Policy – Conflict of interest

Purpose

This policy helps board directors, committee members, contractors, and employees of the Australasian College for Infection Prevention and Control (ACIPC) identify, disclose, and manage actual, potential, or perceived conflicts of interest. It protects the integrity of ACIPC and mitigates risk.

Scope

This policy applies to ACIPC’s board directors, committee members, employees, contractors, and other individuals engaged with ACIPC.

Policy statement

A conflict of interest arises when an office bearer’s personal interests conflict with their duty to act in ACIPC’s best interests. This includes situations where private interests could improperly influence decisions or create the appearance of bias. Conflicts are especially important to manage when an individual has decision-making responsibilities.

Conflicts of interest are not inherently wrong and often arise without misconduct. However, they must be disclosed and managed to ensure decisions are fair and unbiased. Personal interests may be:

• Pecuniary: Involving actual or potential financial gain.
• Non-pecuniary: Without financial benefit, but potentially influencing judgment.

Given ACIPC’s relationships with external organisations, it is vital that all representatives act, and are seen to act, with integrity, avoiding personal benefit from their position.

The most effective way to manage conflicts is through a transparent system requiring disclosure and independent evaluation.

Managing Conflicts of Interest

A conflict exists when personal interests—whether direct or indirect (e.g., involving family, friends, or other organisations)—conflict with a duty to ACIPC. It can also arise from conflicting responsibilities to another organisation.

ACIPC manages conflicts of interest by requiring its representatives to:

• Avoid conflicts where possible.
• Identify and disclose any actual, potential, or perceived conflicts.
• Manage conflicts transparently and responsibly.
• Comply with this policy and report any breaches.

Procedure for Managing Conflicts

Conflicts and the actions taken must be recorded by:

• Disclosing during meetings; or
• Completing an ACIPC Conflict of Interest Form, to be added to the Conflict of Interest Register, if it arises outside meetings.

For Board Members and Committees:

Once disclosed, the board or committee (excluding the conflicted person/s) must decide whether the conflicted individual should:

• Vote on the matter (minimum consideration);
• Participate in any discussion; or
• Be present during discussions and voting.

In exceptional cases, where a conflict significantly limits participation, the board or committee may consider whether resignation is appropriate.

Factors in Deciding Actions

The board or committee should consider:

• Whether the conflict must be avoided or can be documented and managed.
• Whether it impairs the person’s ability to participate impartially.
• Alternatives to avoid the conflict.
• Whether it creates the appearance of improper conduct that may damage ACIPC’s reputation.

Decisions require the majority approval of non-conflicted members present and voting. Actions and outcomes are recorded in meeting minutes and the register of interests.

Board of Directors’ Responsibilities

The board is responsible for:

• Establishing systems to identify, disclose, and manage conflicts of interest.
• Monitoring compliance with this policy.
• Reviewing the policy annually to ensure effectiveness.

Identification and Disclosure

When an actual, potential, or perceived conflict is identified, it must be:

• Disclosed to the relevant committee or person.
• Entered in ACIPC’s register of interests, maintained by the office manager, including the nature, extent, and actions taken.

Confidentiality

Alternative disclosure mechanisms may be used if additional confidentiality is required.

Compliance

If the board or a committee believes someone has breached this policy, they will investigate. Failure to disclose a conflict may result in action, including possible termination of the individual’s relationship with ACIPC.

Anyone who suspects a breach should raise their concerns with the individual and the president.