As the world seems to teeter wildly from one ethically questionable news reel to the next with self-interest squarely at the forefront of recent major geopolitical decisions, it seems fitting to consider: How does this apply to our small corner of the earth – one focused on environment, sustainability and achieving mutually beneficial outcomes for both the companies we work for, and the land we live on?
Furthermore, what happens when projects with significant environmental and social impacts are approved by government with minimal or even no environmental conditions attached? Can we trust the management in charge of these companies to do the right thing, when self-interest (or investor self-interest) is high, and strong moral and ethical environmental leadership is not mandated and explicit, but optional and implied? And if we don’t hold ourselves accountable in these situations, who will?
In recent times we seem to be relying heavily on environmental referral documents and the like, (which are not legally binding), but describe how we intend to proceed with environmental management for these projects. But as the world has seen recently, good intentions can be left by the proverbial roadside when the opportunity to profit presents itself. So, the questions remain, how should a company hold itself to be accountable to our good environmental intentions, and how can the Community or Government be assured that these good intentions will be adopted or the intent addressed to ensure impact is managed?
Approvals in Numbers
Within our WA legal system, under Part IV of the Environmental Protection Act 1986, projects with significant environmental impacts can be referred to the Environmental Protection Authority (EPA) for assessment, either by the proponent or by the public. These referral documents describe the project, the potential impacts and proposed management options, but do not constitute an approval document and are not legally enforceable. The EPA can choose to assess these referrals, with one of the following potential outcomes:
- Decide not to assess the project (at which point the EPA may provide advice to the proponent, but this is also not legally binding).
- Decide to assess the project and completes the assessment report (still not legally binding). Upon completion of the assessment, the EPA may issue a Ministerial Statement allocating conditions under which the project may proceed (section 45 of the Act); this Ministerial Statement however does have legal effect and penalties can apply for non-compliance.
Within the last few years, the number of projects referred to the EPA, the number assessed and the outcomes are shown in the table below:
Between 2023 and 2025 annual reporting years, approximately 25% of referred projects under section 37 of the EP Act were determined not to require assessment (EPA, 2025; EPA, 2024; EPA, 2023), and in 2023-24, the EPA determined that for more than 95% of assessments undertaken, other statutory decision making could mitigate the potential environmental effects (EPA, 2024).
The question then is, given these are projects with potentially significant environmental impacts (sufficient to warrant EPA referral in the first place); are we comfortable that the current level of secondary assessments is sufficient to address these impacts? And if not, when relying mainly on the environmental goodwill of the Companies undertaking the projects, do we trust in the ethical and moral governance of these companies to step up for the environment?
But First, What Exactly are Ethics, and How Do They Guide Us?
The Merriam-Webster dictionary (2026) describes ethics as “an awareness of the moral importance of a specific thing”, and also as “the principles of conduct governing a person or group”. It is not however simply the same as feelings, religion, following the law, or following the cultural norm (Santa Clara University, 2021). Most universities, business institutions and leadership companies discuss ethical decision making and have step by step guides to making ethical decisions which usually involves some version of the following:
- Consider the issue through the ‘lenses’ of interests or rights, justice, utility, common good, virtue and care (Santa Clara University, 2021); and use these in the decision making process which comprises:
- Knowing the facts, identifying the required information, listing the concerns, developing and evaluating possible resolutions, and finally recommending an action (Michigan State University, 2023).
Thus, if people know what to do, then why do some people still not make the right ethical decisions? How do we end up with some of the questionable decisions and practices we have seen in the industry?
According to Lea Strickland (2025), people’s motivations for looking the other way or directly engaging in unethical behaviour can be deeply rooted in their perceptions, attitudes, and worldviews. She identifies the mental range of unethical behaviour as, Naivety, Ignorance, Stupidity, Complicity, and Delusion. Of these, she identifies delusion as perhaps the most dangerous because it involves rationalizing unethical behaviour, making excuses, or persuading others it’s okay. Strikland suggests a delusional person justifies their unethical behaviour through a warped sense of reality and see themselves as above the rules. They often believe they are playing a larger game or justify their actions with an “ends justify the means” mentality (Strickland, 2025).
