Conduct and Compliance Procedure – Declaration of Private Interests

Parent policy

Conduct and Compliance Policy

Preamble

IIn order for the University to effectively minimise the possibility of conflicts of interest and to ensure that it is, and is seen to be, managing its business in a fair, ethical and transparent manner, free of bias, the following procedure is to be followed in respect to the disclosure of pecuniary or other private interests or benefits.

Definitions

Conflict of interest: Where there is, or it appears that there is a divergence between the private interests or duties of a person and their professional responsibilities to the University such that an independent observer might reasonably question whether the actions or decisions of that person are influenced by their private interests or duties. Conflicts of interest can involve private financial or non-financial interests of the staff member, and such interests of the staff member’s immediate family or relatives, business partners or associates, or friends.

Private financial interests:This includes substantial sources of income (more than $10,000 per annum) other than from paid employment with the University. This will include outside employment, business activities, company directorships/board memberships, distributions from trusts, directorships of trusts and significant shareholdings (more than 5% of the issued capital) in a public or private company.

Private non-financial interests: Membership of community groups or organisations and voluntary directorships/board memberships.

Associates: These may include a relative, business associate or domestic partner (includes married, de-facto or same sex relationships whether or not cohabiting with a staff member at the time).

1. Declaration of private interests

Human Resources will issue an annual request via email to staff holding a University financial delegation in excess of $50,000.

Staff members must:

• complete a Declaration of Private Interests Form on an annual basis;
• sign the form and ensure that it is also signed by their supervisor (electronic signatures will also be accepted); and
• submit completed forms electronically via email to the Declarations Officer at: declarationsofficer@adm.monash.edu.au

Any staff member holding a University financial delegation in excess of $50,000, who fails to disclose all private interests, may face disciplinary action from the University.

Responsibility

This procedure applies to all staff holding a University financial delegation in excess of $50,000, including the Vice-Chancellor and staff at controlled entities.

Human Resources Division will administer the Declarations of Private Interests process and store completed forms on the University’s electronic records management system, TRIM.

2. Declaration of pecuniary interests

The University is required to comply with the Financial Reporting Direction (FRD) 22A, and make a statement as to whether ‘Declarations of pecuniary interests have been duly completed by all relevant officers’. (FRD 22A)

Responsibility

Divisional Director, Human Resources
Vice-President (Administration)
Audit and Risk Management

The Human Resources Division is responsible for administrating the Declaration of Private Interests process.

Related Procedures

• Conduct and Compliance Procedure - Conflict of Interest (including Conflict of Interest in Research)
• Conduct and Compliance Procedure - Paid Outside Work

Related Enterprise Agreement Clauses

Related Documents

• Financial Management Act 1994 (FMA)
• Financial Reporting Direction 22A [pdf]
• Pecuniary Interests (University Council)

Related Forms

• Declaration of private interests [Word] [PDF]