seek to use office to secure unduly preferential treatment or detriment for themselves or others, and in personal dealings with the council must not expect preferential treatment, see Schedule 1 Part 3 cls 1-3.

• Use of resources and information: Councillors must use council resources appropriately and only for public duties except where council policies allow otherwise; must not allow others to misuse resources; may access council information only as needed for duties; and must release information only in accordance with council policies and relevant legislation, see Schedule 1 Parts 4-5.

• Gifts and benefits: Councillors may accept gifts only where directly related to carrying out public duties, appropriate to the circumstances and not contrary to relevant legislation; they must avoid appearances that gifts procure influence, see Schedule 1 Part 6 cls 1-2.

• Conduct towards people and third parties: Councillors must treat persons fairly, avoid causing offense to a reasonable person, not bully or harass, and focus on issues rather than personalities. They must not contact or instruct a contractor or tenderer without authorisation and must not contact a council employee regarding council matters unless authorised by the general manager, see Schedule 1 Part 7 cls 1-4. They must also avoid conduct constituting "prohibited conduct" as referenced in Part 7 cl 5.

• Representation and public statements: Councillors must accurately represent council policies and decisions when providing information to the community, must not speak for the council without mayoral authorisation, and must indicate when a view is personal. Personal views must not be expressed publicly so as to undermine council decisions or bring the council into disrepute. Appointed external representatives must understand the basis of their appointment and the responsibilities attached, see Schedule 1 Part 8 cls 1-8.

Specific decision rights and delegations

• Mayoral authorisation to speak on behalf of the council. The mayor is the locus for authorising official spokespersons, see Schedule 1 Part 8 cl 3.

• General manager control over employee contact. The general manager determines authorisation to contact council employees in relation to council matters, see Schedule 1 Part 7 cl 4.

Limitations, qualifications and cross‑links

• Council policies and relevant legislation qualify many duties. Examples include use of resources (Part 4 cl 2), release of information (Part 5 cl 2(a)-(b)), and acceptance of gifts (Part 6 cl 1(c)). Councils therefore provide the detailed procedural contours for several obligations.

• The reasonable person and reasonable judgement tests create standards that are fact and context dependent. For example, whether a councillor should leave the room is measured by what "a reasonable person would consider", see Schedule 1 Part 2 cl 6(b).

• Exclusion of pecuniary interests from the conflicts Part signals that pecuniary interest obligations are governed by a different legal regime not restated in this order, see Schedule 1 Part 2 cl 7.

Rights created by the order are limited. The order grants none of the usual civil or property rights; it articulates obligations and confers procedural authorisation roles on the mayor and general manager. The code does not itself create a private right of action, nor does it prescribe internal enforcement procedures or penalties; those matters must be located in the Act and council governance frameworks that implement enforcement of codes declared under s 28R(1) of the Act, see s 4. Councillors therefore gain clarity on behavioural expectations but not new statutory enforcement remedies within this instrument.

The order does not contain express penalty provisions or a detailed enforcement regime. It declares Schedule 1 as the code of conduct "for the purposes of section 28R(1) of the Act", see s 4. The order therefore supplies the substantive text of a model code but does not itself prescribe sanctions, investigation procedures, complaint mechanisms, disciplinary processes or appeal routes. Because the order is to be read alongside the Act, enforcement will depend on the mechanisms the Act provides and on the operational policies and procedures that each council adopts under its powers; the order itself is silent on the specific sanctioning steps and the factual thresholds for disciplinary measures.

Practical consequences of the absence of penalties in the order

• Enforcement dependency on the Act and local rules. The code’s legal effect is as the text of the code for s 28R(1) purposes. Any enforcement, sanctioning or remedial action must therefore proceed under the Act or council governance rules that implement the Act‑based obligations. The order does not set out those mechanisms.

• Evidence and proof standards are not specified. The Schedule uses evaluative standards such as "reasonable judgement" and whether "a reasonable person would consider" a councillor should leave the room, see Schedule 1 Part 2 cls 4-6. The order does not set evidence standards, leaving investigatory procedures and proof burdens to other instruments.

• Discretion for councils and administrators. Councils will need to specify complaint-handling procedures, investigation protocols, evidence rules, and penalties or sanctions consistent with their statutory powers and the Act. The order requires councils to have policies in place for authorisation and for permitted exceptions in resource and information use, but it does not bind councils to particular enforcement outcomes, see Schedule 1 Parts 4-5.

