Frequently Asked Questions

This policy applies to all UniSA employees. This includes all staff: full time, part time and casual employees.

It does not apply to UniSA Council Members as they are covered by the University of South Australia Act 1990 (S 15C), or other members of the UniSA community e.g. Adjuncts, students, volunteers, consultants or contractors for whom there are separate obligations.

A conflict of interest can be actual, potential or perceived. It may arise where the direct or indirect personal interests of a UniSA employee conflict with, are in opposition to, or appear to (or actually does), inappropriately influence how they undertake their obligations to UniSA.  It can be time limited or on-going.

An actual conflict of interest arises when there is a direct conflict between an employee’s duties and responsibilities and their personal interests which influence the performance of those duties.

This includes financial or other personal or professional considerations which compromise an individual’s objectivity, professional judgment, professional integrity, and/or ability to perform his or her responsibilities to the University.

Perceived conflicts of interest include situations where it could be perceived, or appear to a reasonable person, that an employee’s personal interests could improperly or unduly influence the performance of their duties and responsibilities.

Potential conflicts of interest are where a conflict of interest may arise in the future due to personal interests conflicting with or influencing required University duties or responsibilities

Perceived and potential conflicts may involve situations where an individual member of the University community, a member of the individual’s family, or a close personal relation has financial interests, personal relationships, or professional associations with an outside individual or organisation, such that his or her activities within the University could appear to be biased against the University by that interest or relationship.

A pecuniary (involving financial gain or loss) conflict of interest is a situation in which the potential exists for an individual’s personal financial interests to impair their judgment in the execution of their responsibilities to the University of South Australia.  A financial or economic interests could include shares, investments, assets or debts or associations with family or private business(es).

A non-pecuniary conflict of interest is a situation in which the potential exists for an individual’s personal interests to impair their judgment in the execution of their responsibilities to the University of South Australia. Personal interests of a non-financial nature can be based on enmity or amity. These can be direct or indirect. For example, where the conflict is related to someone with whom the employee has a significant relationship (i.e. spouse, family member, associate or close friend).

The Declaration needs to be completed by any employee who may have an actual, potential or perceived conflict of interest.

As soon as a situation arises which gives rise to the actual, potential or perceived conflict and before beginning the activity in question.

Types of things you should disclose:

  • Any relationship you have with a third party that does business (such as sponsoring research or providing goods and services) with the University.
  • Any relationship with a third party in which you hold a significant financial interest.
  • Professional activity that you undertake for personal payment or remuneration of any kind.
  • Any intellectual property (Patents, trademarks, licensing agreements, etc.) contractually obligated to you or the University in which you are the author or owner.
  • Any textbooks or other course materials for sale that you have authored or co-authored which you are also requiring of students enrolled in coursework under your direction.

Please note, the above list is not exhaustive. There are numerous other circumstances which the Management of Conflict of Interest Policy will guide you to consider.

All senior staff must fill out a Register of Personal Interest as soon as possible after employment and thereafter annually or when personal circumstances change, whether they are engaged in activities that might create the perception of or potential for a conflict of interest or not. A reminder e-mail notification will also be issued when it is time to complete the annual disclosure online.

If a UniSA employee is concerned at any time about an actual, potential or perceived conflict of interest resulting from the actions or relationships of another UniSA employee, they must also disclose that concern to their People Talent and Culture business partner or a senior staff member who will advise on appropriate action.

Whenever relevant circumstances change regarding your personal circumstances that may impact on your duties or research and lead to an actual, potential or perceived conflict of interest, you should lodge a further Declaration of Conflict of Interest.

Whenever relevant circumstances change regarding your personal circumstances that may impact on your duties or research and lead to an actual, potential or perceived conflict of interest, you should lodge an updated Register of Personal Interests. You are also required to update your register annually.

The new online system for the declaration of Conflict of Interests and Register of Personal Interests automatically forwards your disclosure to the designated reviewer.

The information provided in your disclosure is confidential and is only used for the purposes of administering the Management of Conflict of Interest Policy. Access to this information is limited to personnel who need to review and approve your disclosure and to ensure that any resulting management plan is followed. This includes, but is not limited to, your line manager or relevant SMG member. Under certain circumstances, the University may be required to make personal financial information available to comply with legislation.

The online form eliminates the need to fill out and submit paper documentation. Once the online form is submitted, it will be electronically issued to your line manager for review and approval. Once approved it is held in the Conflict of Interest Register and can be retrieved at any time if you require a copy.

Once completed, the online form is electronically stored in your personnel file.  It can be retrieved at any time if you require a copy.

Your disclosure is considered part of your personnel record. Access to this information is limited to personnel who need to review and approve your disclosure as part of their role, and to ensure that any resulting management plan is followed. This includes, but is not limited to, your line manager or relevant SMG member. Others who may access your Register of Personal Interests on direction from the Vice Chancellor include the General Counsel and the Executive Director: People, Talent and Culture.

Your line manager and where required either the Executive Director People, Talent and Culture or the Deputy Vice Chancellor Research and Innovation will review your complete disclosure and determine whether an actual, potential, or perceived conflict of interest exists. If the Reviewer determines that an actual, potential, or perceived conflict of interest exists, the Reviewer will determine what conditions or restrictions, if any, should be imposed by the University to manage, reduce or eliminate such conflicts. The Reviewer will work with the staff member to establish a Management Plan.

You should not take part in the activity until a Management Strategy has been approved by your line manager or where required by the Executive Director People, Talent and Culture or the Deputy Vice Chancellor Research and Innovation.

A Management Plan is a document that outlines and implements safeguard measures to reduce, mitigate or eliminate an actual potential or perceived conflict of interest held by an employee. It details the actions and measures you and your line manager will undertake to ensure your objectivity is maintained while performing your duties or research at UniSA.

If a Reviewer determines that an actual, potential, or perceived conflict of interest exists, the Reviewer and staff member will establish a Management Plan in order to ensure the reduction, management, or elimination of any conflict.

Yes. Reviewers may delegate the review of conflict of interest disclosures to an SMG member if required.

Yes. If you need an expedited review of your disclosure due to a deadline or other time constraint, please inform your line manager when submitting your disclosure. If your line manager determines that there may be a potential, perceived or actual conflict of interest, they can work with you to establish a Management Plan for consideration by the Executive Director People, Talent and Culture or the Deputy Vice Chancellor Research and Innovation review where required.

Please contact your local People Talent and Culture (PTC) business partner or a senior member of the PTC team for assistance.