Conflict of Interest

Declaration of private interests

A declaration of private interests (DOPI) is designed to allow nominated staff to identify any private interests they hold which may result in a conflict of interest.

It involves school staff disclosing the range of personal interests they hold, including:

• other sources of income
• holding of other public or private offices
• shareholdings, investments or other business interests
• trusts
• real estate holdings
• other agreements
• family interests.

Completed DOPIs will be made available to immediate line managers to promote transparency and to ensure that any of private interests that may constitute a conflict of interest can be identified.

Employees required to complete a declaration of private interests

The following nominated employees must complete a DOPI:

• executive officers
• school principals
• public entity board members
• employees directed to do so by their manager in recognition of a high conflict of interest risk due to a private interest they hold or a work duty they perform.

These nominated employees must complete a DOPI on all of the following occasions:

• upon appointment to their position
• annually, each financial year
• if there is a change to their private interests as previously declared.

In schools, usually only the principal (or any school staff who act in a principal role during that financial year period) is required to complete an annual DOPI. Other staff may also be instructed to complete a DOPI on rare occasions.

How to complete a declaration of private interests

Staff can access the DOPI form in eduPay (staff login required) through the My Declarations tile from the Employee Self-Service menu.

When completing a DOPI, staff must provide adequate detail for each private interest to help with clear identification of conflicts of interest. This may include details such as:

• the ABN of any listed company or organisation
• the number of shares or equity held of specific companies
• family trust details including beneficiaries
• related employment of any family member
• details of any other employment or directorship at another company, business or trade.

Staff can complete and submit the form, or partially complete the form and save for later completion if necessary. Declarations must be completed by the relevant deadline below:

• for DOPIs to be completed upon appointment to a position – within 5 business days of appointment to the position
• for DOPIs to be completed annually – before the deadline noted in the annual notification sent in May of each year
• for DOPIs to be completed due to a change to the private interests of the school staff – within 5 days of the change in private interests occurring.

Access to the personal information provided in a declaration of private interests

The manager or principal will view a DOPI and help staff determine whether any of their declared private interests might represent a conflict of interest. No approval is required as part of this process. The point of review for principals is their area executive director.

The DOPI may also be viewed by staff in Conduct and Integrity Division during policy compliance monitoring duties, or as part of employee conduct investigations. Further disclosure of the information provided in the DOPI may occur where required in information requests made by external agencies, which include but are not limited to:

• Australian Securities and Investment Commission (ASIC)
• Australian Taxation Office (ATO)
• Victorian Ombudsman
• Independent Broad-based Anti-corruption Commission.

All personal information provided is managed by the department in accordance with its obligations under the Data Protection Act 2014 (Vic) and the Public Records Act 1973 (Vic).

Identifying a conflict of interest

When completing a DOPI, the staff member or their manager might identify that a particular private interest conflicts with one of the staff member’s public duties.

If a conflict of interest is identified in completing the DOPI, school staff members must complete a separate conflict of interest declaration and management plan. Staff can access the conflict of interest declaration form through eduPay (staff login required) in the My Declarations tile in the Employee Self-Service menu.

Manager role in reviewing a declaration of private interests

All DOPIs are made available to line managers to ensure an objective assessment of declared private interests and to help staff to determine whether any conflict of interest might exist or be perceived to exist.

A principal’s DOPI will be reviewed by their area executive director. All other school staff who have been asked to complete a DOPI will have it reviewed by their principal.

Managers must review each section of the DOPI and assess whether, in the staff member’s expected duties, they have the potential to be influenced by their declared private interests.

If the manager identifies a private interest that may conflict with a public duty, they will discuss with the staff member further. This may result in the staff member being required to submit a conflict of interest declaration and management plan in eduPay.