Declaring a conflict of interest

Identifying a conflict of interest

To determine whether a Conflict of Interest (COI) exists, consider the following questions in the context of your past/present/future relationships, obligations and affiliations and discuss the circumstances with your supervisor.

• Do I have a personal interest that does not allow me to act in a fair, impartial and objective manner?
• Are there factors that may influence my ability to maintain fairness, impartiality and objectivity?
• Are there benefits or losses for me or a close associate, now or in the future, that could impact or cast doubt on my conduct?
• Do I have a personal interest that could be perceived by colleagues or external parties to conflict with my professional duty?
• Would a neutral, reasonable person believe I should be removed from the situation?
• Would a neutral, reasonable person believe controls should be implemented to sufficiently manage or prevent a COI?
• Would my involvement withstand public scrutiny?
• Would my actions be illegal and non-compliant with University policy and procedure?
• Are there perception risks for me and/or the University?
• Are there consequences for me, other parties, colleagues, the University and the public if I ignore a conflict of interest?

If you answered yes to any of the above questions, you must declare your COI.

Conflict of Interest form – for COIs involving day-to-day operations, recruitment and committees

Secondary Employment form – request approval for secondary employment including self-employment

Receipt of Gift form – for gifts received with a value of over $100

Discuss your conflict of interest with your supervisor

In order to develop safeguards and oversights that will sufficiently manage or prevent a conflict of interest, you must have an open and transparent conversation with your supervisor (or another senior officer within your work area). Your supervisor must:

• assist and guide you to understand your roles, responsibilities and rules of their position
• reinforce University policies, procedures and ethical standards
• protect information about disclosed conflicts of interest from misuse
• discuss the 5 R's to determine the most appropriate safeguards and oversights to manage the COI:
  • Restrict – Limit your involvement in the matter. For example, refrain from voting on a decision where you have a personal interest.
  • Recruit – Involve an independent third party to oversee or review the process.
  • Remove – Withdraw from all involvement in the matter for as long as the conflict exists. For example, if a candidate for a position is a friend, remove yourself from the interview panel.
  • Relinquish – Give up your personal interests. For example, relinquish a membership to a club or association where it is creating a conflict of interest. However, this is not always reasonable (e.g. if the conflict is related to a family relationship) and no one can be forced to relinquish a personal interest.
  • Resign – As a last resort for serious conflicts of interest, you may be required to resign from your position.
• agree safeguards and oversights that must be stated on the COI form and implemented to manage the COI
• complete the supervisor section of the COI Declaration form.

Seek Band 7 Approval

Your Band 7 leader must review the COI Declaration form and complete the Band 7 section to indicate approval of the proposed safeguards and oversights. They may request that you and your supervisor review and improve the safeguards and oversights before they add their approval.

Submit completed form to DPC

DPC will review your completed form and provide a unique reference number for your records and citing when contacting DPC about the COI.

If a COI is serious and carries high risk, DPC may formalise safeguards and oversights in a Conflict Management Plan (CMP). You will be notified by your supervisor or a DPC representative if a CMP is required. All parties will be given the opportunity to review and agree the final CMP.

Notify all parties of changed circumstances

If circumstances of the COI change, discuss the changes with your supervisor as soon as possible. If your supervisor determines that the previously agreed safeguards and oversights are now insufficient, complete a new declaration form and submit to DPC being sure to cite your previous declaration reference number so it can be matched to your new declaration.

You should also cite your declaration reference number if you need to advise DPC that the COI has concluded prior to the expected end date.