Purpose
This policy outlines the principles applying to the declaration of actual and potential conflict of interest.
The objectives of this policy are:
- To protect Western Student Connections interests in impartial and objective decision masking
- To protect the reputation of Western Student Connections by maintaining ethical standards of good judgment, fairness and integrity in all its dealings
- To ensure that employees always observe the highest standard of business ethics
- To avoid any activity or interest that might reflect unfavourably upon a staff member’s own integrity and good name, or upon the integrity and good name of Western Student Connections.
Scope
The policy applies to all staff employed by Western Student Connections and all Board and committee members.
Policy Provisions
All staff members performing work duties are required to act in good faith towards Western Student Connections.
Staff members must ensure there is no conflict of interest between their personal interests and their duties, obligations and responsibilities to Western Student Connections. Where such a conflict occurs, the interests of Western Student Connections will be balanced against the interests of the staff member.
Unless exceptional circumstances exist, the balance of interests will be resolved in favour of Western Student Connections.
Conflict of interest can be financial or personal and involves the interests of a staff member or members of the staff member’s family or friends.
Staff must disclose, of their own volition, actual or potential conflicts of interest to their manager and stand down in any decision making process where they may be compromised.
Failure of a staff member to disclose a potential or actual conflict of interest constitutes a breach of policy and may result in disciplinary actions. Depending on the nature and impact of the conflict of interest situation, other action may be instigated, including legal action.
Confidentiality is to be maintained at all times by all persons involved and Western Student Connections will seek to ensure that confidential disclosures are protected from misuse. The staff member who has disclosed the conflict of interest and the manager to whom the disclosure was made may seek advice from the CEO or other party.
Acceptance of Gifts or Benefits
As a general principle, staff should not seek or accept favours or gifts for services they perform in connection with their Western Student Connections employment from anyone who could benefit by influencing them in their official capacity.
Included in this category are gifts in kind, which go beyond common courtesies consistent with ethical and accepted business practices.
This principle extends to favours and gifts extended to staff member’s family. Accepting such gifts may expose staff and/or Western Student Connections to accusation of bias or favourable consideration.
Close Personal Relationships
Conflict of interest situations may arise from close personal relationships, including family and emotional relationships.
Employment Related Matters
Partners, family members or close friends of staff should only be employed where an appropriate independent merit selection process has been observed.
A person who has the delegated authority to employ a staff member cannot authorise the employment of a family member. The employment approval must be gained from their immediate manager.
Partners, family members or close friends cannot be in a direct supervisory relationship to each other. However, the existence of a close personal relationship with a staff member should not constitute a bar to the employment of any individual.
A staff member in an acting position cannot sign off on their own recommendations.
Financial Decision Making
Purchase of goods and services must be made on the basis of merit. No preference in the placement of orders will be given to any member of staff, Board member, gift donor, or any person associated with Western Student Connections in any capacity.
It is policy that Western Student Connections should not have any dealings with companies in which members of staff or Board members, or their relatives have an interest, unless it can be demonstrated that it is in the interests of Western Student Connections to have such dealings.
All members of staff are advised to carefully consider all of the implications of any personal dealings with outside concerns that would appear to involve the commitment of Western Student Connections.
Use of Western Student Connections Facilities and Equipment
Staff members are expected to use facilities and equipment, including technology and the Internet, efficiently, carefully and honestly.
Resources must not be used for financial gain or for political purposes without express permission of the CEO. Any agreement for personal use should be minimal and strictly limited.
Declaration of Potential or Actual Conflict of Interest Procedure
| |
Procedure |
Responsibility |
Timeline |
| 1 |
A staff member involved in a situation where there is or may be a conflict of interest must disclose this situation be completing and submitting a Declaration of Potential or actual conflict of Interest Form to their manager.
The staff member must also withdraw himself or herself immediately from the situation giving rise to the conflict, pending advice from the manager to whom the disclosure was made. |
Staff member |
Immediately when identified |
| 2 |
Where the manager decides there is no conflict of interest the staff member is authorized to continue the activity.
The manager and staff member must identify the circumstances in which conflict of interest could occur, and how it would be resolved. |
Manager |
Following review of the declaration |
| 3 |
Where the disclosed situation reveals a conflict of interest, or is likely to be perceived as involving a conflict of interest, the manager will:
- Ask the staff member to take action to remove the conflict of interest or
- Reorganise the duties of the staff member so as to remove the conflict of interest or
- If considered necessary, ensure that the staff member’s involvement in the situation or activity is withdrawn immediately, and establish parallel or alternative arrangements specifically for the purpose of the activity.
|
Manager |
Following review of the declaration |
| 4 |
The manager must record agreements regarding how to manage the potential or actual conflict of interest in writing. The manager will retain a copy and provide a copy to the staff member and the CEO. |
Manager |
Following review of the declaration |
| 5 |
Where the withdrawal of the staff member’s involvement in the situation is not practical or appropriate and their involvement does not breach any statutory or other duty, the manager will ensure that others involved in the situation are informed of the potential conflict of interest. |
Manager |
Following review of the declaration |
| 6 |
Where the manager does not agree to allow the staff member to continue the activity that is subject of the disclosure, the staff member may seek to renegotiate this through a meeting with the CEO. |
Staff member |
Following a decision by the manager that the staff member must cease the activity |
Dowload Conflict of Interest Declaration Form
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