Conflict of Interest Policy

CONFLICT OF INTEREST POLICY

________ (ACN..............................................) ("Employer")

Last updated: ________

(1) ABOUT THIS POLICY

(a) This Policy applies to all of the Employer's employees, including full time, part time and casual employees, temporary employees, permanent employees, managers, supervisors, interns and apprentices, student trainees, volunteers and other representatives of our organisation as well as any persons in the role of director or secretary for our organisation (together hereinafter "Employees").

(b) The Employer expects that all Employees conduct themselves ethically and with integrity in the course of their employment.

(c) This Conflict of Interest Policy ("Policy") is designed to help all Employees of ________ to handle potential conflicts of interest.

(d) This Policy provides information about how to identify potential conflicts of interest, how to manage them, as well as how and when to disclose them. Handling potential conflicts of interest in accordance with this Policy will help Employees to protect their integrity and that of the Employer. It will also help Employees to enjoy a successful career with the Employer.

(e) Please take the time to read and review this Policy as thoroughly as possible. If you have any questions, please reach out to your manager or supervisor.

(f) Compliance with this Policy is a condition of employment. Failure to comply with this Policy may result in disciplinary action and/or termination of employment.

(2) WHAT IS A CONFLICT OF INTEREST?

(a) An Employee encounters a conflict of interest when their personal interests conflict with their obligation to act in the best interests of the Employer. These "personal interests" could include the Employee's own interests, as well as the interests of their spouse, family, friends or other associates.

(b) A conflict of interest may also arise if an Employee has obligations to another organisation, which are in conflict with their obligations towards the Employer. This might occur, for example, if the Employee is employed by another organisation at the same time that they are employed by the Employer. It might also occur if the Employee owns shares in another organisation which is in competition with the Employer.

(c) A conflict of interest might be actual, potential, or perceived. A conflict of interest might also relate to financial or non-financial matters.

(d) An "actual" conflict means a normal conflict of interest that actually exists.

(e) A "potential" conflict means that the conflict of interest might not exist yet, but if the Employee continues to do what they are doing then a conflict of interest is likely to arise.

(f) A "perceived" conflict means that the conflict of interest might not actually exist yet, but it might look like a conflict exists. In other words, "it is a bad look", and should still be avoided - as it is likely to undermine confidence in the Employee and the Employer.

(3) EXAMPLES

(a) The examples provided below are intended to help Employees understand what a conflict of interest might look like. They are not an exhaustive list, so it is possible that Employees may encounter conflicts of interest in circumstances that are different from what is included in this list.

(b) Some general examples of conflicts of interest include:

(I) the Employee or the Employee's friend or family member has a current or potential financial interest which would impact the Employee's ability to perform their employment duties in an unbiased manner;

(II) the Employee is involved with or has the potential to be involved with a business that directly competes with the Employer;

(III) the Employee uses the Employer's confidential information to profit personally;

(IV) the Employee accepts significant gifts or monetary compensation from third-parties working with the Employer, such as clients or vendors; or

(V) the Employee otherwise stands to profit personally as a result of their relationship with the Employer in a capacity other than as an employee.

(c) Some specific examples of conflicts of interest that may arise in our organisation include:

________

(4) OUR APPROACH

(a) We understand that Employees have a life outside of work and they have other obligations and interests, aside from their obligations to us.

(b) We also understand that conflicts of interest are a common occurrence, and they are not a problem as long as they are handled openly, honestly and effectively.

(c) Nevertheless, any conflict of interest, whether actual, potential or perceived, and whether financial or non-financial, creates a risk that the Employee might act in a way that is not in the best interests of our organisation.

(d) We will handle any matters related to this Policy sensitively and confidentially.

(5) WHAT WE EXPECT OF EMPLOYEES

(a) We require Employees to:

(I) comply with all applicable laws, rules and regulations;

(II) comply with this Policy;

(III) avoid conflicts of interest;

(IV) avoid the appearance of any conflicts of interest;

(V) notify us of any actual, potential, or perceived conflict of interest at the earliest opportunity;

(VI) carefully and continually monitor and manage any conflicts of interest that do arise, in open consultation with us;

(VII) manage any conflicts of interest as directed by us;

(VIII) promptly respond to any breaches of this Policy;

(IX) promptly report any breaches of this Policy to us;

(X) take a proactive and precautionary approach to any conflicts of interest. If unsure whether something is a conflict of interest or not - treat it as though it is one;

(XI) conduct themselves in a manner that does not compromise our reputation;

(XII) act in our best interests during the course of their employment;

(XIII) not have any financial interests that conflict with our interests;

(XIV) not be involved with any business or organisation that conflicts with or competes with our business;

(XV) not use or share our confidential information except for the purpose of performing their employment duties for us.

(6) HOW TO DISCLOSE CONFLICTS OF INTEREST

If you need to disclose a possible conflict of interest, you may do so in the following manner:

________

(7) HOW WE HANDLE CONFLICTS OF INTEREST

We handle conflicts of interest in the following manner:

________

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(9) IF YOU NEED MORE INFORMATION OR ASSISTANCE

Employees may contact a supervisor or manager for a confidential discussion in relation to any matters related to conflicts of interest.

(10) ACKNOWLEDGEMENT

By signing below, the Employee acknowledges having read and understood this Policy, and the Employee agrees to comply with this Policy:

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Employee Signature

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Employee Name

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Date