Conflict of interest obligations during APS employment
Your conflict of interest declaration and management obligations continue after you commence employment, and your initial declaration and plan should be reviewed at regular intervals. APS employees must always stay aware of how their personal interests could conflict—or could reasonably be perceived to conflict—with their powers, functions, or duties as a public official.
Having a personal life, a prior work history, a wide professional network, close connections with community, and interests outside of work are all normal aspects of being a public servant. Even if from time to time there is a conflict between those things and your APS employment, most conflicts can usually be managed.
See also Section 5: Conflict of Interest | Australian Public Service Commission and NACC’s Corrupt conduct and conflicts of interest – A guide for public officials
You must always consider potential conflicts that may arise when your role or duties change, when you are involved in activities that carry a higher risk of conflict of interest, such as recruitment or procurement processes, or when there is a change in your personal circumstances.
Agency Heads and Senior Executive Service (SES) employees are subject to a specific regime that requires them to submit, at least annually, a written declaration of their own and their immediate family’s financial and other material personal interests.
While all APS employees have an obligation to declare potential conflicts as they arise, declaring the conflict is not enough on its own. Conflicts of interest must also be assessed and appropriately managed to ensure they do not compromise an employee’s real or perceived ability to perform their duties. Key to this is ensuring appropriate record keeping of declarations and management plans.
Leaders and managers should pay close attention to the potential for conflicts of interest to arise for their staff as well as for themselves, and agencies should establish systems and processes to support all staff to avoid conflicts where possible, or appropriately manage declared conflicts where necessary.
The Department of Finance’s Resource Management Guide 208 on Managing Conflicts of Interest and Confidentiality identifies four risk-based principles for managing conflicts:
Principle 1 – Know
Conflicts of interest are common and can arise in many different contexts. Employees must understand the objective of the role/activity they are performing, as well as their own personal interests and competing duties.
Principle 2 – Disclose
Any material personal interests or competing duties relating to the affairs of the agency must be disclosed to allow a conflict to be identified.
Principle 3 – Assess
Understand disclosed material interests and how they relate to the role/activity being performed. The nature of any personal relationships must be considered.
Principle 4 – Manage & Review
Declared conflicts must be actively managed and reviewed to ensure any material personal interest or conflicting duties do not impact the integrity of an agency or its functions.