Organisations must ensure the model conflict of interest policy reflects their level of conflict of interest risk.

This includes undertaking a risk assessment and building upon the minimum standards in the model policy to ensure high risk activities and functions are appropriately covered.

The guidance and tools on this page will assist organisations to assess their conflict of interest risk profile, including consideration of:

  • Their activities and functions
  • The community in which the organisation operates
  • The personal circumstances of employees and their private interests
  • The nature of client-contractor relationships.

When there is an intersection of function and interests, the conflict of interest risks increase.

Activities and interests with an increased conflict of interest risk

While conflict of interest may occur in any part of an organisation, some activities involve a higher risk than others. Similarly, while all employees have external interests, some interests are more likely to create concerns about conflict of interest than others. The tables below highlight some of the activities (Table 1) and interests (Table 2) that are likely to give rise to a higher risk of conflict of interest.

Table 1: Activities in organisations which increase the risk of conflict of interest

Categories of activities Examples of organisational functions/activities that may increase risk of conflict of interest
Procurement and recruitment
  • Procuring goods or services.
  • Tendering for and managing contracts.
  • Making appointments to positions.
Regulating individual or business activities
  • Inspecting, regulating, or monitoring standards, businesses, equipment or premises.
  • Issuing qualifications or licences.
  • Issuing or reviewing fines or penalties.
Distributing funds or subsidies
  • Allocating grants of public funds.
  • Allocating subsidies, financial assistance, concessions, or other relief (including non-financial).
Making binding decisions
  • Issuing determinations on matters.
  • Passing binding judgments.
  • Exercising powers over planning and land development.

Table 2: Key interests/associations which increase the risk of conflict of interest

Categories of association Interests or associations that may increase risk of conflict of interest
Financial matters
  • Financial and economic interests (such as significant liabilities or debts, assets including shareholdings, real estate holdings, investments or other financial interests).
  • Family or private business interests.
  • Interests such as trust or nominee companies, directorships or partnership holdings.
Group affiliations
  • Affiliations with not-for-profit organisations.
  • Affiliations with (or obligations to) political, trade union, or professional organisations.
  • Other personal interests and affiliations (including community and professional affiliations).
Other public duties
  • Access to privileged and confidential information as part of multiple public roles.
  • Holding another role as a public officer that potentially conflicts with other public duties.
Family and personal relationships
  • Obligations to family or friends.
  • Family businesses.
  • Competition with another person or group.
Employment prospects
  • Promise or prospect of future employment with a person or organisation which interacts with a public official’s duties.

Gifts, benefits and hospitality risks

Receiving gifts, benefits or hospitality can create a perception of a conflict of interest where decisions are made involving the giver of such gifts or benefits. The VPSC has set minimum accountabilities and provided guidance for the effective management of gift benefits and hospitality. See the Gifts and hospitality page for further information.

Your organisation’s conflict of interest policies and procedures should be linked to its policies and procedures for the giving and receiving of gifts, benefits and hospitality.

This resource suite contains:

Available formats

Checklist for identifying risks of conflict of interest in organisational functions

Download PDF 0.13MB (1 page)

Checklist for identifying risks of conflict of interest in client and contractor relationships

Download PDF 0.12MB (1 page)

Checklist for identifying risks of conflict of interest in restricted communities

Download PDF 0.11MB (1 page)

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