It is possibly a situation such as this justification of the larger game that led to catastrophic decisions such as the Rio Tinto Juukan Gorge incident (in which 46,000 year old caves with significant Aboriginal Heritage value were destroyed to facilitate mining operations). The Australian Parliamentary Inquiry (Joint Standing Committe on Northern Australia, 2020) into the incident noted:
“Rio [Tinto] knew the value of what they were destroying but blew it up anyway. It pursued the option of destroying the shelters despite having options which would have preserved them. Rio knew of the site’s archaeological significance and its cultural significance to the [Traditional Owners]”.
If, as in this case, we could not rely on the Company to do the right thing, what of the secondary approvals that we also rely on to reduce environmental (and in this case, social) impacts?
Unfortunately, while a good system of law does incorporate many ethical standards, the law can also deviate from what is ethical (Santa Clara University, 2021). In this case, the Parliament also noted:
“Western Australian law played a critical role in the destruction of the shelters. The Aboriginal Heritage Act 1972 has failed to protect Aboriginal Heritage, making the destruction of Indigenous heritage not only legal but almost inevitable” (Joint Standing Committe on Northern Australia, 2020).
This example of the law becoming ethically corrupt— when it becomes a function of power alone and is designed to serve the interests of narrow groups (Santa Clara University, 2021) – suggests that we are back at our original questions, of how can we then trust companies to do the right thing, if neither their own ethical standards or even in some cases legislation, is able to achieve this?
How Can We Measure Trustworthiness?
In recent years with the increased focus on ESG (Environmental, Social, Governance) metrics, many Companies are now following various ESG accreditation systems, which track and rank ESG performance such as the Global Reporting Initiative (GRI) and the Sustainability Accounting Standards Board (ISSB-aligned disclosures). While this data can give an indication of overall year on year ESG performance, it doesn’t necessarily translate directly into community trust, as financial and industry metrics can diverge from community and trust metrics. For example, a company may exhibit good financial returns from an investment perspective but not be strong on ESG performance.
In these situations, ‘trust barometers’ such as Roy Morgan’s Trust/Distrust list, the Reputation Institute’s RepTrak report and Essential Media’s Trust and Integrity polls can indicate community and stakeholder perceptions. Governments, NGO’s and other stakeholders such as a researchers use these polls demonstrate social licence to operate, guide policy decisions and in strategic communications.
Following the Juukan Gorge incident, Rio Tinto was listed as #6 in the Roy Morgan (2021) Top 10 Most Distrusted Brands list, showing public support for the company was low, and the reputational damage done by its unethical practices was playing out in public perception polls.
While we could use these trust barometers as indicators of how trustworthy we consider companies to be, in the end, we are still at the mercy of individual company leadership decision makers and the existing legislation and approval system. And even if an organisation has received low trust rankings, companies are still eligible to receive EPA and other approvals when they meet the current requirements for such instruments, as trust level is not a discriminating factor in the environmental approval process and low social trust does not preclude future approvals. So where do we stand on being able to trust?
When to Trust
The leadership and business development ‘industry’ is full of handy acronyms, or snappy word alliterations classifying trustworthiness in businesses and people, such as Chief Executive’s 5 Cs of Trust (Care, Communication, Character, Consistency, and Competence) (Grovue & Watson, 2022); or Deloitte’s (Deloitte, 2022) Four Factors of Trust (being Humanity, Capability, Transparency and Reliability). David Maister, Charles Green and Robert Galford (Maister, Green, & Galford, 2021) in their book even have a formula for trust, which consists of Credibility (the words we speak, can they be believed) + Reliability (the actions we take and do they meet expectations) + Intimacy (a level of human connection and understanding)/ Self Orientation (whether we are focused on ourselves or others) = Trust (Trusted Advisor Associates, 2026).
