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(1) The purpose of this policy is to set out a framework for the identification, declaration, and management of conflicts of interests for University employees and others engaged in University business. (2) The University is committed to conducting its business and delivering higher education and research in a fair, transparent, accountable, and impartial manner that ensures public trust and confidence. (3) Conflicts of interest commonly occur in all types of situations. If not properly managed, these can expose the University to risk that decisions or actions are based on personal or other external influences, rather than being made for proper purposes in the best interests of the University. (4) This policy applies to all University representatives. (5) This policy should be read in conjunction with the University’s Code of Conduct, and is supported by procedures and guidelines which are mandatory to demonstrate compliance with this policy. (6) University controlled entities are expected to establish and implement their own conflict of interest policies, but may resolve to adopt this policy. (7) For the purpose of this policy: (8) All University representatives have obligations to act honestly and in good faith at all times, including observing obligations of confidentiality. (9) The obligation to disclose, and to avoid or minimise, conflicts of interests applies where: (10) The University requires all University representatives act ethically at all times, with openness and fairness, and to proactively safeguard the performance of their official duties and responsibilities as University representatives against conflicts of interest. (11) This requirement recognises the University's legal obligations in dealing with the disclosure, management, and reporting of conflicts of interest that apply to University representatives. These include: (12) The University will maintain a Conflict of Interest Register where the disclosure, management and reporting of conflicts of interests are recorded, monitored, and managed. (13) The University will also require specified University representatives to complete annual declarations of interests in order to comply with relevant legislative or governance standards. (14) The University requires all University representatives to actively and continuously: (15) All staff are required to report any breaches of this policy to their supervisor, a senior manager of the University, the Office of Audit and Risk Assessment, or a Public Interest Disclosures Officer under the University's Whistleblowing (Reporting Corruption and Other Serious Wrongdoing) Policy. (16) The University Executive, senior staff and all managers and supervisors play a leading role in ensuring a culture that exemplifies best practice and sets the benchmark for ethical behaviour. In particular, they are expected to: (17) The University will ensure that University representatives have access to programs designed to raise awareness and to assist them in carrying out their responsibilities and duties, including through induction and other training initiatives. (18) The University regards non-compliance with this policy as a serious matter and, depending on severity and impact, will take appropriate action, which may include disciplinary action or cancellation of a contract with an external supplier. (19) The University may also refer any non-compliance with this policy for independent investigation or to an external reporting agency, such as Independent Commission Against Corruption or the NSW Auditor-General. (20) Information concerning disclosures of conflicts of interest will be managed in accordance with the University’s Privacy Policy and Privacy Management Plan. (21) The University will implement appropriate systems and controls (including as part of any contractual arrangements) to ensure that conflicts of interest involving agents and contractors of the University are identified, declared and managed appropriately. (22) See Conflicts of Interest Procedures. (23) See Conflicts of Interest Guidelines.Conflict of Interest Policy
Section 1 - Purpose and Context
Part A - Introduction
Part B - Application
Section 2 - Definitions
Top of Page
Section 3 - Policy Statement
Part C - The Conflicts of Interest Rule
Part D - University’s Requirements
Part E - The University’s Expectations of Conduct
Part F - Raising Awareness and Training
Part G - Consequences of Non-Compliance
Part H - Privacy
Part I - Agents and Contractors
Section 4 - Procedures
Section 5 - Guidelines