Scenario-based training and guidance

In addition to providing clear policy guidance, agencies support their staff by providing education and training on how to identify, avoid, declare, and manage conflicts of interest. Scenario-based training—either through e-learning modules, interactive virtual sessions, or in-person sessions—is recommended to raise awareness of the conflicts that can arise in the context of different roles, responsibilities, and activities, and build employee and manager confidence and capability to manage conflicts. Areas of focus for training will be different in each agency, and should be tailored to agencies’ needs, high-conflict risk activities, and operating context.

Minimum requirements

Regularity of training – Training (e-learning) is conducted as part of induction, and on an annual refresher basis for all staff.

Note – High-conflict risk areas or activities may need more regular bespoke conflict of interest training.

Assessment Requirements – Training must include an assessment. Wrong answers are explained at the end but there is no ‘pass’ or ‘fail’ grade given.

Scenario-based training – Training contains scenarios that are relevant to conflict of interest risks specific to the agency.

Assurance – Supervisors must remind their teams to complete the training, and must provide the next level manager with confirmation once the training is complete each year.

Further considerations – Business areas are made aware that they can reach out to the enabling team responsible for agency conflict of interest policy for training or education resources as required.

Good practice

Regularity of training – As per minimum requirements, plus staff with supervisory responsibilities are required to complete mandatory annual manager-specific conflict of interest training.

Note – High-conflict risk areas are encouraged to conduct refresher training in between the annual requirement (either virtually or face-to-face).

Assessment Requirements – Training must include an assessment with a ‘Pass’ or ‘Fail’ grade given. Wrong answers are explained at the end with the requirement to reattempt incorrect answers. There is a limit of three reattempts at passing, and the employee must speak with their supervisor if they are unable to achieve the pass grade.

Scenario-based training – As per minimum requirements, plus the training covers various levels of complexity. Scenarios will cover both personal and agency conflicts of interest and contain scenarios to illustrate identifying, declaring, managing and monitoring a conflict of interest. Training scenarios are reviewed and updated every two years as part of training module updates (these updates are the responsibility of the agency). Manager-specific training is made available which managers may be required to complete.

Assurance – As per minimum requirements, plus annual reminders are issued to supervisors on the due date (if system capability allows) indicating training completions, which is then provided to the next level manager (or whoever agency deems appropriate). Alternatively, this list could be complied manually on an individual team level and reported to the manager.

Further considerations – As per minimum requirements plus the implementation of biannual drop-in sessions for conflict of interest awareness raising. Agencies can also consider implementing an ‘awareness campaign’, similar to Fraud Awareness Week, in relation to conflict of interest management. Simultaneously or alternatively, conflict of interest management could be incorporated into existing agency integrity awareness campaigns.

Excellent practice

Regularity of training – As per good practice, plus training is delivered via in-person or virtual face-to-face engagement.

Assessment Requirements – As per good practice plus employees are required to achieve a certain percentage of correct answers before being considered to have completed or passed the training. Components of the training are tailored to different classifications or roles to reflect relevant obligations and duties, as well as any changes to the operating environment/risk appetite.

Scenario-based training – As per good practice, plus scenarios for both general and manager-specific training are updated annually. Components of training are tailored to different classifications or roles to reflect relevant obligations and duties.

Assurance – As per good practice plus agency systems provide an individual reminder (via email) both prior to and on the due date of training. Agencies can take additional steps, including (but not limited to) the following:

• Once the due date lapses, the next level manager (or whoever the agency deems appropriate) is provided a list to confirm and follow up any staff who have not yet completed the training.
• If a gap in knowledge is identified through the training, this is discussed during the employee’s next one-on-one with their supervisor.
• Managers completing supervisor-specific training must obtain a ‘pass’ result for their assessment.

Further considerations – conflict of interest awareness is built into broader integrity education programs with the implementation of conflict of interest training sessions tailored for business areas and certain roles (for example, managers). Scenarios should also reflect organisational experience of failures of conflict of interest being adequately identified and managed. Feedback surveys to gauge staff understanding of conflict of interest matters and practices could feed into additional awareness. Annual reviews of training outcomes could be conducted to identify areas of poor knowledge or awareness, which can then be used to inform further education/training.