Policy

Conflict of Interest - Policy

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1.0   Purpose and Scope

1.1    Purpose

The University of Queensland’s (UQ or the University) framework for managing conflict of interest seeks to protect the University and its employees from the risks associated with actual, perceived and potential conflicts of interest. The framework has three key pillars: (1) education and awareness; (2) self‑assessment and disclosure; and (3) management of conflicts.

Conflicts of interest are a normal part of employment relations in a large complex organisation like the University. What is important is how conflicts are efficiently and effectively disclosed and appropriately managed.

A conflict of interest involves:

  • A perceived conflict where it could reasonably be perceived, or give the appearance, that a competing interest or obligation, whether personal or involving a third party, could improperly influence the performance of a staff member’s duties and responsibilities to the University.

  • A potential conflict of interest where a staff member has an interest or obligation, whether personal or involving a third party, that could conflict with the staff member’s duties and responsibilities to the University.

  • An actual conflict where a staff member has a competing interest or obligation, whether personal or involving a third party, that directly conflicts with the staff member’s duties and responsibilities to the University.

This policy is consistent with principles of the Public Sector Ethics Act 1994 and The University of Queensland Code of Conduct, which require staff to acknowledge the primacy of the public interest and ensure that any conflict of interest is avoided, or resolved or appropriately managed.

1.2    Scope

This policy applies to all University staff (including contractors) and members of UQ Senate. Where conflicts of interest are identified, they must be disclosed and manage appropriately in accordance with this policy and:

  1. for UQ staff – the Conflict of Interest for Members of Staff Procedure and the Commercialisation Conflicts of Interest Procedure; and/or

  2. for members of UQ Senate – the Conflict of Interest and Disclosure Procedure for Members of Senate.

2.0   Principles and Key Requirements

2.1    Principles

Accountability, honesty and common sense are central to the good management of conflicts of interest. Without limiting the obligations set out in this policy, University staff must:

  1. Restrict the extent to which a private interest could compromise, or be seen to compromise, their impartiality when carrying out their official duties.

  2. Refrain from involvement in official decisions and actions which could be compromised by other private interests and affiliations.

  3. Avoid personal activities or undertakings which could, or could be seen to, provide an improper advantage through the use of confidential or privileged UQ information.

  4. Refrain from using their official position or University resources for private personal gain or gain by others with whom the staff member has a relationship or personal association.

  5. Ensure that there can be no perception that they have received an improper benefit that may influence the performance of their official duties.

  6. Refrain from taking improper advantage of their official position or confidential/privileged information gained in that position when seeking employment outside the University, or provide such advantage to others with whom they have an association.

2.2    Types of conflict

University staff and contractors must be aware of the different types of conflicts of interest and regularly self‑assess their circumstances, and disclose and appropriately manage any conflict of interest in accordance with this policy and the associated procedures.

Conflicts of interest include, but are not limited to, the examples outlined below.

Private interests

Conflicts of interest can arise from a University staff member avoiding personal losses or gaining personal advantage by virtue of their role or access to University information that is not available to others. A private interest may be financial or non‑financial, and may include business interests in a company tendering for paid work from the University.

Personal relationships

University staff must carry out their official duties with integrity and avoid conflicts of interest between their personal relationships and their University responsibilities. Personal relationships may include:

  • Family and close personal relationships – staff must not be involved in decisions affecting the employment or academic administration or teaching of a person with whom they have a family or close personal relationship. These relationships may include spouse, children, siblings or cousins, relations by marriage, close relatives, close friendships or sexual relationships.

  • Financial relationships – staff must not be involved in decisions affecting the employment or academic administration of a person with whom they have a commercial relationship or where a personal financial interest exists.

Personal benefits

A conflict of interest may occur where a University staff member receives a gift or benefit that is, or may be perceived as, influencing the performance of their official duties. The University’s Reportable Gifts and Benefits Procedure requires staff to disclose their receipt of certain gifts.

Researchers

Researchers have additional responsibilities under the University’s Responsible Research Management Framework Policy, which requires researchers to disclose and manage actual, potential, and perceived conflicts of interest which may relate to the design, conduct or reporting of research.

