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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 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 external, personal or financial interests or duties to compromise their obligations, responsibilities and duties to RMIT. All conflicts of interest, regardless of their character or level, will be identified, disclosed and managed to uphold this expectation.

(5) A conflict of interest arises when you:

  1. act, appear to act, or could act on behalf of someone other than RMIT
  2. have, appear to have, or could have a self-interest from which you obtain, appear to obtain or could obtain some form of benefit, which is, appears to be, or could potentially be adverse to RMIT’s best interests.

(6) There are three different types of conflicts of interest that create an obligation to declare 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.

(7) 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

(8) 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 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 actual, potential or perceived conflict of interest; or
  5. must withdraw from the situation which gives rise to the conflict of interest if directed to by a manager.

(9) RMIT managers are responsible for the management of actual, perceived or potential conflicts of interest of direct reports.

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

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

(12) Internal Audit, Compliance Risk and Regulation monitors compliance trends, risk profiles and improvement opportunities under this policy.

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Section 6 - Declarations of Conflicts of Interest

(13) Conflicts of interest are sometimes clear, and sometimes difficult to identify. Schedule 1 provides non-exhaustive examples of situations that could represent either an actual, perceived or potential conflict of interest. The Chief Operating Officer may add to the examples provided in Schedule 1 to promote the expectations of this policy and its application at RMIT.

(14) 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.

(15) Breaches will be managed in accordance with the Code of Conduct and Managing Conduct Policy.

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

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Section 7 - Review

(17) This policy will be reviewed annually.

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Section 8 - Schedules

(18) Refer to the following documents which are established in accordance with this Policy:

  1. Schedule 1 – Actual, Perceived and Potential Conflict of Interest Examples.
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Section 9 - Procedures and Resources

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

  1. Conflict of Interest Declaration and Management Procedure
  2. Conflict of Interest Policy FAQs
  3. Self-Authored Learning Resources: Conflict of Interest - Disclosure Guidance Materials
  4. Online declaration portal
  5. Conflict of Interest Declaration form [for employees without an e-number]