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This paper considers two specific difficulties in developing a code of ethics for the public sector, the contested nature of the values to be expressed in a code of ethics and the organisational demands of a corporate managerialist framework which uses performance indicators. Using the example of the Western Australian public sector code of ethics, the authors conclude that a good strategy for developing a public sector code of ethics will recognise contestability, demonstrate philosophical integrity in the code, mesh the code with identified performance indicators and provide whistleblower protection. The strategy described provides a sufficient framework for any public sector bureaucracy to develop a justifiable code of ethics for use by public sector employees.