Conflict of Interest Policy


This procedure template is general in nature and is provided as a guide only. Please check for any changes to Terms of Business, NDIS Rules or other instructions.


This Template has considered the core NDIS Practice Standards. Organisations will need to adapt this template to suit their organisation. Organisations applying any of the supplementary NDIS Practice Standards will need to ensure they include any associated additional requirements in their procedures.


Policy statement


ARMAR HEALTHCARE actively manages real and possible conflicts of interest that have the potential to negatively impact or influence services. This is part of our commitment to always provide safe and high-quality supports.


Where personal interest comes into conflict with a person’s work-related or volunteering responsibilities. ARMAR HEALTHCARE exercises good governance, to ensure any conflicts are identified and prevented or resolved.


A conflict of interest may be naturally occurring rather than as an indication of improper activity and all conflicts whether real or possible must be identified, declared, recorded and managed.




This policy applies to Board members and all staff including permanent and casual employees, contract workers, temporary agency workers, and volunteers.  Anyone working with or for ARMAR HEALTHCARE is expected to be familiar with this policy and use the approved procedures for responding to real and possible conflicts of interest.

This policy is owned by the board.




  • ARMAR HEALTHCARE acts in the best interests of participants and protects them from harm or disadvantage due to real or possible conflicts of interest.
  • Participants have the right to services and supports that are effectively managed, regularly reviewed, accountable and contemporary.
  • Participants have the right to know about any real or possible conflict of interest that does, or may, affect their services.


  • The conflict of interest policy is provided or explained to each participant in their own language using their preferred method of communication.
  • Participants are provided with advice about support options (including those not delivered directly by ARMAR HEALTHCARE to support a person’s ability to make choices and control their services.
  • No participant is given preferential treatment above another in the receipt or provision of supports.
  • People working for or with ARMAR HEALTHCARE must not seek or receive any personal benefit as a result of their work including gifts or rewards.
  • All real and possible conflicts of interest are declared, documented, managed and monitored.
  • ARMAR HEALTHCARE will comply with any operational guidelines or instructions about conflict of interest from the funding agency.



Key actions/Procedures


Conflict of interest is a routine agenda item at Board and Executive Meetings.

A conflict of interest register is kept and maintained by the manager with responsibility for risk management with ARMAR HEALTHCARE .


Conflict of interest is explained to staff during induction by the manager responsible for the induction process. This includes a list of potential conflicts arising from multiple employers, personal relationships and gifts.


Conflict of Interest policy is provided to participants and families during orientation and they are given the opportunity to ask questions.


Advice is provided on appropriate ways to thank or recognise staff.


Staff and Board members are required to read the Conflict of Interest Policy and declare any personal interests using a declaration of conflict of interest form. Staff who are unsure about whether something is a conflict of interest should speak to their manager.


Breaches of the conflict of interest policy are managed through supervision, and if required, through performance management or the Constitution/ Rules.







Conflict of interest: when a person working for or with ARMAR HEALTHCARE has the potential to gain personal advantage or benefit from their work or be influenced in the way they do their work. Conflicts of interest are documented and reported to Board.


Personal interest: refers to a person’s own interests and those of their family and friends and/or any organisations they support of are involved with.


Benefit: Any product, service, or advantage given to a person due to their work. This can include money, gift cards, gifts or discounts or favourable treatment.


Related policy and procedures


  • Conflict of Interest procedure and register
  • Code of Conduct
  • Gifts and Benefits policy


Related legislation and standards


  • NDIS Quality and Safeguarding Practice Standards 2018
  • NDIS Terms of Business March 2017
  • National Standards for Disability Services 2013
  • Corporations Act 2001
  • Associations Incorporation Act 2009 No 7




Date of approval: [13/01/23]

Date of review: [13/01/24]

Signature of management: