Conflict of Interest & Disclosure Policy

1. Purpose

The purpose of this Conflict of Interest & Disclosure Policy is to protect the integrity, transparency, and reputation of the organisation by establishing clear requirements for identifying, disclosing, managing, and resolving conflicts of interest.

The policy ensures that decisions are made in the best interests of the organisation and are not improperly influenced by personal, financial, professional, family, or other interests.

2. Scope

This policy applies to all individuals who have responsibilities, decision-making authority, or representation on behalf of the organisation, including:

Board members and directors.
Committee members.
Officers and office bearers.
Employees.
Volunteers.
Members serving in positions of responsibility.
Consultants, contractors, or representatives where applicable.

3. Definition of a Conflict of Interest

A conflict of interest occurs when an individual’s personal, financial, professional, family, or other interests could improperly influence, or could reasonably appear to influence, their duties, responsibilities, decisions, or actions on behalf of the organisation.

A conflict may be:

Actual: A conflict currently exists between the individual’s personal interests and organisational responsibilities.
Potential: A situation could reasonably develop into a conflict in the future.
Perceived: Circumstances could reasonably create the appearance that the individual’s impartiality or decision-making may be compromised.

A conflict of interest does not necessarily mean that wrongdoing has occurred. The purpose of disclosure is to ensure that potential conflicts can be identified and appropriately managed.

4. Examples of Conflicts of Interest

Examples may include:

Having a financial interest in a business that is seeking to provide services to the organisation.
Participating in a decision that could financially benefit the individual or a close family member.
Using organisational information or resources for personal benefit.
Hiring, supervising, or making decisions concerning a family member or close associate.
Having a personal relationship with an individual involved in a matter being considered by the organisation.
Receiving gifts, benefits, favours, or hospitality that could influence or appear to influence decision-making.
Holding a position in another organisation that has competing interests with the organisation.
Participating in decisions involving a business, organisation, or individual with whom the member has a significant personal or professional relationship.

5. Duty to Disclose

Individuals covered by this policy have a responsibility to promptly disclose any actual, potential, or perceived conflict of interest.

Disclosure should be made as soon as the individual becomes aware of the conflict and before participating in any decision or activity affected by the conflict, where reasonably possible.

When in doubt, individuals should disclose the potential conflict rather than assume that disclosure is unnecessary.

6. Disclosure Requirements

A conflict-of-interest disclosure should, where applicable, include:

The nature of the conflict.
The parties or organisations involved.
The individual’s relationship or interest.
Any financial or other benefit that may arise.
The matter, decision, transaction, or activity affected by the conflict.
Any other information necessary to understand the circumstances.

The organisation may require individuals to complete a formal Conflict of Interest Disclosure Form or annual declaration.

7. Annual Disclosure

Individuals in positions of governance, leadership, management, or decision-making authority may be required to complete an annual conflict-of-interest declaration.

The declaration should confirm that the individual:

Has read and understood this policy.
Has disclosed all known actual, potential, or perceived conflicts.
Understands their ongoing duty to disclose new conflicts.
Agrees to comply with the organisation’s conflict-of-interest requirements.

Annual disclosure does not replace the obligation to report new conflicts as they arise.

8. Management of Conflicts

Once a conflict has been disclosed, the organisation will determine the appropriate method of managing the conflict.

Depending on the circumstances, management measures may include:

Recording the disclosure in the appropriate register.
Requiring the individual to abstain from discussion or decision-making.
Excluding the individual from voting on the matter.
Restricting access to confidential information.
Assigning the matter to an independent person or committee.
Obtaining independent advice.
Requiring the individual to withdraw from a meeting or discussion.
Taking other reasonable steps to protect the organisation’s interests.

9. Recusal and Abstention

Where an individual has a conflict of interest, they may be required to recuse themselves from discussions, deliberations, decisions, or votes relating to the matter.

The individual’s disclosure and recusal should be recorded in the relevant meeting minutes or organisational records where appropriate.

