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Policy: Declarations of Interest and Conflicts
of Interest (SH-POL-111)
Publish Date 8 October 2024
Approved by
General Manager- PGC
Owner:
Director – Risk Oversight
Author
Integrity Services
Purpose
1. The Declarations of Interest and Conflicts of Interest policy (the policy) will assist all
Kāinga Ora – Homes and Communities (Kāinga Ora) people to fulfil their obligations as public
servants in relation to declarations of interests, and sets out the approach Kāinga Ora wil take
to conflicts of interest management.
2. This policy provides:
• guidance on determining whether an interest may pose a conflict;
• guidance on determining types of conflicts of interest (whether actual, potential or
perceived);
• guidance on conflicts of interest declaration and management;
• the potential consequences of non-compliance with this policy;
• Key roles and responsibilities of stakeholders.
under the Official Information Act
Background
3. It is our duty as public servants to work to the highest standards of integrity in everything we
Released
do. As public servants we need to exercise a high standard of judgement around the
management of conflicts of interest.1 To ensure our actions are of a high standard this policy
aligns with Te Kawa Mataaho Public Service Commission (PSC) Model Standards and Auditor
General Tumuaki o te Mana Arotake (OAG), Managing Conflicts of Interest: A Guide for the
Public Sector.
4. All Kāinga Ora people have a duty to place public interest above their personal or private
interests when performing their official duties. This means our people’s independence,
objectivity, or impartiality must not be called into question.
1Te Kawa Maataaho Public Service Commission Model Standards 2022
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Scope
5.  This policy, and related procedures, apply to all Kāinga Ora employees (including permanent,
casual, and fixed term employees) as well as contractors, consultants, secondees, cadets,
apprentices and interns. The policy also includes any person, supplier, or entity seeking to
secure a role, partner, or contract with Kāinga Ora. For the purposes of this document, the term
‘Kāinga Ora people’ or ‘Kāinga Ora person’ is used to capture this col ective of affected
individuals.
6.  Kāinga Ora people must take reasonable care to communicate expectations in relation to
identifying interests and any resulting actual, potential, or perceived conflict of interest areas
before and during the employment process, appointment, or when the agreement starts.
7.  The policy must be read in conjunction with the relevant legislation, regulations, standards and
guidelines referenced in this document.
Act
Policy
8.  The reputation of Kāinga Ora depends on our ability to be impartial in our decision making and
to exercise a high standard of judgement when dealing with interests and actual, potential and
perceived conflicts of interest.
Information
9.  A conflict of interest is any situation where your duties or responsibilities as an employee or
office holder in a public organisation conflict, or could be seen to conflict, with another interest
Official
you might have outside of work.
the
10. This policy is underpinned by the PSC’s Standards of Integrity and Conduct, which establishes
four principles of conduct which apply to al  public servants, including all Kāinga Ora people:
•  Being trustworthy
under
•  Being fair
•  Being impartial
•  Being resp
  onsible.

Released
11. All Kāinga Ora people will behave in accordance with our values and will perform their duties
efficiently, professionally, and conscientiously.
12. This policy further considers these key principles:
•  Kāinga Ora people act in the public's interest – We have a duty to place the public interest
above our private interests when conducting our official functions.
•  Kāinga Ora people are responsible and accountable – We are responsible and accountable
for identifying, declaring and managing any interest or relationship that could constitute
actual, potential or perceived conflicts that apply to them. Equally, we are accountable for
ensuring our suppliers comply with this policy.
•  Kāinga Ora takes a risk-based approach – We should take a proactive approach to
assessing and managing conflict of interest risks.

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13. Conflicts of interest are natural in our working lives, are often unavoidable and do not
necessarily mean anyone has done anything wrong. Many interests are not conflicts at all but
declaring them enables proper consideration and management where appropriate.
14. In determining whether an interest may pose a conflict, all Kāinga Ora People including People
Leaders must consider the closeness and the relevance of the interest to the work undertaken
and position held. The below classifications of interests are designed to help Kāinga Ora people
to consider whether the interest is declarable and how an interest could result in a conflict
either through a single or combination of types.
‘Declarable Interests’ and ‘Conflicts of Interests’ to consider

Examples
Declarable interests
Conflicts of interest
Examples of financial
A financial interest becomes a
interests include:
conflict of interest where your
work role an
Act  d responsibilities
•  shareholdings;
conflict or could be seen to
•  ownership interests and
conflict with that interest.
investments (including
private and commercial
A financial interest becomes a
“A financial conflict of interest
property interests);
declarable interest when it is
is any situation where you
stand to gain or lose financial y
Financial interest  •  business involvement;
relevant in any way to your
Information
and
work role and responsibilities.
from a decision you are asked
•  Secondary employment.
to make. Financial interests

might be direct or indirect.

