DGD14-010
Policy
Conflict of Interest
Policy Statement
ACT Health is committed to ensuring that all staff members and volunteers maintain a high
standard of professionalism and integrity in the workplace. In meeting this obligation, any
staff member with a perceived, potential or actual conflict of interest must declare this to
their manager.
As far as practicable ACT Health staff and volunteers will not place themselves in a situation
in which it could be seen or perceived to be a conflict of interest. If a situation arises where
there may be a perception of conflict of interest the staff member or volunteer will notify
their manager or supervisor of the situation to avoid any allegations of misconduct.
A breach of this policy may be reviewed under the Public Sector Management Act 1994,
Section 9 General Obligations of Public Employees, and be managed under the misconduct
and discipline section of the relevant enterprise agreement or the Volunteer Conditions of
Placement.
Purpose
The purpose of this policy is to inform ACT Health staff and volunteers of their
responsibilities in relation to the declaration of any conflict of interest, whether perceived,
potential or actual.
Scope
It applies to all ACT Health staff, whether they are permanent, temporary or casual. ACT
Health staff from a regulated health profession are also subject to professional standards
regarding professional and personal boundaries, breaches of which may also be notified to
the Australian Health Practitioner Regulation Agency (AHPRA).
Roles & Responsibilities
Staff and volunteers are responsible for:
 As far as possible, not placing themselves into situations of possible conflict of
interest whether it be perceived, potential or actual; and
 Advising their manager of any perceived, potential or actual, conflict of interest in
the workplace.
Managers are responsible for:
Doc Number
DGD14-010
Issued
March 2014
Review Date
March 2017
Area Responsible
PSSB
Page
1 of 4
DGD14-010
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Including an item on each meeting agenda which requires participants to declare any
conflict of interest in relation to the meeting agenda items;
Contacting their Executive Director to discuss any conflict of interest declared to
them by a staff member or notification from another person of a perceived, potential
or actual conflict of interest due to a close personal relationship;
Discussing a potential conflict of interest with a staff member if a concern is raised
with them by another party due to a close personal relationship;
Acknowledging the situation and supporting the staff member;
Maintaining a record of notifications of conflicts of interest (see Conflict of Interest –
Close Personal Relationships Standard Operating Procedure for form), which includes
any actions taken and providing it to their Executive Director for official, central filing
on the employee’s personnel record; and
Managing the situation to ensure that both the staff member and ACT Health are not
seen to be in a position of conflict of interest that has not been managed
appropriately.
Executive Directors are responsible for:
 Ensuring that records of notification of a conflict of interest are maintained
appropriately;
 Contacting People Strategy & Services Branch (PSSB) to discuss declared conflicts of
interest that require further clarification; and
 Submitting a notification to the AHPRA where a registered health professional
commits a breach of this policy. A notification about a registered health professional
or student is made by downloading the Notification Form - NOTF-00 (663 KB,PDF),
from the AHPRA website, completing and mailing it to the AHPRA office.
People Strategy and Services Branch (PSSB) are responsible for:
 Implementation of this policy;
 Reviewing and updating the policy;
 Ensuring that staff orientation includes information about the need to declare any
conflict of interest and the means by which this is done; and
 Providing information to the Director General/Delegate, managers and staff of their
obligations where a possible conflict of interest situation may arise or has been
declared.
Evaluation
Outcome Measures
 ACT Health staff are informed of their responsibilities in regard to the ACT
Government’s Code of Ethics, Avoiding Conflicts of Interest;
 Any perceived, potential or actual conflicts of interest by staff that are reported
internally and/or publically have previously been declared to and addressed by
managers.
Method
 Information regarding conflict of interest and how it should be declared is included
on all orientation schedules.
Doc Number
DGD14-010
Issued
March 2014
Review Date
March 2017
Area Responsible
PSSB
Page
2 of 4
DGD14-010
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The discussion and actions arising from declarations are documented and stored
securely in the employee personnel file, which may be retrieved if a report of conflict
of interest requires investigation and to confirm that a matter of conflict of interest
has been addressed.
Related Legislation, Policies and Standards
Legislation
Public Sector Management Act 1994
ACT Public Service Code of Conduct
Human Rights Act 2004
ACT Procurement Act
Health Practitioner Regulation National Law (ACT) Act 2010
Policies
Conflict of Interest – Close Personal Relationship Policy
Conflict of Interest – Close Personal Relationship SOP
Health Directorate Enterprise Agreement
Health Directorate (Health Professionals) Enterprise Agreement
Health Directorate (Medical Practitioners) Enterprise Agreement
Health Directorate (Nursing and Midwifery) Enterprise Agreement
Misconduct and Discipline Policy
Fraud Management Framework Control Plan and Policy
Second Job Policy
Second Job SOP
Media Policy
Procurement Guideline
Research Practice Policy
Reviewing the Clinical Competence of a Doctor or Dentist following Receipt of a Complaint
or Concern SOP
Student Trainee Clinical Placement Policy - Appendix 1-8
Credentialing and Defining the Scope of Clinical Practice for Senior Medical and Dental
Practitioners SOP
Donations, Fundraising and Seeking External sponsorship SOP
Recruitment of Senior Medical and Dental Practitioners SOP
Corporate Governance Statement
Records Management Policy
Volunteer Policy
Standards
Public Sector Management Standards 2006
ACT Public Service Code of Ethics
Allied Health Professionals ACT Standards of Practice
Doc Number
DGD14-010
Issued
March 2014
Review Date
March 2017
Area Responsible
PSSB
Page
3 of 4
DGD14-010
Definition of Terms
Conflict Of Interest
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Perceived conflict of interest arises when it appears to an outsider that a staff
member’s private interest could improperly influence the performance of their duties
but this is not in fact the case;
Potential conflict of interest arises where a public official has private interests that
are of such a nature that a conflict of interest would arise if the staff were to become
involved in official responsibilities in the future related to those interests; and
Actual conflict of interest is where the improper influence is occurring or has
occurred in the past.
Avoiding Conflicts of Interest
To ensure that the community perceive public servants as impartial, effective and
fair, they must ensure that their official responsibilities do not conflict, or do not
appear to conflict with their personal or financial interests, including the interests of
their immediate family. This does not necessarily mean that they cannot have a
personal or financial interest in a matter that their agency or organisation is dealing
with, but the interest must be declared to an appropriate authority within their
agency. This will usually simply mean voicing their concern with their supervisor or
manager. In some circumstances it may be necessary to divest themselves of some
personal or financial interest, or remove themselves from the decision making
process, in order to avoid the conflict of interest
Disclaimer: This document has been developed by ACT Health, People Strategy & Services Branch specifically for
its own use. Use of this document and any reliance on the information contained therein by any third party is at
his or her own risk and ACT Health assumes no responsibility whatsoever.
Doc Number
DGD14-010
Issued
March 2014
Review Date
March 2017
Area Responsible
PSSB
Page
4 of 4