The organisation may determine whether the individual may remain present for factual discussions or must leave the meeting entirely.

10. Financial Interests

Individuals must disclose significant financial interests that could influence, or reasonably appear to influence, their responsibilities to the organisation.

This may include interests in:

Businesses.
Companies.
Partnerships.
Investments.
Contracts.
Suppliers.
Service providers.
Other financial arrangements relevant to organisational decisions.

The organisation may require additional information where necessary to assess and manage the conflict.

11. Gifts, Benefits and Hospitality

Individuals should not accept gifts, benefits, hospitality, discounts, or other advantages that could improperly influence their decisions or create an appearance of preferential treatment.

Where gifts or hospitality are permitted under organisational rules, individuals may be required to disclose them in accordance with the applicable policy or register.

12. Related Parties

Individuals should disclose relevant relationships with persons or organisations that may benefit from decisions made by the organisation.

This may include relationships involving:

Immediate or close family members.
Business partners.
Employers.
Close personal associates.
Organisations in which the individual holds a significant role or interest.

The organisation may determine appropriate safeguards where a related-party relationship creates a conflict.

13. Confidential Information

Individuals must not use confidential, proprietary, or non-public organisational information for personal benefit or for the benefit of another person or organisation.

Confidential information must only be accessed, used, and disclosed for legitimate organisational purposes and in accordance with applicable policies.

14. Conflict of Interest Register

The organisation may maintain a Conflict of Interest Register to record disclosed conflicts and the measures taken to manage them.

The register may include:

Name of the individual.
Date of disclosure.
Nature of the conflict.
Relevant matter or activity.
Management action taken.
Date the conflict was resolved, where applicable.

Access to the register should be limited to authorised individuals where the information is confidential or sensitive.

15. Responsibilities of Individuals

Individuals covered by this policy are responsible for:

Acting honestly and in the best interests of the organisation.
Identifying potential conflicts.
Making timely and complete disclosures.
Updating disclosures when circumstances change.
Following recusal or abstention requirements.
Protecting confidential information.
Avoiding the improper use of organisational position, resources, or information.
Cooperating with reasonable requests relating to conflict management.

16. Responsibilities of the Organisation

The organisation is responsible for:

Providing clear guidance on conflicts of interest.
Maintaining appropriate disclosure procedures.
Reviewing disclosed conflicts.
Determining appropriate management measures.
Maintaining relevant records.
Applying the policy consistently.
Taking appropriate action where conflicts are not disclosed or improperly managed.

17. Failure to Disclose

Failure to disclose an actual, potential, or perceived conflict of interest may result in appropriate action under the organisation’s applicable policies and procedures.

Where an individual knowingly fails to disclose a material conflict or improperly participates in a matter despite a conflict, the organisation may take corrective or disciplinary action where appropriate.

18. Review of Disclosures

The organisation may periodically review conflict-of-interest disclosures to ensure that:

Disclosures remain accurate and current.
Management measures remain appropriate.
New conflicts have been properly disclosed.
Previous conflicts have been resolved or appropriately managed.

Individuals may be asked to provide additional information where necessary.

19. Protection Against Retaliation

Individuals who make a genuine conflict-of-interest disclosure in good faith should not be subjected to retaliation, intimidation, harassment, or adverse treatment as a result of making the disclosure.

Concerns regarding retaliation may be addressed under the organisation’s Grievance, Complaints, or Disciplinary procedures.

20. Related Policies

This policy should be read together with the organisation’s:

Constitution and/or Bylaws
Member in Good Standing Policy
Code of Conduct
Ethics Policy
Grievance Policy
Disciplinary Policy
Gifts and Hospitality Policy
Procurement Policy
Financial Management Policy
Privacy and Data Protection Policy
Whistleblower Policy, where applicable

21. Policy Review

This policy will be reviewed periodically to ensure that it remains effective, relevant, and consistent with the organisation’s governing documents, internal procedures, and applicable requirements.