Commercialisation or financial conflicts of interest

The University recognises financial conflicts of interest may arise as staff commercialise their research or teaching resources into products and services. A financial conflict of interest occurs when the primary interest of a University staff member, in maintaining and promoting the University‘s vision, mission and values, is put at risk through the potential conflict of a significant financial interest.

2.3    Disclosing and managing a conflict of interest

2.3.1    Members of Senate

Conflicts of Interest relating to members of Senate will be disclosed and managed in accordance with the Conflict of Interest and Related Party Transactions for Members of Senate Procedure.

2.3.2    University staff

All conflicts of interest must be disclosed and managed transparently between relevant parties and should align with a conflict of interest management plan. Strategies available to manage conflicts of interest include:

Register

Disclose and establish the details of the conflict

Restrict

Restrict the staff member’s involvement or actions in the matter

Recruit

A disinterested third party should oversee processes involved in the matter 

Remove

The individual may remove themselves from their involvement in the matter

Relinquish

The individual and/or their related parties may relinquish the private interest

Resign

The individual’s resignation is an option of last resort if no other options are workable

3.0   Roles, Responsibilities and Accountabilities

3.1    Members of Senate

Under the University of Queensland Act 1998, members of Senate are responsible and accountable to Senate. Members of Senate are required to disclose and avoid conflicts of interest in accordance with the Conflict of Interest and Disclosure Procedure for Members of Senate.

3.2    University staff

Staff must comply with this policy and associated procedures.

Staff are required to:

  • complete mandatory training and undertake regular self-assessment;

  • disclose or update any conflict of interest involving themselves, and suggest an appropriate management plan;

  • work with their Supervisor to refine a management plan they have submitted; and  

  • alert supervisors to conflicts of interest held by other staff where they have reasonable belief the conflict of interest has not previously been disclosed.

3.3    Supervisors

As defined in section 4.2 of the Conflict of Interest for Members of Staff Procedure.

3.4    Integrity Unit

The Integrity Unit is responsible for:

  • administering conflict of interest training;

  • maintaining the staff self‑assessment tool;

  • investigating breaches of this policy and the University Code of Conduct in relation to conflicts of interest, where appropriate and in accordance with complaints management practices.

The Integrity Unit will also maintain records of all conflict of interest matters it investigates, including outcomes and any external referrals that have been made. Where necessary, breaches of this policy can be referred to the Human Resources Division or the Office of Research Integrity for action as appropriate. 

4.0   Monitoring, Review and Assurance

4.1   Compliance

Failure to comply with this policy and associated procedures will constitute a breach of the University’s Code of Conduct and may be dealt with as misconduct or serious misconduct in accordance with The University of Queensland Enterprise Agreement.

A member of the University Senate who fails to disclose a conflict of interest in the exercise of their functions may be removed from office under provisions of the University of Queensland Act 1998.

The University has a legislative obligation to report breaches of this policy, where necessary, to external agencies including the Queensland Audit Office and the Crime and Corruption Commission.

4.2   Monitoring

The University, through the Provost and Chief Human Resources Officer, will periodically review this policy and its procedures for their effectiveness.

5.0   Recording and Reporting

5.1   Conflict of interest register

5.1.1   Members of Senate

The Senate Secretary is responsible for maintaining a confidential register of interests for members of Senate.

5.1.2   University Staff

A University conflict of interest register must be established and maintained in accordance with the Conflict of Interest for Members of Staff Procedure.  Staff are required to submit and maintain conflicts of interest via the disclosure tool in accordance with the Conflict of Interest for Members of Staff Procedure.

6.0   Appendix

6.1   Definitions, terms and acronyms

Academic administration (including research administration): means any administrative aspect of a student’s enrolment in a program at the University including admission, enrolment and assessment.

University staff: means all officers and employees of the University, persons acting in an honorary or voluntary capacity for or at the University, and Members of the University Senate. For the purposes of this policy, this definition also includes contractors undertaking work for or on behalf of the University.

