Conflict of Interest Policy

Basic guidelines

A conflict of interest exists where there is a divergence between the employee’s personal interests and their professional obligation to Diabetes Victoria.

An actual conflict of interest arises in a situation where financial or other personal and professional interests compromise an employee’s objectivity, judgment, integrity, and/or ability to perform their current duties and responsibilities.

A perceived or potential conflict of interest exists in situations where an employee, an employee’s family member, or a close personal relation has financial interests, personal relationships or professional associations with an outside individual or organisation, such that his or her activities could appear to be biased due to the interest or relationship.

Employees must, at all times, act in a manner which will avoid actual, potential or perceived conflicts of interest.

Examples of conflicts of interest

Without limiting the circumstances, the following are examples which can give rise to a conflict of interest:

• An employee or a family member or close friend has a financial interest in a business which supplies goods or services to the company.
• An employee takes a service provider of the company to lunch, in circumstances where the employee hopes to obtain a personal benefit, such as discounted goods or services.
• An employee receives a gift or benefit of value from a supplier of goods or services who already does, or wishes, to do business with the company. From time to time, employees dealing with external organisations may receive token benefits as part of the normal business relationship. This type of benefit should not be regarded in itself as a breach of this policy. However, a continuing pattern of such token benefits, outside of the specific business relationship may be seen as a potential conflict of interest.
• An employee acts on the basis of personal friendship or personal animosity to advantage or disadvantage a fellow employee.
• An employee discloses confidential information derived in the course of employment for their own personal gain.
• An employee influences a customer in purchasing goods and services that may result in greater cost savings for the company, even though the advice may not be in the customer’s best interest.
• An employee uses the company’s resources, such as printing or photocopying, to assist in the conduct of private business.

Conflicts of interest may or may not involve monetary or financial gain (or the avoidance of financial loss). For example, an employee may choose not to disclose an error in the performance of their duties because it might affect their next performance assessment.

In cases where Diabetes Victoria is providing consulting or other advisory services, it is important to be conscious of potential conflicts of interest between the interests of two different clients.

Disclosing conflicts of interest

Any employee who feels that they are, or may be, in a position of an actual, potential or perceived conflict of interest, must disclose the matter immediately to their manager. Managers will refer the matter to the HR Services and Workplace Relations Manager and will take advice from the Chief Executive Officer on the resolution of the conflict.

Upon disclosure, actions determined to resolve or eliminate any conflict of interest must be implemented immediately. These may include:

• Reorganising duties of the employee to remove the conflict of interest.
• Introducing additional processes to ensure the impartiality of the employee in performing his or her duties.

Details of the disclosure, assessment and resolution of conflict will be placed in the employee’s personnel file. All information regarding conflicts of interest is confidential and disclosed only to employees with delegated authority for dealing with such matters.

Employees who are uncertain if a potential or actual conflict of interest exists should seek advice from their manager or the People & Culture department.

Any employee with a complaint about a fellow employee acting in breach of this policy may raise the matter with the HR Services and Workplace Relations Manager. This complaint will be investigated and resolved appropriately.

Failure to disclose conflicts of interest

Failure to disclose conflicts of interest is a matter of utmost seriousness.

Depending on the circumstances, disciplinary action may be taken against an employee who has a conflict of interest. This may include immediate termination of employment for serious misconduct.