Where enforcement features are alluded to in the code

• Some clauses impose immediate procedural duties that are easily enforced as factual matters, for example the duty to declare conflicts at meetings and workshops and to indicate the nature of the interest before discussion begins, see Schedule 1 Part 2 cl 6(a). Compliance with these procedural declarations is objectively determinable from meeting minutes and workshop records.

• Other duties are conduct standards that are context dependent and therefore harder to enforce without procedural frameworks. Examples include "must not bring the council into disrepute", "must not cause a reasonable person offence or embarrassment" and "must not bully or harass", see Schedule 1 Parts 3 and 7. Enforcement of these provisions requires councils or tribunals to apply subjective or quasi-objective standards.

Administrative and practical enforcement actors

• Councils will be the front line for procedural enforcement because several clauses require adherence to council policies and authorisations, e.g. the general manager’s authorisation to contact employees (Schedule 1 Part 7 cl 4) and the mayor’s authority to authorise spokespersons (Part 8 cl 3). Councils must therefore create or maintain administrative mechanisms to authorise contacts and spokespeople.

• The Department of Premier and Cabinet administers the order at instrument level, but the source does not allocate any investigative or sanctioning functions to that Department in relation to enforcement of councillor conduct under the code.

Consequences for legal practitioners and compliance officers

• Research into enforcement must go beyond this order. To identify applicable sanctions, remedies and procedures for breach, lawyers and compliance professionals must consult the Act (the Local Government Act 1993) and any local government policies and procedures that councils adopt pursuant to the Act and the code.

• Records and governance architecture will be decisive. Because the code relies on factual determinations (for example, declaring conflicts, leaving the room, authorisation to contact employees/contractors), councils should maintain meeting records, conflict registers and authorisation registers to enable objective enforcement and defence against allegations of non‑compliance.

In short, the order supplies the normative text and mandates disclosure and behavioural duties but leaves the punitive and remedial architecture to other instruments and local administrative processes. The order’s silence on penalties is material for planners of compliance and enforcement.

The order is explicitly framed to operate within the broader statutory and administrative framework. Section 3(1) provides a definition point: "Act" means the Local Government Act 1993. Section 3(2) instructs that the Acts Interpretation Act 1931 applies to interpretation of the order as if the order were by‑laws. Section 4 declares the Schedule 1 code to be the code of conduct for councillors "for the purposes of section 28R(1) of the Act". Those three provisions anchor the order’s legal interactions.

Direct statutory interactions

• Local Government Act 1993. The code is declared to be the code for s 28R(1) purposes; therefore the Act is the primary statutory frame for enforcement and operation. The order supplies content but the Act will provide legal mechanisms, definitions and possibly penological provisions governing councillor conduct and consequences for breaches. The order does not restate or replace other statutory duties or rules contained in the Act.

• Acts Interpretation Act 1931. Applying that Act "as if this order were by‑laws" impacts interpretive approaches, such as how terms are construed, how commencement and repeal are handled and potentially how powers are read. That direction to treat the order like by‑laws means councils and decisionmakers will need to apply by‑law interpretive principles when construing or operationalising the code.

Dependencies on council policies and other legislation

• Council policies and procedures. Several clauses require or permit action "in accordance with established council policies and procedures" and allow exceptions "as provided by council policies and procedures", see Schedule 1 Part 4 cl 2, Part 5 cl 2(a), Part 4 cl 2. This creates an interaction where the code’s applicability and limits are partly defined by locally adopted policies. Councils must therefore ensure their policies align with the code and with statutory obligations.

• "Relevant legislation." The code refers repeatedly to compliance with "relevant legislation" in specific contexts such as gifts and information release, see Schedule 1 Part 5 cl 2(b) and Part 6 cl 1(c). That phrase imports other applicable statutes (for example records, privacy, anti‑corruption or conflict of interest statutes), but the order does not list them. Users must map those applicable regimes themselves, guided by the fact that the code expressly defers to legislative requirements.

Scope limitations and exclusions

• Pecuniary interests. The order’s Part 2 explicitly excludes pecuniary interests from the non‑pecuniary conflicts Part, see Schedule 1 Part 2 cl 7. That division indicates that pecuniary interest regulation is governed elsewhere, typically the Act or other statutory instruments. Practitioners must therefore treat pecuniary interest obligations as a separate compliance track.

