Conflict of Interest Policy

A conflict of interest policy sets out how your organisation identifies, discloses, and manages situations where personal interests could affect professional decisions. For Australian aged care providers, having this policy in place is a governance requirement under the Aged Care Act 2024 and a clear expectation under the Strengthened Aged Care Quality Standards. This page explains what the policy should cover and includes a free downloadable template below.

What This Policy Covers

A conflict of interest (COI) policy applies to everyone involved in running an aged care service, including board members, executives, managers, care staff, volunteers, and contractors. It covers both actual conflicts and perceived conflicts, as well as financial interests, personal relationships, and outside employment arrangements.

The policy establishes a clear process for disclosing conflicts, recording them in a register, and deciding how to manage or resolve each situation. It also sets out what happens when disclosures are not made.

Why This Policy Matters for Aged Care Compliance

Aged care providers operating in Australia are subject to specific governance obligations that make a COI policy more than just good practice. The following standards and legislation directly require it.

Standard or LegislationRelevant RequirementStrengthened Aged Care Quality Standard 2: The OrganisationRequires governing bodies to act with integrity, manage risks to residents, and maintain strong governance systems including conflict of interest management.Aged Care Act 2024 (Governance Requirements)Approved providers must have documented processes for identifying and managing conflicts of interest at the governance level, including obligations for responsible persons.Australian Aged Care Quality and Safety CommissionAssessors review governance documentation during audits, including how providers handle disclosures and what controls are in place.

Without a documented policy, providers risk non-compliance findings during audits, reputational damage, and in serious cases, regulatory action. A well-written policy also reinforces the trust that residents, families, and staff place in your organisation.

What a Good Conflict of Interest Policy Should Include

A policy that meets current regulatory expectations should go beyond a simple declaration of intent. It needs to be practical and specific enough that staff at every level know what to do when a conflict arises.

Key elements include:

• A clear definition of what constitutes a conflict of interest, including actual, potential, and perceived conflicts
• The scope of who the policy applies to, covering board members, management, staff, volunteers, and contractors
• A step-by-step disclosure process with timelines and the responsible person for receiving disclosures
• A conflicts of interest register that is regularly reviewed and kept up to date
• Decision-making rules for managing or resolving disclosed conflicts
• Consequences for failing to disclose a known conflict
• A review schedule aligned to your broader governance calendar

This policy works closely with your Code of Conduct and Ethics Policy, which sets out the broader behavioural standards expected of everyone in your organisation. Together, they form a strong foundation for ethical governance.

Linking Conflicts of Interest to Broader Governance

Conflict of interest management does not sit in isolation. It connects directly to how your organisation handles whistleblowing, decision-making transparency, and workforce conduct. If a staff member observes an undisclosed conflict, they need to know what action to take. Your Whistleblower Policy should give them that pathway.

Providers who treat these policies as connected documents, rather than standalone tick-boxes, tend to perform better during assessments. Auditors look for evidence that governance systems work together in practice, not just on paper.

How Governa Helps Providers Stay Compliant

Governa gives aged care providers a structured way to manage their policy library without the manual overhead. The platform includes pre-built templates aligned to current legislation, version control, approval workflows, and the Norma compliance bot to answer staff questions about your policies in real time.

Rather than updating documents manually every time a standard changes, your team gets alerts and suggested updates through the platform. This keeps your conflict of interest policy current without requiring a compliance officer to monitor every regulatory development.

You can browse the full collection of ready-to-use templates in the Policy Templates Library, including workforce, clinical, and governance categories.

Download the Free Template

The downloadable Conflict of Interest Policy template below is formatted for immediate use. Fill in your organisation details, review the procedures against your current practices, and have it approved by your governing body. If you want to see how Governa manages your full compliance framework, book a demo with the team today.