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Conflict of Interest Policy

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Section 1 - Purpose

(1) The purpose of this policy is to outline RMIT’s expectations regarding the identification and management of actual, potential or perceived conflicts of interest and to assist staff in addressing conflict of interest issues.

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Section 2 - Overview

(2) Staff who work for, or with, the RMIT Group, have an obligation to act in RMIT’s best interests. This policy sets out the requirement to comply with this obligation and put RMIT’s interests above the actual, perceived or potential interests of their own or other parties.

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Section 3 - Scope

(3) This policy applies to all employees of the University and its controlled entities (known as the RMIT Group), as well as to any other persons working with or for the RMIT Group and who are notified of the need to comply with this policy.

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Section 4 - Policy

(4) RMIT expects all staff members to act with honesty and integrity, and to not allow any personal or professional interests or duties to compromise their obligations, responsibilities and duties to RMIT. All conflicts of interest, regardless of their nature or type, will be identified, disclosed and managed to uphold this expectation.

(5) The following types of conflicts of interest will create an obligation to disclose and manage the interest:

  1. Actual conflict of interest: Where a person working for or with the RMIT Group does not act in RMIT’s best interests because they have another interest that they prioritise over RMIT’s interests.
  2. Perceived conflict of interest: Where a person working for or with the RMIT Group has other interests that could cause other people to think that they cannot act in RMIT’s best interests - even if, in fact, they do act in RMIT’s best interests. 
  3. Potential conflict of interest: Where a person working for or with the RMIT Group has other interests, which may influence their ability to act in RMIT’s best interests in the future.

(6) RMIT will:

  1. act promptly to identify, manage and mitigate actual, perceived or potential conflicts of interest and put in place arrangements that protect the integrity of the University’s processes and decision-making
  2. define and communicate a best practice approach to the identification, declaration and management of conflicts of interest
  3. ensure any breaches of this policy are investigated confidentially, transparently and professionally.
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Section 5 - Responsibilities

(7) All staff who work for, or with, the RMIT Group:

  1. have a duty to act in RMIT’s best interests;
  2. are responsible for considering and identifying actual, perceived or potential conflicts of interest;
  3. must declare any situations that give rise to an actual, perceived or potential conflict of interest; and
  4. must take appropriate steps to adequately manage the declared actual, perceived or potential conflict of interest; or
  5. must withdraw from the situation which gives rise to the conflict of interest if directed to by a manager or supervisor.

(8) Managers and supervisors are responsible for the management of actual, perceived or potential conflicts of interest and must refer to the Conflict of Interest Declaration and Management Procedure.

(9) The Executive Director, Property and Campus Services is responsible for identifying potential conflicts of interest that may arise during the procurement of goods and services and managing the declaration process.

(10) The Chief People Officer investigates and manages conduct matters arising from all types of conflicts of interest.

(11) The Chief Audit and Risk Officer monitors compliance trends, risk profiles and improvement opportunities under this policy.

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Section 6 - Compliance

(12) Failure to comply with this policy and the Conflict of Interest Declaration and Management Procedure may result in disciplinary action, up to and including termination of employment. It may also constitute non-compliance with the Code of Conduct.

(13) Breaches will be managed in accordance with the Code of Conduct and Workplace Behaviour Policy.

(14) RMIT may also refer behaviour that constitutes a potential crime to law enforcement agencies.

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Section 7 - Review

(15) This policy will be reviewed every three years at a minimum in accordance with the Policy Governance Framework.

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Section 8 - Procedures and Resources

(16) Refer to the following documents which are established in accordance with this policy:

  1. Conflict of Interest Declaration and Management Procedure
  2. Self-Authored Learning Resources: Conflict of Interest - Disclosure Guidance Materials