Purpose

This policy has been developed to provide a framework for:

• all employees or contractors in declaring conflicts of interest; and
• the CEO, when determining procedures to deal with situations of possible conflicts of interest.

Scope

This policy applies to all employees, contractors and sub-contractors.

Definitions

Conflict of Interest

A situation where a person can derive a real or perceived benefit from actions or decisions made in their official capacity, where their decision is affected by relationships. These relationships can be because of family, friends or other positions they hold (for example, sitting on Boards). In relation to the NDIS this relates to any influence that may cause an Ability Links staff member to not work in the best interest of the participants they support.

Registered Support Coordination Provider

– an NDIS provider who is registered to help NDIS clients to identify, connect with and work with service providers who provide the supports best suited to them. These providers must be registered to provide Support Coordination.

Policy

When working for Ability Links, employees and contractors should place the Participants interests before the Interests of the organisation or private interests they may have, and should be seen to do so.

Conflicts of interest, and the perception of conflict of interest, should be avoided. Ability Links team members are to ensure what they are doing passes the ‘’Pub test’’ – nothing untoward

For this reason, where an employee or contractors may be seen as having a financial interest or personal gain in any decision such that it raises the possibility that the employee or contractors might be influenced by that financial interest, this interest must be notified to the participant or organisation involved and the manager of the employee or contractor. The manager may issue instructions to the employee or contractor regarding relevant workplace matters.

Ability Links Pty LTD or any of its employees, staff or board members are not to receive any Incentives, financial or otherwise for making referrals internally or externally.

Where an employee or contractor is in a relationship with any other person working or volunteering in or having dealings with the organisation, that relationship must be disclosed to the manager of the employee or contractor where that relationship may cause or be construed to cause a conflict of interest. That manager may issue instructions to the employee or contractor regarding relevant workplace matters.

A conflict of interest may occur if an interest or relationship influences or appears to influence the ability of the organisation’s employees or contractor to exercise objectivity.

Ability Links places great importance on making clear any existing or potential conflicts of interest.

Employees and contractors must declare to their manager all such conflicts of interest, and the manager may issue instructions to the employee or contractors regarding relevant workplace matters.

If and when services are presented to participants, they should include a variety of service providers that best suit the participant’s needs and requests.

We manage Conflicts of Interest by:

• Separating Support Coordination and Recovery Coaching from support delivery. (Support Workers cannot view client information posted by support coordinators in our CSM Caretaskr). Those responsible for rostering supports and determining service delivery do not have access to participant budget information unless specifically provided by the participant.
• Ensuring that staff do not receive any trailing commissions or incentives for making internal referrals.
• Respecting a participant’s right to Choice and Control over their life and that we use Supported Decision Making Practices to allow Dignity of Risk Choice.
• When presenting provider options we always make recommendations that match with support provision preferences. If our Staff recommend our services it will be alongside other options and that it has been provided in the best interest of the participant, not for the gain of Ability Links.
• Real or perceived conflicts of interests relating to individual employees are to be documented and investigated by the QHSER manager or CEO.
• Referrals to and from other providers are documented for each participant. This is evidenced in AL-Part-02 Participant Provider Choices, in AL-Part-24 Referral and Consent Form and our website referral form.
• Providing participants with a participant manual outlining conflicts of interests and information relating to advocacy and additional support.
• By having systems that are auditable and promote integrity.
• By having easy read and informative documents available to help explain support delivery, the NDIS, conflicts of interest and the rights and responsibilities of participants.

Related – Standard Operating Procedure

• AL-HR-SOP-23 Conflict of Interest Procedure
• AL-GF-19 Conflict of Interest Form

References:

https://teamdsc.com.au/resources/support-coordination-conflict-of-interest

https://www.ngoservicesonline.com.au/blog/conflict-of-interest-and-the-ndis/

https://www.ndis.gov.au/media/865/download