COI FAQs for managers

These FAQs are presented for educational and informational purposes and will be updated periodically. The information provided is general and your own unique situation must be considered in making decisions about conflicts of interest. This guide does not reduce the need for you to obtain your own advice.

Updated January 2020.

Does it matter what I do in relation to conflicts of interest (COIs) in my area?

COI procedures are in place to protect individual staff members, your unit and your agency. When they are flouted or ignored, the adverse consequences typically affect all involved. Any staff member or manager who has been found to flout or ignore procedures is often judged by others to have done the wrong thing. Negative perceptions are also often held by others about your unit and agency.

What are my responsibilities with regard to informing my staff about COIs?

As the manager, it is your responsibility to ensure that people in your area are aware of your agency’s COI policy and procedures, and the importance of acting appropriately.

What do I do if a staff member’s disclosure does not contain enough information for me to be able to make a decision on how a COI should be managed?

Ask for further information so that you can clearly understand the staff member’s position. Only when you have all the information that you need should you make a decision about managing the COI.

What do I need to document in such a scenario?

Any discussions with your staff member should be documented, especially those in which the staff member explains the COI or gives information about it that expands on what was in their disclosure. You should also document your COI management plan and any reasons for your decisions regarding the management of the COI.

Am I responsible if my staff member does not declare a COI?

It is the individual’s responsibility to declare a COI, but it is your responsibility to take action if you have an indication that a staff member in your area has not done so.

What should I do if I suspect a person might have a COI, but I am not sure?

You should make appropriate enquiries. In many cases, it is a good idea to discuss your concerns with your agency’s governance, audit or human resources personnel. If you suspect that the non-disclosure would amount to corrupt conduct you should report it in accordance with your reporting policy.

What should I do if my staff member is unhappy with my COI management plan?

As the manager, it is your responsibility to manage a COI in accordance with your agency’s policy and procedures. You may find it useful to get advice from your governance, audit or human resources personnel.

Do I have to monitor that the staff member is complying with the COI management plan?

Yes, monitoring compliance is your responsibility; how frequently and how detailed the monitoring depends on how risky the COI is for your organisation. Where required, supervisors are usually responsible for ensuring that staff resubmit COI disclosures.

Do I need to do anything if I am aware that the staff member’s COI has changed?

Yes, you need to instruct the staff member to give you a new disclosure.

If the staff member’s role at work changes, do I need to do anything about managing the COI?

Yes, you should consider how this affects the COI. It might change or possibly end the COI, and affect the COI management plan. You may need to request a new disclosure and/or update the management plan. If the staff member has a new supervisor, you should make that person aware of the COI disclosure and the existence of the management plan.