Supervisor: refer to section 3.2 of this policy, or for Members of the University Senate, the Chancellor or Deputy-Chancellor or a person elected to preside over a Senate meeting under section 27(2) of the University of Queensland Act 1998.

Custodians
Chief Human Resources Officer
Provost Professor Aidan Byrne

Procedures

Disclosure of Interests relating to Commercialisation - Procedures

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1.0    Purpose and Scope

1.1    Purpose

This procedure supports The University of Queensland’s (UQ or the University) Conflict of Interest Policy and outlines the processes for identifying, disclosing and managing commercialisation financial conflicts of interest (FCOIs) that may arise as UQ staff seek to commercialise their research.

1.2    Scope

A commercialisation FCOI occurs when the potential influence of a significant financial interest – that has arisen through the commercialisation of UQ Intellectual Property (IP) a staff member has developed – puts at risk the primary interest of a staff member in maintaining and promoting UQ’s core values and mission.

This procedure applies to all UQ staff (including contractors) that have developed IP and have, or intend to have, a significant financial interest in the external entity that is commercialising the IP.

This procedure must be read in conjunction with the Conflict of Interest for Members of Staff Procedure.

This procedure does not apply to members of Senate. The Conflict of Interest and Related Party Transactions for Members of Senate Procedure provides the process for members of Senate to disclose and manage a conflict of interest.

2.0    Process and Key Controls

  1. All staff must assess their personal interests and identify whether those interests may conflict with their UQ duties and responsibilities.
  2. All staff are required to disclose any interest that may represent a FCOI and suggest management plans for approval using the online disclosure tool.
  3. Senior Leaders, as defined in the Conflict of Interest for Members of Staff Procedure, have the option, through the online disclosure tool, of seeking advice from the Deputy Vice-Chancellor (Research and Innovation) on how best to manage a commercialisation FCOI that has been disclosed by a staff member and must do so where they propose to approve a management plan for a FCOI that deviates from principles 2-4 set out in section 3.1of this procedure.
  4. The Deputy Vice-Chancellor (Research and Innovation) may  refer a request for advice to the Commercialisation Pathways Advisory Group to consider the most appropriate management plan.
  5. The Deputy Vice-Chancellor (Research and Innovation) will confer with the Provost on the most appropriate management plan, where the plan may deviate from principles 2-4 set out in section 3.1 of this procedure.

3.0    Principles and Key Requirements

3.1    Commercialisation FCOIs

Under normal circumstances:

  1. A staff member may not make a personal financial gain from the outcomes of UQ research, or assisting outside organisations by providing access to UQ IP, without following UQ policy and procedures for the commercialisation of UQ IP.

  2. As part of a sponsored research project or other UQ research activity, a staff member may not enter into a contract with an outside entity in which they, or a related person, hold a significant financial interest either directly or through another related outside entity.

  3. A staff member may not assign a student, trainee or staff member under their supervision to a research project that would benefit an entity, in which they or a related person, hold a significant financial interest directly or through another related outside entity, or in which a fiduciary / governance / management role is held.

  4. A staff member may not hold a paid or unpaid fiduciary / governance / management role in an outside entity that has a commercial interest in UQ IP generated by or under the supervision of the staff member in question

Under limited circumstances, and only with Deputy Vice-Chancellor (Research and Innovation) approval, an approved management plan for an FCOI may permit deviations from principles 2-4.

UniQuest is a wholly-owned subsidiary of UQ, and is not considered an outside entity where reference is made to outside entities in the articulation of these principles.

3.2    Management of Commercialisation FCOIs

A number of options are available to manage FCOIs through an approved management plan as outlined in section 2.3 of the Conflict of Interest Policy. The successful implementation of a management plan for a commercialisation FCOI is dependent on determining when the FCOI becomes manageable in this hierarchy of options. The general suitability of the options for managing a commercialisation FCOI is given below.

 

Option 1: Register – disclose and establish the details of the conflict of interest

  • All relevant interests need to be registered through a full disclosure of interests.

  • After registering the conflict, a management plan must be proposed and discussed with a supervisor.

Option 2: Restrict – restrict the staff member’s involvement or actions in the matter.

