Conflict of Interest

Will Holmes à Court
Will Holmes à Court
Last updated 
Ensure personal interests do not influence or compromise services to clients

Overview

Introduction
  • This policy helps to identify, disclose and manage any actual, potential or perceived conflicts of interest. 
  • Everyone who represents HWH must be aware of their obligations to disclose any conflicts of interest that they may have.
  • Complying with this policy will ensure that conflicts of interest are effectively managed.
What is a conflict of interest?
  • A conflict of interest occurs when our interests conflict with our responsibility to act in the best interests of HWH and the people we support. Personal interests include direct interests and those of family, friends, or other organisations a person may be involved with or have an interest in (for example, as a shareholder, board member or business owner).
  • A conflict of interest may be actual, potential or perceived, and financial or non-financial. These situations present the risk that a person will decide based on, or be affected by, these influences rather than in the best interests of HWH and must be managed accordingly.
Applies to
  • any situation that could affect a person's impartiality
  • any situation that could affect a client's choice and control.
  • all HWH representatives
Related Items

Policy

Organisation responsibilities
As part of HWH responsibilities, we will:
  • ensure the company or our ethical values do not impede a client's right to choice and control
  • manage, document and report on individual conflicts of interest as they arise
  • ensure that advice to a client about support options (including those not delivered directly) is transparent and promotes a client's choice and ability to control the services they receive.
Responsibilities of representatives
The responsibilities of all HWH representatives are to:
  • avoid conflicts of interest wherever possible
  • identify and disclose any conflicts of interest
  • carefully manage any conflicts of interest
  • adhere to the conflict of interest policy and respond to any breaches.
Key management personnel responsibilities
Key managers are to:
  • work with all HWH representatives to avoid or manage any conflict of interest
  • record all reported conflicts of interest in a register of interest document.
Gifts and benefits
Regarding gifts and benefits:
  • representatives of HWH must not accept any offer of money, gifts, services or benefits that could cause them to act in a manner contrary to the interests of a client
  • representatives must have no financial or other personal interest that could directly or indirectly influence or compromise the choice of the service provider or the provision of services to a client—this includes obtaining or offering any form of commission.
Examples of conflicts of interest
The following are examples of conflicts of interest:
  • financial interests
  • personal and family relationships between employees/volunteers
  • decisions regarding appointments, promotions or other decisions relating to employees
  • acceptance of gifts or benefits, e.g. monies, jewellery, makeup, clothing, flights or holidays
  • use of confidential and official information
  • reproduction or use of copyright information for company purposes only
  • membership of, or employment in, an organisation that comes into serious competition with another organisation
  • use of the company’s facilities and equipment for personal benefit or the benefit of a third party.
What is not a conflict of interest
The following are not conflicts of interest:
  • membership or affiliation with other organisations where there is no possible benefit or perception of benefit
  • union representation or membership
  • approved collaboration with other organisations.
Breach of conflict of interest policy
  • Failure to disclose a potential, perceived, or actual conflict of interest breaches this policy.
  • Disciplinary action may follow if it is deemed an incident of misconduct, wrongdoing or abuse of power.