Conflicts of Interest

It has top management commitment and guiding principles with the aim to:

• establish, implement and maintain the Conflict of Interest Policy consistent and compatible with the defined IMS scope while supporting the strategic direction of IAC
• be consistent and appropriate to the purpose and context of IAC including the nature, scale / size, and international standard requirements (ISO 9001:2015 QMS, 14001:2015 EMS; 27001:2022 ISMS; 45001:2018 Work/OHSMS of its activities, procedures, products and services)
• provide a framework for setting objectives (quality, environmental, information security, OHS, and core business); and targets
• fulfill its applicable compliance obligations, legal requirements, and other issues (Australian Commonwealth, and State/Territory legislation, codes of practice, International and National standards, agreements, licenses, permits) while applying guiding principles for a risk-based process approach without changing any rights for –
  
  • (a) quality
    -  i) conformity of procedures, products and services
    -  ii) enhanced customer satisfaction
    - iii) continual improvement
  • (b) conflict of interest
    -  i) definition of types of conflicts of interest, who it applies to, when and how a conflict should be disclosed, a breach, and relevant legislation
  • a) compliance with
    Corporations Act 2001 
    - section 180 - the duty to exercise their powers and discharge their duties with a reasonable degree of care and diligence.
    - section 181 - the duty to act in good faith in the best interests of the company or for a proper purpose.
    - section 182 - the obligation to not use their position to obtain an advantage for either themselves or a third party, or to cause detriment to the company.
    - section 183 - the obligation not to improperly use information gained through their position as a director to obtain an advantage for either themselves or a third party, or to cause detriment to the company.
    - section 191 - the obligation to disclose material personal interests in matters relating to the affairs of the company.
    Commonwealth Fair Work Act 2009
    - If favouritism (rather than merit) affects hiring decisions or promotions, then in some cases this might lead to claims of discrimination from unsuccessful applicants.
    Commonwealth Work Health & Safety Act 2001
    - Health, safety and well-being in the workplace.
  • b) when an employee’s personal interests (self, spouse, family, friends, associates, other organisation, shareholder of another organisation in competition with the employer, secondary employment) conflict with their obligations to act in the best interests of the employer
  • c) actual, potential (not yet in existence), perceived (might look be a ‘bad look’)
  • d) relate to financial or non-financial, or property matters
  • e) examples
    - an employee awarding a contract to a business owned by a friend or family member without disclosing the relationship to their employer.
    - an employee accepting gifts or financial incentives from a supplier in exchange for favourable treatment.
    - an employee simultaneously working for the employer and a competitor of the employee, or owning shares in a competitor of the employer.
    - an employee using the employer's confidential information for their personal gain.
  • f) additional documentation requirements
    - Employee Handbook provides an overview of the employer's general rules, standards and expectations of employees.
    - Social Media Policy outlines the employer's approach to use of social media by employees.
    - Alcohol and Drug Policy outlines the employer's approach to drug and alcohol issues.
    - WHS Policy outlines the employer's approach to health and safety issues (bullying, harassment, victimisation & discrimination; remote work) at the workplace.
    - Information Security Policy outlines the employer's protocols, standards and procedures in relation to cyber security.
    - Letter or Memorandum emailed to employees about new or updated policies with an Induction / Training Checklist authorised (name, position title, date) by the employee, place information on Notice Boards and shared drive (intranet).
  • ii) avoid, accept, reduce (risk assessment), share and retain records (Conflict of Interest Register) for conflicts of interest at work to act with integrity and transparency
  • iii) prevent situations where workplace decisions are unfairly influenced by personal interests or relationships
  • iv) practices for handling conflicts of interest arising including induction, training, resolutions, and discipline for employees that breach this voluntary policy
  • (vi) report actual (gifts), protentional or perceived conflict of interest to the ELT, OMT including Human Resources Manager (Commonwealth Corporations Act 2001).
• realise the benefits of continual improvement of the IMS.

This policy shall be implemented to -

• determine process sequences, interrelationships and co-dependencies, criteria and methods needed for operational planning and control for relevance, appropriateness, and process effectiveness;
  
  • maintain version control;
  • make available / accessible and communicate in simple English, the IMS’ intent to relevant parties through awareness / inductions, and training;
  • make available resources for effective and efficient operational management, necessary to support business activities; manage changes; and monitor processes, products and services;
  • conduct scheduled audits, and
  • regular management reviews.

Dr Gloria Carter
ManagingDirector
1 July 2025