Conflict of Interest Policy

1. Purpose and intent

Requires actual, potential and perceived conflicts to be disclosed and managed transparently. This policy is intended to provide a consistent reference for decisions, conduct and controls. It should be read alongside applicable laws, contractual obligations and relevant internal procedures. Where requirements differ, the applicable legal requirement and formally approved internal control take precedence.

2. Scope and application

Applies to directors, officers, employees and representatives involved in decisions, procurement, recruitment, commercial relationships, financial approvals or access to sensitive information.

Business partners are expected to observe equivalent standards where these are relevant to the services they provide or the activities they undertake on the organisation’s behalf. Application should be proportionate to role, activity, risk and applicable legal requirements.

3. Core principles

• Disclosure: disclose relevant interests promptly, fully and in writing.
• Objectivity: do not participate in decisions where impartiality may reasonably be questioned.
• Proportionality: apply controls suited to the nature and seriousness of the conflict.
• Confidentiality: protect personal and commercially sensitive information during assessment.

4. Minimum standards and controls

The following controls describe the expected minimum approach. Specific procedures, approval limits, forms and technical controls may be established separately and updated through controlled internal documents.

• Disclose outside employment, financial interests, close relationships or other circumstances that could influence work decisions.
• Declare relationships with bidders, suppliers, customers, candidates or competitors where relevant.
• Do not use position, information or organisational opportunities for personal gain.
• Do not influence recruitment, procurement or contract decisions involving close personal relationships without approval and safeguards.
• Update declarations when circumstances change.

5. Roles and accountability

Managers must assess declarations and determine suitable controls. Depending on the circumstances, controls may include recusal, reassignment, independent review, restricted access or divestment of an interest.

Any person who is uncertain about the application of this policy should seek guidance before taking action. No individual may override a legal obligation or approved control without appropriate authority and documented justification.

6. Reporting and escalation

Concerns, suspected breaches, control weaknesses and incidents should be raised promptly through the relevant management or designated reporting channel. Urgent threats to health, safety, the environment or the security of information must be escalated immediately. Reports should be handled fairly, sensitively and in accordance with applicable privacy and records requirements.

7. Monitoring, assurance and review

Declarations and mitigation decisions should be documented and reviewed periodically. Failure to disclose or comply with controls may result in disciplinary or other appropriate action.

Where improvement actions are identified, they should be assigned to an accountable owner, given a proportionate target date and monitored to closure. Material changes in law, risk, organisational context or operating arrangements should trigger an earlier review.

8. Non-compliance

Failure to follow applicable requirements may result in corrective action, additional training, restricted authority, disciplinary measures, contractual remedies or referral to relevant authorities, depending on the circumstances and applicable law. Any response should be proportionate and follow fair process.

9. Related policies and standards

Code of Conduct; Anti-Bribery; Gifts & Hospitality; Procurement; Delegation of Authority.

Additional policy requirements

The following provisions expand the practical expectations set out in this policy. They should be applied in conjunction with applicable law, approved internal procedures, contractual obligations and the circumstances of each activity.

Recognising a conflict

A conflict may arise where personal, family, financial, professional or external interests could influence, appear to influence or compete with an individual’s duties. Examples include interests in suppliers, outside employment, recruitment of relatives, personal relationships affecting decisions and use of confidential information for private benefit.

Disclosure before action

Potential conflicts should be disclosed as soon as they are identified and before the individual participates in the relevant decision, negotiation, selection or approval. Disclosure should describe the relationship, interest, affected matter and any proposed safeguards.

Management measures

Depending on the circumstances, measures may include recusal, reassignment, independent review, restricted access to information, divestment where appropriate or written conditions on participation. The individual must follow the management plan and report any change in circumstances.

Gifts and outside interests

Gifts, hospitality, external appointments, investments and close personal relationships must be assessed where they could impair impartiality or create an appearance of improper influence. A disclosure does not itself authorise the activity.

Records and non-compliance

Disclosures, assessments, decisions and mitigation measures should be retained in an appropriate register. Failure to disclose or comply with a management plan may result in removal from a decision, restriction of authority or other proportionate action.

10. Document governance

This web page is a public policy statement. The controlled internal version, where formally approved, is maintained through the organisation’s document-control process. Approval status, document owner, effective date, review cycle and revision history must be confirmed in the controlled document register before this text is represented as a formally issued internal policy.