There are also situations where
Official

you might be deemed to share
the same financial interests as
the

another person or
organisation.” (OAG guidelines,

point 3.7 - 3.11)
under
A non-financial interest
Examples of non-financial
becomes a conflict of interest
interests include:
where your work role and

responsibilities conflict or could
•  family relationship;
A non-financial interest
be seen to conflict with that
Released
•  close personal
becomes a declarable interest
interest.
Non-financial
relationship;
when it is relevant in any way
“A non-financial conflict of
interest
•  community interests or
to your work role and
relationships (
responsibilities.
interest is any situation where
membership of a
you are not affected financial y
community group); and

by a decision but are affected in
•  Previous employment.
some other way that might
make you biased or appear to

be biased.” (OAG guidelines,
point 3.12 - 3.24)
Examples of role interests
A role interests become
A declarable role interest
Role interest
include:
declarable when it is relevant
becomes a conflict of interest if
in any way to your work role
•  paid or unpaid
the interests of two
and responsibilities.
(voluntary) work or roles
organisations and/or roles
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(including governance or
concerned conflict or could be
management roles);
seen to conflict.
•  Professional or legal
obligations (being a
“A conflict of roles can arise in
trustee)
any situation where you are a
•  Current or (recent)
decision-maker for two
former advisor, director,
different organisations about
or partner of another
the same matter.” (OAG
business or organisation
guidelines, point 3.25 - 3.31)

Predetermination becomes a
conflict when a risk is identified
that you wil  ‘taint’ a decision
you are involved in making
because you are biased or
appear to be biased.
Examples of
Predetermination becomes a
“Predetermination is any
predetermination can include  declarable interest if it creates  situation where you are
Act
Predetermination  statements, opinions or
a risk of prejudice or bias and
deciding about something and
actions expressing a strong
is relevant in any way to your
there is a risk that people wil
view about a matter.
work role and responsibilities.
think you made up your mind
before you considered al  the
evidence. Suggestions of
predetermination usual y arise
Information
because of something you have
previously said or done.” (OAG
guidelines, point 3.32 - 3.40)
Official
15. If it is considered one of these interests or conflicts of interests apply, it should be considered
the
whether the interest or conflict may present not only an actual but also a potential, and/or
perceived conflict:
under
This is where your personal interests or relationships and your responsibilities at work
intersect.
  Examples of an actual conflicts could include below situations –
Actual
•  if you ar
Released  e a Development Manager and:
o  your brother is a manager at a company that regularly contracts for
construction consultancy work with Kāinga Ora;
o  a contractor on a supplier panel you regularly access sends you
corporate box tickets to a big sporting event.
This is where a conflict of interest could or might happen.
Example of a potential conflicts could include below situations –
•  if you're an Kāinga Ora employee and:
Potential
o  your spouse has just started a multi-media post-production company
and is looking for new clients, including in the public sector (but hasn’t
worked with Kāinga Ora yet);
o  your cousin works at a motion graphics company that’s on a panel of
suppliers used by IRD, MSD and MOE. You hear from the procurement
team that Kāinga Ora is considering whether to join that supplier panel.
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link to page 5 This is where other people might reasonably think that a person or their decision has
been compromised.
Examples of perceived conflicts include below situation –
•  if you are a Communication Advisor for Large Scale Project, and:
Perceived
o  your best friend works for a construction firm bidding for the project.
Neither of you have any influence over whether they win the bid, but
another bidder finds out about the relationship and believes that
because of this association, the construction firm wil  be favoured;
o  you used to work for one of the construction firms bidding for the
project. You have no influence over who is successful but other entities
do not know this and believe that there may be an unfair process.
16.  If in any doubt whether a conflict of interest exists and /or a management plan may be
required, Integrity Services is available to offer advice and support.
Declaring an Interest
Act
17. All declarations (including recording of declarable interests, conflicts of interest and registration
of gifts) must be centrally recorded in Arawhata2. Kāinga Ora people are required to make an
annual declaration and meet the continuous obligation to declare an interest and/or a conflict
of interest as and when it arises.
Information
18. The fol owing situations should prompt a discussion with your People Leader, Integrity Services
team or Procurement team about declaring interests (this is not an exhaustive list):
Official
•  Starting work for Kāinga Ora;
•  Working at Kāinga Ora;
the
•  Working with Kāinga Ora;
•  Engaging in a Kāinga Ora Procurement process; and
under
•  As and when a declarable interest and/or a conflict of interest is identified.