From this perspective then, whether we can trust a company to implement its good environmental intentions for managing potentially significant environmental impacts (whether as stated in a referral document) or outlined in a legally binding instrument, seems to largely depend on whether they ‘walk the talk’ in the many small, incremental opportunities for credibility and reliability in the everyday management actions. This credibility and reliability is shown in the quality of the management measures and environmental outcomes proposed in their environmental management systems and approval documents. Those that have high levels of integrity and good corporate culture with the small things and do the small things well, are more likely to build trust for the effective management of the bigger issues.
So while there may be no straight answers for the questions around trust, ethics and integrity that opened this Insight, by doing the small things well, a Company is more likely to maintain their social licence to operate and gain the trust of the community and industry even if the approvals and legislative system surrounding their activities is not as strong or effective as it could be.
Subsequently, if you would like assistance with developing credible, reliable environmental measures and outcomes for your environmental, social or heritage approval documents or management systems, contact Integrate Sustainability on 08 9468 0338, or email enquiries@integratesustainability.com.au to see how we can help.
ISPL- ENVIRONMENT VS SELF INTEREST – Where do we stand in the current regulatory framework?- PDF
References
Deloitte. (2022, August 26). Enterprise Trust . Retrieved from Deloitte.com : https://www.deloitte.com/an/en/issues/trust/four-factors-of-trust.html
EPA. (2023). Annual Report 2022-23. Perth, Western Australia: Environmental Protection Authority.
EPA. (2024). Annual Report 2023-24. Perth, Western Australia: Environmental Protection Authority.
EPA. (2025). Annual Report 2024-25. Perth, Western Australia: Environmental Protection Authority.
Grovue, A., & Watson, M. (2022, April 27). The 5 Cs of Trust. Retrieved from Chief Executive.net: https://chiefexecutive.net/the-five-cs-of-trust/
Joint Standing Committe on Northern Australia. (2020). Never Again – nquiry into the destruction of 46,000 year old caves at the Juukan Gorge in the PIlbara Region of Western Australia, Interim Report. Canberra, ACT: Parliament of the Commonwealth of Australia. Retrieved from https://parlinfo.aph.gov.au/parlInfo/download/committees/reportjnt/024579/toc_pdf/NeverAgain.pdf;fileType=application%2Fpdf?afd_azwaf_tok=eyJraWQiOiI0QkFCNDRENzg3N0FBQkE3OTY1RkJEMkVCNEQ3NUZCRkQ2QjdCRkVFOThEMkFBRkM0ODZGQTMzNEYyQzVBNzlBIiwiYWxnIjoiUlMyNTYif
Maister, D. H., Green, C. H., & Galford, R. M. (2021). The Trusted Advisor (20th Anniversary Edition). New York: Free Press.
Merriam-Webster. (2026, January 18). Ethic. Retrieved from Merriam-Webster.com Dictionary: https://www.merriam-webster.com/dictionary/ethic#did-you-know
Michigan State University. (2023, June 16). 6-Step Guide to Ethical Decision Making. Retrieved from Michigan State University: https://www.michiganstateuniversityonline.com/resources/leadership/guide-to-ethical-decision-making/
Roy Morgan. (2021, February 3). Press Release – It’s official: Supermarkets are the most trusted brands in Australia. Finding #8628. Retrieved from Roy Morgan.com: https://www.roymorgan.com/findings/its-official-supermarkets-are-the-most-trusted-brands-in-australia?
Santa Clara University. (2021, November 8). A Framework for Ethical Decision-Making. Retrieved from Santa Clara University Marrkula Centre for Applied Ethics: https://www.scu.edu/ethics/ethics-resources/a-framework-for-ethical-decision-making/
Strickland, L. (2025, April 16). Five Mental States of Unethical Behaviour. Retrieved from Focus Resources Inc.com: https://www.focusresourcesinc.com/five-mental-states-of-unethical-behavior/
Trusted Advisor Associates. (2026, January 28). Understanding the Trust Equation. Retrieved from Trusted Advisor.com: https://trustedadvisor.com/build-trust/trust-equation