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.

Activities and functions that may increase the risk of a conflict of interest

Conflicts of interest may arise anywhere in an organisation., However some activities and functions may put employees at greater risk of a conflict of interest because of their ability to make decisions that benefit others. These include:

Making binding decisions including:

  • Issuing determinations on matters
  • Passing binding judgments
  • Exercising powers over planning and land development

Regulating individual or business activities including:

  • Inspecting, regulating, or monitoring standards, businesses, equipment or premises
  • Issuing qualifications or licences
  • Issuing or reviewing fines or penalties

Distributing funds or other benefits including:

  • Allocating grants of public funds
  • Allocating subsidies, financial assistance, concessions, or other relief (including non-financial)

Procurement  including:

  • Procuring goods or services
  • Tendering for and managing contracts

Recruitment including:

  • Making appointments to positions

Private interests that may increase the risk of a conflict of interest

Organisations should remind employees of their obligations to avoid or, if this is not possible, to manage any conflicts between their public duty and their personal interests.

All employees have private interests. In some circumstances their private interests may conflict with their public duties. Factors that employees should consider include:

Financial matters including:

  • Financial and economic interests (such as significant liabilities, 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

Prosptective employment including:

  • Promise or prospect of future employment with a person or organisation that the  employee interacts with as part of their public duties.

Other public duties including:

  • Access to privileged or confidential information in another public sector role
  • Holding two or more public sector roles with conflicting accountabilities

Family and personal relationships including:

  • Obligations to family or friends
  • Competition with another person or group

Group affiliations including:

  • Affiliations with not-for-profit, social or community organisations
  • Affiliations with political, or professional organisations

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 gifts, benefits and hospitality. See the Gifts, benefits 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.


Additional resources

Checklist for identifying risks of conflict of interest in organisational functions

This checklist assists organisations to identify conflict of interest risks when developing their conflict of interest policy.

Last updated July 2016.

Checklist for identifying risks of conflict of interest in organisational functions
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