Conflict of interest policy process

Objectives

This process outlines how a conflict of interest may occur, how to disclose an actual or potential conflict of interest (COI) and options for managing the conflict.

For further guidance please refer to the Conflict of interest guideline.

Process steps

1. What is a conflict of interest?

1.1. A conflict of interest may occur in a number of ways including:

1.1.1. Links and associations to other organisations including directorships, memberships, governance roles, employment, volunteering etc.

1.1.2. Engaging in private paid outside work(excluding contractors and consultants);

1.1.3. Engaging in activities which adversely affect a staff member’s ability to perform duties or meet work objectives;

1.1.4. Staff member or their family or friends receiving money, gifts and benefits from individuals or organisations;

1.1.5. Staff member or their family or friends indirectly receiving a benefit or self-interest by unfairly/unreasonably preventing benefit to other parties.

1.1.6. Personal and family relationships with individuals including staff, students, suppliers, customers, decision makers etc;

1.1.7. Current research activity or affiliation with other research organisations and entities including intellectual property (IP) complications;

1.1.8. Use of University resources or branding for personal benefit;

1.2. If unsure whether a conflict of interest has occurred, then it should be declared.

2. How to disclose and manage a potential or actual conflict of interest

2.1. A Declaration of potential or actual conflict of interest form (DOCX 30kb, 2p) must be completed by the staff member and supervisor with the form signed by both parties.

2.2. If supervisor determines that there is a potential or actual COI, discussion between the staff member and supervisor regarding agreed outcomes needs to occur. Agreed outcomes may include:

2.2.1. reorganisation of duties;

2.2.2. additional processes;

2.2.3. assurances/commitments/undertakings from staff member;

2.2.4. change in time fraction;

2.2.5. ensuring others are made aware of the conflict as appropriate;

2.2.6. removal from student selection, supervision, assessment and appeal (whilst ensuring no disadvantage to the student);

2.2.7. paid/unpaid leave;

2.2.8. permission given to University to access private documentation or accounts;

2.2.9. obtaining insurance

2.2.10. removal from the preparation, letting, evaluation, opening and awarding of tenders.

2.3. If no agreement can be reached regarding how to reasonably manage the actual or potential conflict of interest then the matter is referred to a more senior supervisor. A decision will then be taken by the University which may include:

2.3.1. directing the staff member to take action to remove the conflict of interest;

2.3.2. reorganisation of duties/work arrangement so as to remove the conflict of interest;

2.3.3. establishment of parallel or alternative arrangements;

2.3.4. withdrawal of an offer of employment/contract for services;

2.3.5. instigation of disciplinary action for misconduct/serious misconduct.

2.4. If there is agreement regarding the outcome, even if it is determined that there is no conflict of interest, both staff member and supervisor must sign the form.

2.5. The completed signed form is forwarded to HR to be kept on the staff file.

2.6. The steps should be followed on every occasion as required during employment/engagement at RMIT University and its subsidiaries and associated entities.

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