Conflict of interest policy

This policy should be read in conjunction with the employment agreement of the individual employee. If there is any conflict between this policy and the relevant employment agreement, the terms of the employment agreement supersede these guidelines.

The purpose of this policy is to outline Education Payroll’s approach to identifying and managing conflicts of interest.

Policy statement

Education Payroll’s (our/ we) policy is to have all conflicts of interest identified, assessed, managed
and monitored, to ensure our employees and contractors (you) can perform your duties in the public
service with integrity and honesty. Identifying and managing conflicts of interests is an integral part of
our risk management and assurance programmes.

Application

This policy applies to:

• current and prospective employees
• contractors
• board members.

Definition

A conflict of interest is a perceived or actual conflict between your personal interests and the
duties and responsibilities you have to Education Payroll. Conflicts of interests can also arise
between different duties and responsibilities you hold within Education Payroll and if you have
secondary employment outside of Education Payroll.

Key principles

All conflicts must be declared

You must:

• declare any potential conflicts of interest:
  • before joining Education Payroll
  • when you become aware of one during employment or your contract
• let your People Leader and the People and Culture team know if a declared conflict has
  disappeared
• let the chair of any relevant decision-making body or group know if you have a conflict of
  interest
• seek your People Leader’s approval prior to accepting secondary employment or declare it
  prior to accepting employment with Education Payroll
• not enter any contractual arrangements that could compromise Education Payroll.

People leaders must:

• during interviews, ask all candidates about potential conflicts of interest
• respond to declarations of interest in a timely manner. They must either:
  • accept there is low, or no risk and authorise you to continue your duties
  • accept there is a risk and establish a plan to manage or avoid the conflict
• inform the Chief Executive of conflicts of interests for senior leaders
• remain aware of, and raise, any potential conflicts of interest with their team members.

Chairs of decision-making groups must:

• facilitate the group to raise any conflicts before decisions are made.

We will:

• maintain a conflict of interest register and review this at least once a year
  • a separate board member declarations register will be managed by the Executive Principal Advisor
  • all service provider declarations will be managed by the Procurement and Contracts Manager
• handle declarations of interests with due regard to the privacy of those involved
• support people leaders to create management plans for declared conflicts of interest
• support the Board Chair in informing any declarations made by the Chief Executive to the Public Services Commission.

All conflicts must be managed or removed

You must:

• follow any plan agreed to manage or remove your conflict of interest
• not take part in work or decision making that could be biased or compromised by a conflict of
  interest
• raise with People and Culture or a member of the Executive team if you have any concerns
  about how conflicts of interest are being managed.

People leaders must:

• ensure there are appropriate plans in place for all conflicts of interest in their team.

Training and awareness will be provided

You must:

• participate in all training and read all awareness material.

We will:

• provide this policy to all new hires and contractors and ask them to declare any conflicts of
• interest
• provide conflict of interest training at induction for all new staff, contractors and people
  leaders
• provide conflict of interest reminders to all staff at least twice annually.

Non-compliance

Failure to declare personal interests or failure to follow conflict of interest management plans could
be considered serious misconduct and result in disciplinary action, up to and including dismissal.