• Revocation of prior model codes. Schedule 2 revokes earlier model code instruments, namely the 2016 and 2018 orders. That revocation removes potential parallel model provisions and indicates that the new text supersedes the prior model codes, see s 5 and Schedule 2. Councils and practitioners must therefore ensure they apply the new Schedule 1 content rather than relying on now‑revoked instruments.

Operational interactions

• Mayor and general manager authorisations. The code assigns specific operational roles to the mayor (authorising who speaks on behalf of the council, Schedule 1 Part 8 cl 3) and the general manager (authorising contact with employees, Part 7 cl 4). These internal governance interactions will be exercised under the council’s delegation and employment frameworks. Councils will need to reflect these role limits in delegation registers and internal protocols.

• Records and meeting governance. Several duties are procedural and rely on council meeting practices, such as the requirement to declare a conflict "before discussion of the matter begins", see Schedule 1 Part 2 cl 6(a). This creates an interface with council standing orders, minutes practices and workshop governance, which must permit and record declarations.

Interpretive consequences

• Reasonableness standards. The code repeatedly uses standards like "reasonable judgement" and "reasonable person". Courts, tribunals and governance bodies interpreting these standards will likely import ordinary legal constructions of those phrases, but this order itself does not define them. The Acts Interpretation Act 1931 will guide statutory construction, but the local context and council policies will inform application.

In sum, the order is structural rather than standalone. It integrates with the Act, is to be interpreted as a by‑law under the Acts Interpretation Act 1931, defers operational detail to council policies and defers pecuniary interest regulation to other statutory instruments. Anyone advising on compliance or enforcement must read the order together with the Act, local council policies and other relevant legislation.

The instrument’s own amendment history is limited to revocation of previous model code orders and its date of notice. The order revokes the Local Government (Model Code of Conduct) Order 2016 (No. 23 of 2016) and the Local Government (Model Code of Conduct) Amendment Order 2018 (No. 88 of 2018), see s 5 and Schedule 2. The revocations are explicit and recorded in Schedule 2.

The order contains no internal amendment clauses and does not record any prior amendments to itself. The only temporal marker supplied in the source is that the order was notified in the Gazette on 10 September 2024 and that it takes effect on the day its making is notified in the Gazette, see s 2 and the Gazette notation at the end of the source. The short title is fixed as the Local Government (Code of Conduct) Order 2024, see s 1.

Because the Acts Interpretation Act 1931 applies as if the order were by‑laws, any future amendments would likely follow the statutory process for by‑laws or secondary instruments as regulated by the Acts Interpretation Act and the Rules Publication Act 1953, which is referenced only in the Gazette display and numbering note in Schedule 2. The order itself does not set out an amendment mechanism, transitional provisions, or saving clauses.

Practically, the revocation of the 2016 and 2018 instruments indicates a legislative reset to the Schedule 1 code text. Councils and practitioners should therefore treat Schedule 1 as the governing model code as of the instrument’s commencement date and, unless the order is later amended, the text stands as the operative code for s 28R(1) purposes.

No other amendment history, marginal notes or transitional arrangements are provided in the source.

The source contains no litigation history. It does not cite any judicial decisions, tribunal findings or legal disputes concerning the order, Schedule 1 or the revoked instruments. The document names no cases. The absence of litigation history in the instrument means that, as far as this source shows, there is no reported judicial characterisation or interpretation of the Schedule 1 text reflected in the order itself.

For practitioners seeking precedent or clarified interpretive positions, that absence implies two clear tasks. First, they must consult the Local Government Act 1993 and any relevant judicial or tribunal decisions that address s 28R or comparable code enforcement mechanisms, because enforcement under this code will depend on the Act and on how courts or tribunals have previously treated councillor conduct and conflicts. Second, because the order directs that the Acts Interpretation Act 1931 apply as if the order were by‑laws, any litigation or review will likely require attention to by‑law interpretation principles and to whether local policy instruments invoked under this code are consistent with the Act.

If a practitioner requires cases that specifically construe the provisions now contained in Schedule 1, the source does not supply them and further research outside this instrument is necessary. The order itself is a model code instrument and does not carry an attached litigation narrative within the provided text.

Several features of the order are easy to overlook but significant for compliance and risk assessment.