  • Suitable for infrequent conflicts or if staff member can be separated from UQ activity that forms part of the FCOI.

  • Not suitable for frequent or on-going conflicts or if regular duties could not be performed.

Option 3: Recruit – disinterested third party should oversee all of the processes involved in the matter.

  • Suitable where proactive management by others can remove the opportunity that a personal benefit could accrue to the individual.

  • Not suitable if the FCOI is serious and on-going, rendering the ad-hoc recruitment of others unworkable. The technical nature of much research, and the retrospective nature of reporting to an oversight committee, will often make it impractical for such a committee to effectively determine if an overlap in interests between UQ and an outside entity has occurred, or to direct work away from an area of contention.

Option 4: Remove – The staff member may remove themselves from their involvement in the matter.

  • Suitable if removal from all duties associated with the conflict is possible. As a consequence of the undirected nature of research within the UQ environment, removal of the FCOI in this context requires the individual to cease working with the outside entity. The staff member continues to independently work in their research area.

  • Not suitable if any association through further research is to be maintained between the staff member and the outside entity.

Option 5: Relinquish – the staff member and/or their related parties relinquish the personal interest.

  • Suitable if the staff member and/or related parties agree to divest all associated secondary interests that generate the opportunity/perception that a personal benefit could accrue to the staff member.

  • Not suitable if the staff member and/or related parties are unable or unwilling to divest their personal interests in the outside entity.

Option 6: Resign.

  • Resignation may be the only principled course of action to resolve the FCOI if relinquishment is not possible, and a serious FCOI remains.

  • An option of last resort if no other options are workable.

A key premise in the application of these options is to attempt to put in place a suitable management plan that adequately addresses the conflict at the lowest option level possible.

4.0    Roles, Responsibilities and Accountabilities

4.1    Provost

The Provost will confer with the Deputy Vice-Chancellor (Research and Innovation) on management plans that deviate from principles 2-4 in section 3.1 of this procedure.

4.2    Deputy Vice-Chancellor (Research and Innovation)

The Deputy Vice-Chancellor (Research and Innovation) is responsible for:

  • Ensuring that research at UQ is conducted in manner consistent with the Australian Code for the Responsible Conduct of Research.

  • Providing advice to Senior Leaders on the management of FCOIs.

  • Conferring with the Provost on management plans that deviate from principles 2-4 in section 3.1 of this procedure.

4.3    Senior Leaders

Senior Leaders as defined in the Conflict of Interest for Members of Staff Procedure are responsible for:

  • Working with staff who have made a disclosure of a commercialisation FCOI to refine and implement an agreed management plan.
  • Referring disclosed commercialisation FCOIs to the Deputy Vice-Chancellor (Research and Innovation) as required.

4.4    Commercialisation Pathways Advisory Group

The Commercialisation Pathways Advisory Group is responsible for advising the Deputy Vice‑Chancellor (Research and Innovation) on the interpretation and application of the requirements of this procedure in relation to specific commercialisation cases.

4.5    University Staff

Staff must complete mandatory training, undertake regular self-assessment of their interests, make disclosure where necessary, and participate in the construction and implementation of any management plan. Staff are also required to alert supervisors to FCOI held by other staff where they have reasonable belief the FCOI has not previously been disclosed.

Failure to disclose an interest and/or establish an appropriate management plan for an unresolved serious FCOI may result in the staff member being in breach of UQ’s Code of Conduct.

5.0    Monitoring, Review and Assurance

The Deputy Vice-Chancellor (Research and Innovation) and Provost are responsible for the development, compliance monitoring and review of this procedure.

6.0    Recording and Reporting

All records of actual, perceived/apparent, and potential FCOIs are recorded in the conflict of interest register as described in section 6.1 of the Conflict of Interest for Members of Staff Procedure.

7.0    Appendix

7.1    Definitions

Management plan: an approved course of action based around one of the management option levels 2‑6 (Restrict, Recruit, Remove, Relinquish, Resign) to address the FCOI.

Related person: can include the following –

  • Family and close personal relationships –a person with whom a staff member has a family or close personal relationship. These relationships may include spouse, children, siblings or cousins, relations by marriage, close relatives, close friendships or sexual relationships.

