Activity-based conflict of interest management

In the course of your APS career, you may be asked to participate in or lead activities that carry a higher risk of potential conflict of interest. These activities may involve making decisions about expenditure of public money, or decisions that could benefit or disadvantage individuals or stakeholders. Examples of these activities include, but are not limited to:

Procurement
Grant allocation
Contract management
Policy consultation with external entities
Regulatory activity
Recruitment
Investigations, inquiries or reviews.

These activities are considered higher risk because of the potential harm that can result from an employee compromising the activity to serve a personal interest.

When undertaking these activities it is necessary for you to complete a new conflict of interest declaration identifying any material personal interests or competing duties that may impact (or may reasonably be perceived to impact) the activity. Declarations are required in these circumstances even if you do not have any material personal interests or competing duties to disclose.

Agency Heads and SES employees must also submit a declaration in these circumstances, in addition to their mandatory annual declaration, in order to identify any personal interests or competing duties that relate to the specific activity they are undertaking.

If a potential conflict of interest is identified, it must be assessed and appropriately managed.

Declarations of interests and approved conflict management plans should be made in writing and stored appropriately in agency recordkeeping systems.

Employees should refer to relevant legislation, APS or Commonwealth-wide guidance, and agency policies when undertaking higher-risk activities.

Further information on specific activities and relevant conflict of interest management and other integrity requirements which may apply is available at the following resources:

Procurement

Ethics and Probity in Procurement | Department of Finance

Grant Allocation

Commonwealth Grants | Department of Finance

Commonwealth Grants Rules and Principles 2024 - Federal Register of Legislation

Contract management

Contract Management Guide | Department of Finance and Ethical Conduct of Suppliers | Department of Finance

Policy consultation

Management Advisory Services Panel | Department of Finance

Regulatory activity

Regulator Performance (RMG 128) | Department of Finance

Recruitment