Circular Number 2019-11
Issue date: 12 August 2019
Application: All Victorian public sector employers
Resources Engaging with Lobbyists: Guidance for Victorian public sector employees (DOCX, 110KB)
Enquiries:  Victorian Public Sector Commission

Key points

  • Victorian public sector employees consult with the community to inform public policies and the delivery of Government programs. In the performance of their duties, VPS employees may come into contact with professional lobbyists seeking to influence Government decisions.
  • Employees of the public sector have a clear responsibility under the Code of Conduct for Victorian Public Sector Employees and also the Victorian Professional Lobbyists Code of Conduct when engaging with lobbyists.
  • Public sector employees must be aware of their obligations in conducting themselves with integrity, impartiality and transparency where they are party to lobbyist engagement. Further, there are specific obligations that an employee must not knowingly or intentionally be party to lobbying conducted by a lobbyist who is not registered.
  • Lobbyists must be registered and meet appropriate integrity standards. The Register of Lobbyists is maintained by the Victorian Public Sector Commission (VPSC). It is the obligation of the public sector employee to ensure that they are interacting with an appropriately registered lobbyist.


The VPSC has created a guide titled Engaging with Lobbyists – Guidance for Victorian Public Sector Employees. This guide assists Victorian public sector employees understand and comply with their responsibilities under the respective codes of conduct.

Read the lobbyist guidance material


Public sector employers and their employees must be aware of the obligations that are placed upon them by the Victorian Government Professional Lobbyists Code of Conduct (Lobbyist Code) (PDF, 96KB) and the Code of Conduct for Victorian Public Sector Employees (Code of Conduct) (PDF, 259KB) where they engage with lobbyists. Ensuring these obligations are met is essential to maintaining public trust in Government and ensures transparency, integrity and honesty.

Employees are required to ensure that they are meeting with an appropriately registered lobbyist and must decline meetings or other contact with lobbyists if they are not listed on the Register. Employees are also required to not engage with lobbyists who do not provide information about their clients or their involvement in a government tender process.

Public sector employers may wish to develop guidelines that further clarify and support the two codes, including the requirements and situations that are specific to their workplace. The VPSC strongly encourages public sector employers in frequent contact with lobbyists to take this approach in developing additional materials.

It is important that Departments also promote the obligations when dealing with lobbyists to the public entities in their portfolio.


The Lobbyists Code applies to public officials including public sector employees through:

  • Premier’s Circular No 2013/1: Victorian Government Professional Lobbyist Code of Conduct and Register of Lobbyists; and
  • The public sector codes of conduct (The three codes issued by the VPSC for employees, employees of special bodies and directors).

Under section 66 of the Public Administration Act 2004, the VPSC must maintain a public Register in accordance with the Lobbyist Code.


The Guide applies to Victorian public sector employees and public sector bodies. The Guide provides context and clarifies the codes that are binding on Victorian public sector employers and employees. Adoption of this Guide will ensure consistency across the public sector and guide a uniform approach to lobbyist engagement while safeguarding public trust in Government.

Date of application

The Engaging with Lobbyists: Guidance for Victorian public sector employees was published on 12 August 2019.