  • Financial relationships –a person with whom a staff member has a commercial relationship or where a personal financial interest exists.

Significant Financial Interest: includes, but is not limited to, (1) financial compensation, including travel, from consulting, employment, managerial, and fiduciary relationships that, when aggregated over the preceding twelve months, exceed $10,000; (2) equity and other financial interests above $10,000, excluding interests of any amount in diversified financial holdings (e.g. ETFs or other managed funds); (3) equity interests of any amount, or entitlement to the same, in a non-publicly traded, for-profit, entity; (4) intellectual property rights and interests (e.g. patents, copyrights), upon receipt of income related to such rights and interests; and (5) holding fiduciary/governance/management positions such as Directorships. “Financial compensation” does not include royalties or other remuneration paid by UQ.

University staff: means all officers and employees of the University, persons acting in an honorary or voluntary capacity for or at the University, and Members of the University Senate. For the purposes of this policy, this definition also includes contractors undertaking work for or on behalf of the University.

Custodians
Chief Human Resources Officer
Provost Professor Aidan Byrne

Procedures

Conflict of Interest for Members of Staff - Procedures

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1.0   Purpose and Scope

1.1   Purpose

This procedure supports The University of Queensland’s (UQ or the University) Conflict of Interest Policy and outlines the processes for identifying, disclosing and managing conflicts of interest at UQ.

1.2   Scope

This procedure applies to all University staff (including contractors).

Where transient conflicts occur through service on panels, such as appointment or procurement panels, the disclosure of the conflict should occur either verbally in the meeting or on the appropriate form, see UQ Recruitment, Selection and Appointment Policy or UQ’s Procurement Policy respectively.

Sources of research funding need to be disclosed so that research outputs can be objectively assessed by users. All sources of financial and in-kind support for a research output must be disclosed in the acknowledgements of the research output in accordance with the UQ Authorship Procedure. 

Where a conflict relates to the commercialisation of research, this procedure must be read in conjunction with the Commercialisation Conflicts of Interest Procedure.

This procedure does not apply to members of Senate. The Conflict of Interest and Disclosure Procedure for Members of Senate provides the process for members of Senate to disclose and manage a conflict of interest.

2.0   Process and Key Controls

  1. All staff must assess their private and personal interests and identify whether those interests may conflict with their official UQ duties and responsibilities.

  2. All staff are required to disclose their conflicts of interest and suggest management plans for approval using the online disclosure tool.

  3. Local Managers review conflict of interest management plans to ensure the efficient and effective management of the conflict of interest.

  4. Conflict of interest management plans are approved by the relevant approval authority.

Once a staff member discloses a conflict of interest and suggests a management plan using the online disclosure tool their Local Manager will review the management plan and either request further information or changes to be made by the staff member, or recommend the management plan be  approved or not by the Senior Leader.

Senior Leaders will review the management plan and either request further information or that changes are made by the staff member before they approve the plan or not.

3.0   Principles and Key Requirements

3.1   Identifying a conflict of interest

A conflict of interest may include circumstances involving a staff member’s:

  • competing external interest or obligation;

  • personal financial interest;

  • personal relationships; or

  • receipt of personal benefits.

When considering whether a conflict of interest exists, staff should consider:

  • whether the interest, relationship or obligation is consistent with community values, standards and behaviours, and the principles outlined in the University’s Code of Conduct;

  • how the interest, relationship or obligation might be viewed or perceived by other people; and

  • whether the interest, relationship or obligation may compromise their ability to exercise impartial leadership, management or judgment.

Staff should also alert supervisors to conflicts of interest held by other staff where they have a reasonable belief the conflict of interest has not previously been disclosed.

3.2   Disclosing a conflict of interest

When a staff member identifies a conflict of interest, they must disclose the conflict using the online disclosure tool and submit it to their supervisor.

Where a conflict of interest arises during a meeting, the staff member must verbally disclose it and have it formally noted (e.g. in minutes of the meeting).

