Human resources

Conflict of Interest

Recording Declaration of Conflicts of Interest form in eduPay

All employees are required to record Conflict of Interest (COI) declarations and agreed steps to avoid or manage COI. A Declaration of Conflict of Interest form available on eduPay is to be used to do so.

Line manager’s role

Identified conflicts must be reported to the employee’s line manager. It is rarely sufficient for conflicts to be disclosed only to subordinates or peers. Employees may also consult with their manager for assistance in identifying conflicts, or with any COI matters.

School principals who have identified COI are to report it to their Regional Director. Regions may develop processes to facilitate the reporting of COI in relation to certain circumstances (such as recruitment) which do not involve direct contact with the Regional Director.

Line managers can provide guidance to employees about taking appropriate action to mitigate an identified COI. This ensures both integrity and parity in the protection of the public interest.

Whose responsibility is it to take action?

While it is an employee’s responsibility to take appropriate action to resolve an identified COI in the public interest, line managers play a critical role in moderating these decisions and adding perspective to the options available.

In some circumstances, however, line managers may consider it necessary to direct an employee to take action they do not wish to take to mitigate a COI. For example, they might direct the employee to relinquish a private interest while the employee does not consider this to be reasonably necessary. In such circumstances, the line manager’s direction may be a lawful and reasonable direction which the employee must follow or face disciplinary action.

If, however, the employee feels that their manager’s direction is unreasonable or otherwise flawed, they can lodge a grievance with the Merit Protection Boards to challenge its validity.

Chapter of the Conflict of Interest Policy explaining recording and reporting requirements including COI declarations

Reviewed 09 June 2020

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