Conflict of Interest

At risk areas

Risks of Conflict of Interest (COI) are typically significant in relation to 3 types of activity:

• recruitment and selection
• procurement (tendering, purchasing, contracting)
• funding allocation or licensing.

Other areas of high risk include contractor management, other work (external employment), receiving gifts, benefits or hospitality, complaints management and disciplinary processes, and managing private or public partnerships.

Principals and business managers undertake some of these functions regularly and therefore need to be particularly aware of the risks.

Activities which carry a high risk of COI should be subject to considered and systematic scrutiny. It is recommended that business units and schools undertake assessments of COI risk in relation to relevant roles and duties and, where appropriate, develop guidelines which identify specific expectations on employees for the responsible management of these risks. The COI Toolkit includes checklists and COI best practice case studies which may assist in these processes (refer to the Resources tab).

Contractors and external organisations

The department expects organisations with which it partners and contractors it engages to comply with responsible practices in relation to managing COI. Where possible, this expectation should be incorporated into the instruments which determine or influence mutual expectations, such as memoranda of understanding and contracts for services.

It is for individual units throughout the department to take steps to put into effect these expectations in the management of relationships with organisations.

Obligation to incorporate COI management in specific circumstances

The management of COI in accordance with the department policy should be incorporated into the work of the following groups, which are formed in the department from time to time:

• recruitment selection and evaluation panels
• panels dealing with the procurement of goods or services
• internal project boards and committees
• panels dealing with the evaluation of grants.

This obligation rests with those responsible for the relevant process. The management of COI in the work of these groups should include the following steps:

• an assessment of risks of COI to be incorporated into the board, panel or committees’ terms of reference
• reporting and management of members’ COI to be a standing agenda item at each meeting
• steps taken to manage all reported COI to be recorded in the board, panel or committee’s proceedings.