Where a supervisor becomes aware of a potential conflict of interest that has not been disclosed by a member of their staff, they should discuss the matter with the staff member and ensure the conflict is disclosed and managed appropriately using the online disclosure tool.

Where circumstances affecting an existing or previously disclosed conflict of interest change, the staff member must amend the disclosure and submit a revised disclosure and management plan using the online disclosure tool for approval.

3.3   Managing a conflict of interest

When a staff member has identified and disclosed a conflict of interest, they must develop a plan with their supervisor to resolve or manage the conflict. A conflict of interest management plan includes:

  • the nature of the staff member’s private interest;

  • the interests of the University with which the staff member’s private interest conflicts;

  • the likelihood of the interests conflicting;

  • an outline of risk management strategies to be implemented; and

  • the recommended measures to be taken.

Once a conflict of interest management plan has been developed, it must be approved by the relevant Senior Leader using the online disclosure tool.  

The management plan should be reviewed annually or when circumstances change involving the staff member’s conflict. The staff member and their supervisor are responsible for ensuring that the management plan remains appropriate.

3.4   Disclosure and management of interests

The Conflict of Interest Policy and associated Procedures is part of a framework for the governance and management of public and private interests across a number of related areas of activity.

The disclosure and management of these interests requires relevant staff to complete the following:

  • Conflict of Interest Disclosure Tool

  • Secondary Employment Register

  • Sensitive Research Register

  • Foreign Influence and Interference Register.

To complete the Foreign Influence and Interference Register, staff are required to enter data into the Individual Activity Profile that relates to supervision of students at foreign institutions and the holding of honorary/adjunct appointments at foreign institutions.

3.5   Privacy

Any personal information collected, stored, used or disclosed under this procedure must be handled according to the University's Privacy Management Policy.

4.0   Roles, Responsibilities and Accountabilities

Effective conflict of interest management at the University depends on the collaborative efforts of staff members and their supervisors, in consultation with other relevant parties as outlined below.

4.1   University staff

Staff are responsible for identifying whether a private or personal interest conflicts with their official University duties and responsibilities.

Staff must complete mandatory training, undertake regular self-assessment of their private and personal interests and disclose and manage any relevant conflicts.

Where a staff member is unsure about whether they have a conflict of interest they should seek advice from their supervisor in the first instance. Supervisors may seek advice from their Senior Leader or from the Integrity Unit if they require further clarification.

If a conflict of interest ceases to exist, then the relevant staff member should advise their supervisor using the online disclosure tool ensuring the record is closed and no longer subject to a management plan.

4.2   Supervisors

4.2.1   Local Manager

For the purposes of this procedure, a Local Manager is a staff member appointed to Authority Level 4 under the UQ Human Resources Sub-Delegations Instrument.

In addition to the responsibilities in section 4.1, the Local Manager is required to:

  • Work with persons at or below Level 4 within their team(s) to refine management plans for conflicts that have been disclosed to them;

  • Recommend management plans for conflicts involving persons below Level 4 within their team(s) or organisation unit for Senior Leader approval;

  • Seek advice on how to manage conflicts of interest where necessary;

  • Ensure all staff in their team or Organisational Unit undertake annual conflict of interest self‑assessment and disclosure; and

  • Monitor and manage any conflict of interest and management plan within the conflict of interest register (as described in section 5.1 of the Conflict of Interest Policy) involving staff under their supervision until a point in time when a conflict no longer exists.

4.2.2   Senior Leader

For the purposes of this procedure, a Senior Leader is a staff member appointed to Authority Level 3 or their nominee (not below level 4) under the UQ Human Resources Sub-Delegations Instrument.

In addition to the responsibilities in section 4.1, the Senior Leader is required to:

  • Review and approve where appropriate management plans that are recommended to them by a Local Manager;

  • Work with persons at or below Level 3 within their team(s) to refine management plans for conflicts that have been disclosed to them, and approve where appropriate;

  • Seek advice from the Deputy Vice-Chancellor (Research and Innovation) to formulate a management plan for a commercialisation or financial conflict of interest where appropriate; and

  • Monitor and manage any conflict of interest and management plan within the conflict of interest register (as described in section 5.1 of the Conflict of Interest Policy) involving staff under their supervision until a point in time when a conflict no longer exists.

