Declaring a conflict of interest

All staff are expected to actively engage in the identification and management of conflicts of interest.

The Charles Sturt Conflict of Interest Procedure requires all employees to declare conflicts of interest to the Division of People and Culture. This applies to all actual, potential or perceived conflict of interests.

Supervisors are responsible for modelling good behaviour and taking an active role in identifying, preventing and managing conflicts of interest (COI). This includes initiating discussions with staff and managing queries from any employee about conflicts of interest that staff may have.

In most cases, each employee involved in a conflict of interest must make a declaration or seek approval for additional employment, including self‑employment. In situations  such as personal relationships, it may be sufficient for only the person with the highest level of authority or influence to declare the conflict. However, any employee can make a declaration.

Steps for making a declaration

Chart - process for declaring conflict of interest

Step 1

Identifying a conflict of interest

To determine whether a Conflict of Interest (COI) exists, consider the following questions in the context of your past/present/future relationships, obligations and affiliations and discuss the circumstances with your supervisor.

  • Do I have a personal interest that does not allow me to act in a fair, impartial and objective manner?
  • Are there factors that may influence my ability to maintain fairness, impartiality and objectivity?
  • Are there factors that could compromise my ability to perform general and specific responsibilities of a Charles Sturt employee?
  • Are there benefits or losses for me or a close associate, now or in the future, that could impact or cast doubt on my conduct?
  • Do I have a personal interest that could be perceived by colleagues or external parties to conflict with my professional duty?
  • Would a neutral, reasonable person believe I should be removed from the situation?
  • Would a neutral, reasonable person believe controls should be implemented to sufficiently manage or prevent a COI?
  • Would my involvement withstand public scrutiny?
  • Would my actions be illegal and non-compliant with University policy and procedure?
  • Are there perception risks for me and/or the University?
  • Are there consequences for me, other parties, colleagues, the University and the public if I ignore a conflict of interest?

Did you answer yes to any of the above questions?

You must declare your COI.

  • Refer to the Employment Conditions Procedure – Additional Employment and University Consultancies Glossary for definitions of additional employment, University consultancy and research consultancy.
  • Employees seeking approval for a University Consultancy must submit a Request for University Consultancy Approval form , a Budget Tool and all other supporting documentation to their Head of School (HOS) or delegate/supervisor. If multiple employees and/or students will participate in the consultancy, the lead employee must take extra steps to gather all information required for form fields relating to additional internal parties prior to seeking approval from their own HOS or delegate/supervisor. Refer to the University consultancy webpage for details.
  • Research consultancies must be approved under the processes established by the Office of Research Services and Graduate Studies.

Step 2

Discuss your conflict of interest with your supervisor

In order to develop safeguards and oversights that will sufficiently manage or prevent a conflict of interest, you must have an open and transparent conversation with your supervisor (or another senior officer within your work area). Your supervisor must:

  • assist and guide you to understand your roles, responsibilities and rules of their position
  • reinforce University policies, procedures and ethical standards
  • protect information about disclosed conflicts of interest from misuse
  • discuss the 5 R's to determine the most appropriate safeguards and oversights to manage the COI:
    • Restrict – Limit your involvement in the matter. For example, refrain from voting on a decision where you have a personal interest.
    • Recruit – Involve an independent third party to oversee or review the process.
    • Remove – Withdraw from all involvement in the matter for as long as the conflict exists. For example, if a candidate for a position is a friend, remove yourself from the interview panel.
    • Relinquish – Give up your personal interests. For example, relinquish a membership to a club or association where it is creating a conflict of interest. However, this is not always reasonable (e.g. if the conflict is related to a family relationship) and no one can be forced to relinquish a personal interest.
    • Resign – As a last resort for serious conflicts of interest, you may be required to resign from your position.
  • agree safeguards and oversights that must be stated on the COI form and implemented to manage the COI
  • complete the supervisor section of the COI Declaration form.

Step 3

Seek Band 7 Approval

Your Band 7 leader must review the COI Declaration form and complete the Band 7 section to indicate approval of the proposed safeguards and oversights. They may request that you and your supervisor review and improve the safeguards and oversights before they add their approval.

  • Your Band 7 leader is either your Executive Dean or Executive Director (or other senior leader at Band 7 or above).
  • The Delegations and Authorisations Policy provides a list of positions associated to each band.

Step 4

Submit completed form to DPC

DPC will review the approved form and provide further comments and summary of controls including:

  • General and specific employee and supervisor responsibilities for managing the matter.
  • A summary of the basis for approval and/or mitigations approved by your supervisor and Band 7 leader.
  • Monitoring and formal review requirements.
  • A unique declaration number for your records and any future communications if needed.

If a COI is serious and carries high risk, DPC may formalise safeguards and oversights in a Conflict Management Plan (CMP). You will be notified by your supervisor or a DPC representative if a CMP is required. All parties will be given the opportunity to review and agree the final CMP.

Step 5

Monitor, review and report

Employees and supervisors are responsible for monitoring and regular formal review of matters as part of the employee’s performance and planning review. That is, the University’s Performance Planning Development and Review (PPDR) annual and mid-year check-ins.

Learn more

Further questions

For help identifying or managing a conflict of interest, please first contact your supervisor.

You can also contact another senior officer within your work area. If you are still unsure, it is safest to complete a declaration.

For further information or help email dpc@csu.edu.au or procurement@csu.edu.au.