1. The code distinguishes non‑pecuniary conflicts from pecuniary interests and explicitly excludes pecuniary interests from Part 2. Schedule 1 Part 2 cl 7 states that Part 2 does not apply to a pecuniary interest. That creates a two‑track system: non‑pecuniary conflicts are governed by Schedule 1 Part 2 while pecuniary interests are governed separately, presumably under the Act or other instruments. Practitioners must not assume that a declared non‑pecuniary conflict discharges pecuniary interest obligations or vice versa.

2. The code frequently defers to "council policies and procedures." Several prohibitions and permissions are qualified by exceptions or directions to act in accordance with council policies (for example Schedule 1 Part 4 cl 2; Part 5 cl 2(a); Part 6 cl 1). If a council has weak, ambiguous or outdated policies, councillors may have unclear permissible conduct paths. Councils should actively align local policies with the Schedule 1 text; councillors cannot rely on the model code alone to answer operational questions like acceptable use of IT, permitted gifts or authorised contact.

3. Many standards are evaluative and fact dependent. The code uses phrases such as "reasonable judgement", "a reasonable person would consider", "appropriate in the circumstances" and "must not bring the council into disrepute" (for example Schedule 1 Part 2 cls 4-6; Part 6 cl 1(b); Part 3 cl 1). These standards offer flexible governance but increase legal uncertainty. When allegations arise, adjudicators will need to apply fact‑specific reasonableness tests; absence of detailed thresholds risks inconsistent outcomes unless councils provide precise policy guidance.

4. Procedural duties are time‑sensitive. The code requires that a councillor with a conflict "declare the conflict of interest and the nature of the interest before discussion of the matter begins", see Schedule 1 Part 2 cl 6(a). Failure to make that declaration at the correct procedural moment may have consequences that depend on how the Act and council policy structure rectification or sanctions. Councillors and meeting chairs must be vigilant to create auditable meeting records showing timely declarations.

5. Controls on communications with employees and contractors. Schedule 1 Part 7 cl 3 prohibits contacting or issuing instructions to a council contractor or tenderer without appropriate authorisation; cl 4 forbids contacting employees in relation to council matters unless authorised by the general manager. These provisions can constrain councillors’ stakeholder engagement and may require visible authorisation systems. Failure to obtain authorisation can turn routine enquiries into breaches in the absence of good policy.

6. Gifts rules are permissive but unspecified. Part 6 cl 1 allows acceptance of gifts if they "directly relate" to public duties and are "appropriate", yet it does not set monetary thresholds, reporting requirements or registers. Many local governments operate gift registers; the model code assumes councils will adopt policy detail. Without local thresholds or registers, councillors and administrators face judgment calls that can create perceptions of impropriety.

7. Representation restrictions concentrate authorisation in the mayor. Part 8 cl 3 permits only the mayor to authorise a councillor to speak on behalf of the council. Councillors who communicate externally without mayoral authorisation risk breaching the representation rules, particularly when communications could be interpreted as official council positions.

8. The order does not itself describe sanctions or complaint routes. The Schedule’s many "must" and "must not" obligations create expectations without articulating enforcement paths. Practitioners must map the enforcement landscape by reference to the Act and council governance documents.

9. Interpretation as if by‑laws. Section 3(2) requires application of the Acts Interpretation Act 1931 as if the order were by‑laws. That has consequences for statutory construction and possibly for judicial review, but the source does not elaborate the precise interpretive effect. Counsel should take care when framing legal arguments to account for by‑law treatment.

10. Revocation can create transitional confusion. While Schedule 2 revokes model code instruments from 2016 and 2018, the order does not set transitional arrangements for ongoing investigations, existing gift registers, or existing policies aligned with the prior model codes. Councils must manage transition carefully to avoid gaps in governance.

These "gotchas" underline that compliance is not automatic upon reading the Schedule 1 text. Councils must translate the model code into detailed policies, registers, authorisation workflows and training to operationalise the evaluative standards and procedural obligations the order introduces.

Councils and councillors should adopt a practical implementation plan that converts the model code’s aspirational and evaluative standards into auditable procedures. The following steps align directly with the text of the order and indicate where local policy and administrative practice should fill gaps.

1. Adopt or update council policies and procedures. The Schedule repeatedly defers to council policies for exceptions and authorised uses (for example Schedule 1 Part 4 cl 2; Part 5 cl 2(a); Part 6 cl 1(c)). Councils should ensure their policies on use of resources, information release, gifts and benefits, and communications explicitly implement the Schedule 1 standards, including monetary thresholds for gifts, reporting obligations, and permitted exceptions.

