• Section 1 - Overview
• Section 2 - Scope
• Section 3 - Procedures
• Examples of Conflicts of Interest
• Disclosing a Conflict of Interest Procedures
• Example emails for Declaration of Conflicts of Interest
• Section 4 - Definitions

Section 1 - Overview

(1) This procedure provides guidance on how the Conflicts of Interests policy should be applied in the course of carrying out official duties.

Section 2 - Scope

(2) This procedure will apply to all UNE Representatives.

Section 3 - Procedures

Examples of Conflicts of Interest

(3) Conflicts of Interest may occur in any area of an organization's activities. High risk areas include but are not restricted to:

1. Procurement - tendering and purchasing;
2. Staff recruitment - both formal and informal processes;
3. Secondary employment - both as staff member and as a business owner;
4. Serving as a member or director on boards, committees, advisory groups (or similar bodies) of government, for profit, or not for profit entities;
5. Staff Relationships with external contractors;
6. Post separation dealings with former staff;
7. Offer or acceptance of Gifts and Benefits;
8. Supervision of staff and students;
9. Relationships with students;
10. Research activities;
11. Consulting;
12. Use of University information for personal purposes; or
13. Performance management.

Disclosing a Conflict of Interest Procedures

Outside formal committees or meetings

(4) Any Conflict of Interest must be disclosed to the relevant supervisor via email. The staff member will provide the supervisor the following information:

1. The name of the parties involved;
2. A brief outline of the nature of the conflict; and
3. A brief outline of the proposed solution to manage/resolve the conflict.

(5) The supervisor will make a recommendation, via email to the Head of Cost Centre in regards to the appropriateness of the proposed solution to manage the conflict.

(6) The Head of Cost Centre will make a determination on the appropriateness of the proposed solution and either agree with the solution or provide an alternate solution. This determination will be communicated via email to the staff member and the supervisor.

(7) Where the Head of Cost Centre is the staff member with a conflict of interest, they will email the Relevant Senior Executive with the same information as outlined above.

(8) The email train containing all the correspondence will be emailed by the Head of Cost Centre/Relevant Senior Executive to conflictsofinterest@une.edu.au. Please ensure the title of the email contains the staff members staff number and surname.

(9) It becomes the responsibility of the staff members supervisor to ensure the conflict is managed as agreed in the email train as detailed above.

Inside formal committees or meetings

(10) Any Conflict of Interest must be disclosed either in writing or verbally to the chair or other person presiding over the meeting. The staff member must provide the following information:

1. The name of the parties involved;
2. A brief outline of the nature of the conflict; and
3. A brief outline of the proposed solution to manage/resolve the conflict.

(11) The committee/members must do the following:

1. Make a determination in regards to the appropriateness of the proposed solution to manage the conflict;
2. Ensure all information is clearly documented in the minutes of the meeting;
3. Ensure conflict is managed as agreed in the details outlined above; and
4. Ensure once the minutes are approved, an excerpt of the minutes is emailed by the secretary/minute taker to conflictsofinterest@une.edu.au or other appropriate TRIM repository as approved by the University Secretary.

Example emails for Declaration of Conflicts of Interest

(12) Outside a formal committee or meeting

(13) Inside a formal committee or meeting

Section 4 - Definitions

(14) For the purpose of this policy the following definitions apply:

1. Conflict of Interest - means
   1. A UNE Representative will have a Conflict of Interest where:
      1. The UNE Representative has a material interest in a decision or matter; and
      2. The UNE Representative's interest appears to raise a conflict with the proper performance of the UNE Representative's duties in relation to the decision or matter.
   2. If a UNE Representative has a Conflict of Interest then the two key issues are:
      1. Disclosure of the conflict of interest by the UNE Representative; and
      2. Management of the conflict of interest.
2. Non-pecuniary Interest - These interests do not have a financial component but may arise from Personal or Family Relationships or involvement in sporting, social or cultural activities. They include any factor which would predispose the UNE Representative towards favor or prejudice resulting from friendship, animosity or other personal involvement that could bias the UNE Representative's judgment or decisions.
3. Pecuniary Interest - These are interests that involve an actual or potential financial gain or loss. They may result from the UNE Representative or a related party owning property, holding shares or a position in a company bidding for government work, accepting gifts or hospitality, or receiving an income from a second job. Money does not need to actually change hands for an interest to be pecuniary.
4. Personal or Family Relationship - means a relationship between an employee and a relative, a financially dependent person, a person where there is a financially connected relationship, a close friend, a de facto partner or any person with whom there is currently, or has been, an intimate or an agonistic relationship. This does not include a working relationship which exists due to ordinary collegiate collaboration, where colleagues are not relatives, financially dependent, de facto or intimate partners.
5. Relevant Supervisor - normally means the staff member's immediate supervisor.
6. Relevant University Senior Executive - normally means the Head of Cost Centre's supervisor.