Conflict of Interest Policy

INTRODUCTION

The Board of ASHM is committed to high standards of ethical conduct and accordingly places great importance on making clear any existing or potential conflict of interest.

Whilst ASHM recognises that individuals hold a range of legitimate interests outside the immediate workplace, identifying and dealing with any such conflicts of interest is an integral part of establishing an ethical culture at ASHM.

To comply with good governance practice, to maintain its peak body status and to comply with the ACFID Code of Conduct, ASHM needs to be able to have transparent processes which demonstrate its independence to all relevant stakeholders.

PURPOSE

This policy has been developed to provide a framework for all board members, employees, committee members or contractors:

in declaring conflicts of interest; and
when determining how to deal with situations of conflict.

DEFINITIONS

A conflict of interest is a situation in which a person (an ASHM Board member, employee, committee member, contractor) can derive personal benefit from actions or decisions made in their official capacity.

A conflict of interest can be actual, potential or perceived.

Examples of relevant conflicts of interests that should be disclosed include, but are not limited to;

Holding shares in a company that ASHM is considering contracting for services
Presenting at a conference where Industry has sponsored your attendance
Sitting on the Board of another organisation in which ASHM has dealings

POLICY

All board members, employees, committee members and contractors must remain independent, impartial and unbiased in performing their duties
It is the responsibility of board members, employees, committee members and contractors to take reasonable steps to avoid creating a conflict of interest or a perception of a conflict of interest
Where a conflict of interest may exist or arise, it is the responsibility of board members, employees, committee members and contractors to disclose any such conflicts of interest in a timely manner
If there is any doubt as to whether a conflict exists then, in order to protect the individual and ASHM, a disclosure should be made
If any board member, employee, committee member or contractor becomes aware of any non-disclosed conflict by another board member, employee, committee member or contractor, then they will notify the ASHM CEO.
If any board member, employee, committee member or contractor becomes aware of any non-disclosed conflict by the ASHM CEO then they will notify the ASHM President and also the Chair of the ASHM Finance, Risk Management and Audit Committee
ASHM will maintain a register of conflicts of interest across all programs and this register will be available for inspection by relevant stakeholders upon request.
This policy also relates to:
a partner or family member of a board member, employee, committee member or contractor
any partnership of which a board member, employee, committee member or contractor (or a partner or family member) is a member
any corporation in which a board member, employee, committee member or contractor (or a partner or family member) is a director or owns or controls 25% or more of the issued shares.
Conflicts of interest must be disclosed by a board member, employee, committee member or contractor in a timely manner as follows:
each new board member, employee, committee member or contractor will, at the time of their appointment, be required to provide ASHM with a signed declaration disclosing any current conflicts of interest. In addition, during the recruitment process, AHSM will seek information about conflicts of interests from applicants
Board members and committee members will also complete an annual declaration confirming their current conflicts of interest
- failure to provide either of these signed declarations in a timely manner may forfeit the individual’s ability to remain in the position
once a conflict of interest, or a perception of a conflict of interest, arises for an employee or contractor they will advise their Division Manager as soon as possible
once a conflict of interest, or a perception of a conflict of interest, arises for a board member or committee member, they will advise their fellow board/ committee members as soon as possible and be directed by the Chair of the relevant Board/ Committee as to how to proceed. If the conflict arises for the Chair of the meeting, then the Deputy Chair will advise how to proceed
all Board and Committee meetings must commence with a standing agenda item for a declaration of any conflicts of interest.