4.2.3   Executive Leader

For the purposes of this procedure, an Executive Leader is a staff member appointed to Authority Level 2 under the UQ Human Resources Sub-Delegations Instrument.

In addition to the responsibilities in section 4.1, the Executive Leader is required to:

  • Work with persons below Level 2 within their team(s) to refine management plans for conflicts that have been disclosed to them, and approve where appropriate;

  • Approve and manage complex or sensitive disclosures or management plans that are referred to them by a Senior Leader, or otherwise referred; and

  • Monitor and manage any conflict of interest and management plan within the conflict of interest register (as described in section 5.1 of the Conflict of Interest Policy) involving staff under their supervision until a point in time when a conflict no longer exists.

4.2.4   Vice-Chancellor and President

In addition to the responsibilities in section 4.1, the Vice-Chancellor and President is required to:

  • Work with members of Executive Leader (Level 2) to refine management plans for conflicts that have been disclosed to them and approve where appropriate;

  • Approve and manage complex or sensitive disclosures or management plans that are referred to them by an Executive Leader, or otherwise referred; and

  • Monitor and manage any conflict of interest and management plan within the conflict of interest register (as described in section 5.1 of the Conflict of Interest Policy) involving staff under their supervision until a point in time when a conflict no longer exists.

4.2.5   Integrity Unit

The Integrity Unit is responsible for:

  • administering conflict of interest training and maintaining the staff self‑assessment tool;

  • investigating serious breaches of this procedure and the University Code of Conduct in relation to conflicts of interest; and

  • maintaining records of all conflict of interest matters it investigates, including outcomes and any external referrals that have been made.

5.0   Monitoring, Review and Assurance

The Provost and Chief Human Resources Officer is responsible for:

  • reviewing this procedure regularly and in consultation with relevant stakeholders; and

  • raising awareness of the Conflict of Interest Policy and procedures across the University to build an organisational culture that supports supervisors and staff in its implementation.

6.0   Recording and Reporting

6.1   Disclosure and management of interest Register

A University disclosure and management of interest register must contain:

  • conflicts of interest that have been disclosed using the disclosure tool; and

  • approved conflict management plans.

7.0   Appendix

7.1   Definitions and terms

Academic administration (including research administration): means any administrative aspect of a student’s enrolment in a program at the University including admission, enrolment and assessment.

Conflict of interest: is a situation where an actual, perceived, or potential conflict exists:

  • an actual conflict involves a direct conflict between a staff member’s duties and responsibilities to the University and a competing interest or obligation, whether personal or involving a third party.

  • a perceived conflict exists where it could reasonably be perceived, or give the appearance, that a competing interest could improperly influence the performance of a staff member’s duties and responsibilities to the University.

  • a potential conflict of interest arises where a staff member has an interest or obligation, whether personal or involving a third party, that could conflict with the staff member’s duties and responsibilities to the University.

Supervisors: refer to Section 6.1 of the Conflict of Interest Policy.

University staff: refer to Section 6.1 of the Conflict of Interest Policy.

Custodians
Chief Human Resources Officer
Provost Professor Aidan Byrne

Forms

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Conflict of Interest - Printable Disclosure Form (only for casual and unpaid staff)

Conflict of Interest - Printable Disclosure Form (only for casual and unpaid staff)

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Description: 

Casual staff and unpaid staff should use this form as instructed in the Conflict of Interest policy and procedures.

Custodians
Chief Human Resources Officer
Provost Professor Aidan Byrne
Conflict of Interest – online disclosure tool (for continuing and fixed-term staff)

Conflict of Interest – online disclosure tool (for continuing and fixed-term staff)

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Description: 

Online disclosure tool (for continuing and fixed-term staff) for declaring a conflict of interest.

 

Custodians
Chief Human Resources Officer
Provost Professor Aidan Byrne
Custodians
Chief Human Resources Officer
Provost Professor Aidan Byrne
Custodians
Chief Human Resources Officer
Provost Professor Aidan Byrne