Developing and adopting the model conflict of interest policy is just the start. Even the most comprehensive policy is ineffective if it is not implemented properly.
The guidance and tools on this page will assist organisations to implement the model conflict of interest policy and to promote it with employees and stakeholders. Some of the most important things to consider in implementing a conflict of interest policy are education and training, leadership and communication.
Education and Training
Ongoing training and education about the policy and associated procedures are essential for embedding the model policy within the organisation. This should form part of the induction process for employees when discussing the application of the Victorian public sector values of integrity, impartiality and accountability and how these apply to their roles.
Organisations may also consider compulsory training for managers as well as employees or contractors involved in high-risk areas or activities (such as recruitment, procurement, and contract management). Whilst training for all employees is desirable but not always practical or feasible, it may be possible to maximise employees’ awareness through other means, including:
- Short videos featuring senior leaders discussing conflict of interest
- Organizational newsletters
- Team meeting agenda items
- Intranet news items or other electronic communications.
Leadership is fundamental to implementing the model conflict of interest policy. It must be clear to all within the organisation that the CEO and senior leaders sponsor the policy and will enforce adherence to it, including taking decisive action in response to breaches.
This sponsorship and support must be expressed in what leaders and managers say as well as in the way that they behave. Having a senior manager as a contact person for discussion of issues relating to possible conflict of interest may assist with reinforcing the importance of the policy.
An effective communication strategy is necessary to support the implementation of the model policy. This should include general information about the policy, how it works and where to get information, as well as targeted communication designed to remind people of their responsibilities at crucial times (such as before they commence procurement or recruitment activities).
Evaluating and reviewing your policy
Measuring the effectiveness of a policy and processes requires monitoring and evaluation of the policy. This is more than just monitoring individual conflict of interest, it involves monitoring the policy and processes overall.
The tools on this page will assist organisations to monitor the effectiveness of their policy and of the management of conflict of interest risks.
Organisations may also measure employees’ awareness of their conflict of interest policy and processes. This can be as simple as participating in the People Matter Survey conducted by the VPSC. This survey contains questions on integrity that can help gauge whether employees believe that their organisation adheres to the public sector values and adheres to high standards of conduct and behaviour.