Safe Hands - Newcastle, NSW
Conflicts of Interest Policy
This policy provides a framework for identifying, disclosing, and managing conflicts of interest - actual, potential, or perceived - to ensure that Safe Hands’s decisions are always made in the best interests of participants and the organisation, free from improper influence.
1. Purpose
Safe Hands is committed to integrity, transparency, and putting participants’ interests first. A conflict of interest arises when a person’s private interests could improperly influence - or be seen to influence - their professional decisions or actions on behalf of Safe Hands.
This policy applies to all employees, contractors, volunteers, and directors of Safe Hands. It meets requirements under the NDIS Practice Standards (Governance and Operational Management) and is consistent with the NDIS Code of Conduct obligation to act with integrity, honesty, and transparency.
2. Types of Conflicts of Interest
A conflict of interest may be:
- Actual: A real conflict exists between a person’s private interests and their professional duties
- Potential: A person’s private interests could come into conflict with their professional duties in the future
- Perceived: A reasonable person, knowing the facts, would believe a conflict exists - even if there is none in reality
All three types must be disclosed. A perceived conflict that is not disclosed can be just as damaging to trust as an actual one.
2.1 Common Examples in Disability Services
- A worker is employed by (or has a financial interest in) another disability service provider to which they refer participants
- A support coordinator recommends a provider in which they or a family member has a financial interest
- A worker has a personal relationship (romantic, family, close friendship) with a participant or their family member
- A worker receives gifts, payments, or benefits from a participant, their family, or a third-party provider beyond the small gift threshold
- A director or senior staff member awards a contract to a company in which they hold shares or have a personal relationship with the owner
- A worker is considering leaving Safe Hands to start a competing business and begins recruiting colleagues or participants
3. Disclosure Requirements
Every worker must disclose any actual, potential, or perceived conflict of interest to the Director / CEO:
- In writing (email or written form) as soon as the conflict arises or is identified
- Before participating in any decision or action where the conflict is relevant
- On an annual basis, by completing the Conflicts of Interest Register declaration
When in doubt, disclose. It is always better to declare a potential conflict that turns out to be immaterial than to conceal one that affects participant or organisational outcomes. Disclosure protects both the worker and the organisation.
4. Managing Declared Conflicts
Once a conflict is disclosed, the Director / CEO will assess it and determine the appropriate management strategy. Options include:
| Conflict Severity | Management Action |
|---|---|
| Minor / low risk (e.g. a distant acquaintance becomes a participant) | Disclosure recorded; worker continues in role with awareness and monitoring |
| Moderate (e.g. a worker has secondary employment with a competitor) | Disclosure recorded; worker excluded from relevant decisions; conditions may be placed on secondary employment |
| Significant (e.g. support coordinator refers to providers they have a financial interest in) | Worker immediately excluded from all related decisions; may be required to divest interest or change role |
| Serious / irreconcilable | Worker may be required to resign from a role or end their engagement with Safe Hands |
The Director / CEO records all declared conflicts and management decisions in the Conflicts of Interest Register.
5. Support Coordinator Obligations
Support coordinators have a particular responsibility to avoid conflicts of interest because they are in a position of trust that directly influences which providers participants choose. Support coordinators must:
- Always recommend providers based on the participant’s best interests, goals, and preferences - never based on personal financial interest or business relationships
- Disclose to participants if they have any relationship (financial or personal) with a provider they are recommending
- Never accept referral fees, kickbacks, or commissions from providers
- Document the reasons for all provider recommendations in participant case notes
- Offer participants a genuine choice of providers and support them to make their own decision
The NDIS Code of Conduct and Practice Standards impose specific obligations on support coordinators to act independently and in participants’ best interests. Failure to manage conflicts of interest may constitute a breach of the Code and be referred to the NDIS Commission.
6. Gifts and Benefits
Workers must not accept gifts or benefits from participants, their families, or third-party providers that could create or be perceived as creating a conflict of interest. Specific rules:
- Gifts of nominal value (under $20, e.g. a box of chocolates at Christmas) may be accepted and should be declared to the manager
- Gifts with a value over $20 must be declined politely and reported to the Director
- No gift of any value from a current or prospective business partner, subcontractor, or third-party provider may be accepted without Director approval
- Cash gifts must never be accepted
- Invitations to social events paid for by providers must be approved by the Director before acceptance
7. Secondary Employment
Workers who wish to undertake secondary employment (a second job or business) must disclose this to the Director before commencing and confirm it does not conflict with their duties at Safe Hands. Secondary employment that:
- Involves providing disability support services to Safe Hands participants outside of their role
- Is with a direct competitor in the same service area
- Affects the worker’s capacity to perform their duties safely and to standard
- Uses confidential information obtained through their Safe Hands role
...is not permitted without explicit Director approval and appropriate conditions.
8. Breaches of This Policy
Failure to disclose a conflict of interest, or acting on an undisclosed conflict, is a serious breach of this policy and the NDIS Code of Conduct. Consequences may include disciplinary action up to and including termination of employment and referral to the NDIS Commission.
9. Related Documents
- Code of Conduct (POL-COC-001)
- Privacy Policy (POL-PRV-001)
- Feedback & Complaints Policy (POL-CMP-001)
- Whistleblower (Protected Disclosure) Policy (POL-WBL-001)
- NDIS Code of Conduct 2018 (Commonwealth)
This policy has been reviewed and approved by the Director / CEO of Safe Hands and is effective from 1 January 2026.
Approved by
Rujal S - Director / CEO, Safe Hands
Date Approved
1 January 2026
Effective date
Document ID: POL-COI-001 | © 2026 Safe Hands Disability | ABN 31 315 518 918