Conflict of Interest Policy for Commonwealth Government employees and contractors

Information on this page provides advice to organisations that have received grants and believe that a Commonwealth government employee that they have dealings with may not be acting impartially due to a real or perceived conflict of interest.

Commonwealth employees and contractors who are assessing grant applications must abide by the Conflict of Interest Policy and the Australian Public Service (APS) Values and Code of Conduct.

Commonwealth government employee means a person employed by a Commonwealth department or agency under the Public Service Act 1999, whether fulltime or part-time, in an ongoing or non-ongoing capacity.

Contractor means a person employed by an external company who is providing services under the supervision of a government department or agency, where the agency specifies how the work is to be undertaken and has control over the final form of any resulting output.

Conflict of interest disclosure process

What is a conflict of interest?

A conflict of interest may occur when there is a real or perceived conflict between a Commonwealth government employee or contractor’s personal interest, pecuniary (financial) or non-pecuniary (personal), and their official duties. Where there is a real or perceived conflict of interest it is inappropriate for the Commonwealth government employee or contractor to be involved in or to make decisions that may be affected by their personal interest.

Pecuniary interest is an interest that a Commonwealth government employee or contractor may have in a matter because of the reasonable likelihood or expectation of appreciable financial gain or loss to the employee or contractor.

Non-pecuniary interest is an interest that a Commonwealth government employee or contractor may have in a matter because it may involve family or other relationships and/or friendships or other interests that do not involve financial gain or loss.

Examples of a conflict of interest

• Departmental employee is the director of a family company that may be affected by policy changes being considered in their work area.
• Departmental employee may be assessing tenders from companies in which they or a relative have an interest. This involvement could lead to the perception that they were subject to bias.
• Departmental employee is in a position to assess grants to a community group to which they belong.
• Departmental employee on a selection panel has a personal relationship with an applicant for the position. This could be seen as providing an unfair advantage and may be a violation of the APS Code of Conduct.

What should you do if you believe a Commonwealth government employee with whom you have dealings has a real or perceived conflict of interest?

If you believe the conflict of interest is in relation to a Commonwealth employee in the Department of Social Services, Community Grants Hub contact 1800 020 283 or email support@communitygrants.gov.au.

If you believe the conflict of interest is in relation to a Commonwealth employee from another department, you should contact the department’s complaints team as detailed on their website.