Conflict of
Interest Procedures
1
Purpose
The purpose of these Conflict of Interest Procedures is to assist you to apply the
Conflict of Interest Policy.
Please refer to the Conflict of Interest Policy to understand the scope, key concepts
and definitions as they are incorporated by reference into these procedures.
2
Roles and Responsibilities
Disclosures, avoidance and management of conflicts of interest are a shared
responsibility of our executive, managers, employees and other persons as set out
below.
2.1 [Agency head or principal officer]
[Agency head or principal officer] will:

support, endorse, enforce and review the conflict of interest policy, procedures
and related guidance;

educate train and induct persons to whom the policy, procedures or guidance
applies about their meaning and how to apply them, in a practical sense;

lead by example, understand and support the policy, procedures and any
guidance;

in addition to Public Interest Disclosure Act 2002 requirements, provide such
protections as are appropriate to those who report conflicts of interest;

meet their obligation to disclose, manage and report relevant personal
interests and conflicts of interest;

report upon how conflicts of interest that they have disclosed have been
avoided or managed;

negotiate and agree with those who disclose or report conflicts of interest to
them the steps or processes to avoid or manage conflicts of interest;

review, analyse, monitor and action registers of relevant personal interests
and conflicts of interest; and

seek, record and act upon advice from the Integrity Commission or another
appropriate independent advisor about steps or processes to avoid or manage
conflicts of interest.
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2.2 Managers
Managers will:

support, endorse, enforce and review the conflict of interest policy, procedures
and any guidance;

educate train and induct persons they supervise or manage about the
meaning and effect of the policy, procedures or guidance and how to apply
them, in a practical sense;

lead by example, understand and support the conflicts of interest policy,
procedures and any guidance;

meet their obligation to disclose and report relevant personal interests and
conflicts of interest;

report upon how conflicts of interest that they have disclosed have been
avoided or managed;

negotiate and agree the steps or processes to avoid or manage conflicts of
interest where such conflicts are identified and reported to them;

monitor, analyse and report upon relevant personal interests and conflicts of
interest that have been disclosed, avoided or managed; and

where conflicts of interest reported or disclosed to them concern [agency head
or principal officer] seek, record and act upon advice from the Integrity
Commission or another appropriate independent advisor about recommended
steps or processes they should take.
2.3 Employees and persons to whom the policy applies
Employees and others to whom the conflict of interest policy applies will:

ensure that they understand and apply the conflict of interest policy,
procedures or any guidance that applies to them;

meet their obligation to disclose and report relevant personal interests and
conflicts of interest;

negotiate and agree with their line manager or person nominated by them, the
steps or processes to avoid or manage conflicts of interest where such
conflicts are identified; and

report upon how conflicts of interest that they have disclosed have been
avoided or managed.
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3
How to disclose
3.1 Relevant personal interests
Relevant personal interests may be pecuniary or non-pecuniary and may include (but
are not limited to): shares, trusts, partnerships, real estate, directorships, committee
membership, other assets, other substantial sources of income, liabilities and
memberships.
You may be required to disclose relevant personal interests if you work in a high risk
area and those interests may have an impact, or be perceived to have an impact, on
what you do. Senior managers or staff working in procurement, town planning or
investigations usually have to make these disclosures.
If you are required to disclose relevant personal interests you should do so on the
form prescribed on taking up your position or as required. You will also have to
disclose such interests of your partner, dependants or close associates if they impact,
or could be perceived to have an impact, on your ability to properly and impartially
discharge your duties.
A Disclosure of Relevant Personal Interests Form is available from [agency location].
Disclosures of relevant personal interests are stored securely on our register of
relevant personal interests. This register and the records on it are private and are
treated as staff-in-confidence.
If your relevant personal interests vary during the disclosure period you should notify
management of the variation within 14 days.
A Variation of Relevant Personal Interests Form is available from [agency location].
3.2 Conflict of interest
You must disclose an actual, potential or perceived conflict of interest as soon as it is
identified by you. You should do this by discussing the interest with your line manager
and by formally disclosing the details on our prescribed form, or as agreed with your
manager.
A Disclosure of Conflict of Interest Form is available from [agency location].
Your interest may be recorded on our Conflict of Interest Register.
Any information placed on our conflict of interest register is private and is treated as
staff-in-confidence. Such information is only accessible to [Agency head or principal
officer] and/or those responsible for managing conflicts.
Once the matter in which your conflict of interest arose has been completed, or the
conflict has otherwise been resolved, you must also record and report this on our
prescribed form or as agreed with your manager.
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How to avoid or manage
You must discuss how to avoid or manage a conflict of interest you have identified
with your manager before taking any action in relation to the matter affected by the
conflict of interest.
The range of options you can discuss and use are as follows.

Register: register where the details of the existence of possible conflict of
interest are formally registered.

Restrict: restrict your involvement in a matter, to avoid having any decision
making power.

Recruit: ask an independent third party to oversee all or part of the process
you are involved in.

Remove: ask to be removed from taking part in the matter.

Relinquish: relinquish the personal interest that creates the conflict.

Resign: resign if you cannot manage the conflict of interest.
The way that you decide to manage the conflict of interest must be recorded, signed
off by you and your manager, and must continue to be applied for however long the
conflict exists.
The Disclosure of Relevant Personal Interests Form provides an area for the agreed
management strategy to be recorded and signed off.
You can seek advice and assistance on what to report, disclose or manage a conflict
of interest from a number of sources, including:

your line manager;

[designated officer];

with prior approval of your manager, an external independent expert; or

[Agency head or principal officer] where the conflict involves your line
manager, or the issue is high risk.
[Agency head or principal officer] may seek advice from the Integrity Commission.
Where a conflict of interest concerns [agency head or principal officer], you may seek
advice from the Integrity Commission.
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How to record and report
If you receive disclosure forms or other records relating to conflict of interest you must
provide them to [designated officer] unless directed otherwise.
Records and registers kept by [designated officer] are private and are to be treated as
staff-in-confidence.
[add any other agency specific recording/reporting requirements]
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Further resources
Guides, flowcharts and forms are provided to assist you understand obligations,
disclose interests, conflicts of interest, to record management and other processes.
These are available on our intranet or through our library facility. Browse or search to
find the document you require.
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