2. Create a conflicts declaration and management system that separates pecuniary and non‑pecuniary streams. Because Schedule 1 Part 2 excludes pecuniary interests (Part 2 cl 7) but requires declarations of non‑pecuniary conflicts at meetings and workshops (Part 2 cl 3 and 6(a)), councils should maintain separate registers and procedural scripts. Meeting procedures should require declaration "before discussion of the matter begins" and record the nature of the interest and whether the councillor withdrew, see Part 2 cl 6(a)-(b).

3. Document "reasonable person" and "reasonable judgement" guidance. The code uses those tests (Schedule 1 Part 2 cls 4-6). Councils should provide guidance examples and training on applying the "reasonable person" test so councillors can consistently determine when to withdraw from a discussion and when their conduct meets the standard.

4. Establish an authorisation register for contact with employees and external parties. Schedule 1 Part 7 cl 4 requires general manager authorisation to contact employees; cl 3 requires authorisation for contacting contractors or tenderers. Set up a written authorisation process (who may approve, scope of authorisations, expiry dates) and maintain a publicly accessible register of authorised contacts where appropriate.

5. Consolidate representation and spokesperson policies. Because Part 8 cl 3 grants the mayor the exclusive authorisation to permit councillors to speak on behalf of the council, councils should publish a delegation or authorisation protocol indicating which topics or events require mayoral authorisation, the process to seek it and notification requirements when authorisations are granted.

6. Implement a gifts register and reporting workflow. Part 6 cl 1 requires gifts be directly related to public duties and appropriate in the circumstances and not contrary to legislation. Councils should set thresholds, reporting timeframes, review processes and disposal rules so councillors can readily determine permissibility and register accepted gifts.

7. Strengthen meeting minute practices. Because the code requires declarations "before discussion of the matter begins" and other procedural acts, councils should ensure minutes and workshop notes record declarations, withdrawal times and any authorisations. Accurate records create an evidentiary trail for compliance and dispute resolution.

8. Provide mandatory training for councillors and senior staff. Training should cover the code’s obligations (decision making standards, conflicts management, use of resources, information release, gifts and representation), how to apply evaluative standards, and the council’s policy and authorisation processes.

9. Align employment and HR policies with communication controls. The general manager’s authorisation over employee contact (Part 7 cl 4) should be reflected in HR protocols so staff know they need supply authorisations and how to record any councillor communications that arise outside the authorised channels.

10. Integrate code compliance into the council’s governance framework. The code provides normative content but not enforcement steps. Councils should define complaint intake procedures, investigation protocols, sanctions consistent with the Act and the council’s delegation powers, appeal or review options and periodic reporting on compliance, including anonymised statistics if appropriate.

11. Review and update procurement and contractor engagement policies. Because councillors must not contact contractors or tenderers without authorisation (Part 7 cl 3), procurement policies should define permissible councillor engagement,whether limited to public consultation events or through formal channels,and make those limits public to contractors and tenderers.

12. Coordinate with legal counsel on interplay with pecuniary interest laws. Given the explicit exclusion of pecuniary interests from Part 2 (Part 2 cl 7), councils and councillors should seek legal guidance to ensure parallel compliance with the Act’s pecuniary interest provisions, with clear checklists provided to councillors.

13. Publish the code and local implementing policies prominently. Making the model code and the council’s operational policies accessible supports transparency and reduces the risk of inadvertent breaches. Councillors should be required to acknowledge receipt and understanding of the code and local policies as part of induction and on a periodic basis.

14. Prepare for transition from revoked instruments. The order revokes the 2016 and 2018 model codes (s 5 and Schedule 2). Councils must map any outstanding issues, investigations or registers that were established under the old instruments and effect orderly transition to the new model code and local policies.

15. Maintain a compliance audit trail. Regular internal audits or reviews should test compliance with conflict declaration practices, gift registers, authorisation processes and accuracy of public representations, with remediation plans for identified gaps.

These steps translate the Schedule 1 obligations into operational tasks. They allocate costs to councils (policy drafting, training, registers, audits) and require councillors to change behaviours (declarations, authorisation-seeking, restraint in contacting staff and contractors, careful representation). Because the code’s enforcement framework is not self‑contained, councils must ensure their procedural and sanction regimes under the Act are robust and aligned with the code’s standards.