19. Active identification of declarable interests enables proper management of conflicts of interests

which is a fundamental part of maintaining public confidence in our organisation. The People
Released
Leader should encourage team members to actively disclose relevant interests and support
them in managing conflicts of interest to protect Kāinga Ora from possible legal, commercial,
political, or reputational risks.
20. Ultimately the People Leader should careful y consider what, if anything, needs to be done to
avoid or mitigate the conflict of interest.
21. It is important to remember that interests and conflicts do not only occur at an individual level
but also exist at an agency level and it is imperative to consider contractors’ and suppliers’
relationships with agency senior leaders and Ministers. If an interest is identified that relates to

2 Fol ow this link for a demonstration video on how to do this.
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a Minister, this should be escalated to the Chief Executive (CE) in a timely manner for
management via Integrity Services.
Managing a Conflict of Interest

22. It is the responsibility of all Kāinga Ora people to record an interest that may pose conflict in
Arawhata, followed by a discussion with their People Leader or the relevant Subject Matter
Expert to determine whether it may constitute a conflict of interest or not.
23. It is important for People Leaders to assess the seriousness of a conflict of interest, such as
nature or significance of the activity being conducted by Kāinga Ora and/or the extent to which
the person’s other interest could specifical y affect or be reasonably perceived by an impartial
observer to affect an activity or decision being made by Kāinga Ora.
24. It is the People Leader’s responsibility to manage any identified conflicts of interest, effectively
referring to the general standards and expectations or values listed earlier in this policy.

Act
Some actions to consider in Arawhata could include:
•  Where the overlap of the public and personal interests is so low that it does not really
constitute a conflict of interest, People Leader’ comments recorded to this affect in
Arawhata are sufficient.
Information
•  In other situations, documenting the steps being taken to avoid or mitigate the conflict by
way of management plan or similar. This could come in the form of an agreement signed by
an individual and their People Leader. This should be uploaded to Arawhata.
Official
•  In extreme circumstances of potential “high risk” conflicts of interest (OAG Guidelines) or
where there is a degree of uncertainty about how the conflict may be perceived and its
the
resulting severity, collaborative decision making with input from the Legal Team, People
Team, Chief Executive. Subject Matter Experts and other People Leaders may be required.
However, management of this type w
under il be unusual and only necessary.

25. For more information on how a People Leader can avoid or mitigate a conflict of interest and
manage a declara
  tion, the OAG guidelines provide options for consideration Part 4: Dealing with
conflicts of interest when they aris
Released  e — Office of the Auditor-General New Zealand
(oag.parliament.nz). Whatever option is deemed appropriate, it is essential that the option is
documented within Arawhata.
Non-Compliance with this Policy
26. Non-compliance with this policy by Kāinga Ora employees is a serious issue that will be
addressed in line with the Standards of Integrity and Conduct Policy (POL–337) and associated
Procedures POL-337A
27. Where a conflict of interest results in serious wrongdoing, Kāinga Ora people can follow the
Protected Disclosures Policy (POL-338)
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28. Non-compliance with this policy by other Kāinga Ora people wil  be addressed in line with the
processes that apply to their engagement agreements with Kāinga Ora.
Key roles and responsibilities
Role
Responsibility
Chief Executive
•  Accountable for Kāinga Ora upholding the public service principles in
managing conflicts of interest.
•  Understanding risk associated with conflicts of interest related to
Minister(s) and approving the relevant management plan.

Deputy Chief
•  Understanding conflict of interest risks and promoting the principles
Executives and
of this policy.
General Managers
•  Ensuring their business groups are compliant with this policy.
•  General Manager PGC provides approval of this policy.
Chief Executive
•  Reviewing and endorsing the overarching principles of conflicts of
Act
Leadership Group
interest management and this policy.
(CELG)
•  Endorsing and providing guidance around the management of high-
risk conflict of interest matters in the organisation.
Director Risk
•  Policy Owner.
Oversight (DRO)
Information
•  Aligning this policy and practice to Public Service Commission’s
expectations.
•  Ensuring any breaches of this policy are addressed by relevant
Official
parties.
•  Communicating signifi
the cant conflict of interest risks to the CELG where
necessary.
People Leader
•  Ensuring their teams are compliant with this policy.
under
•  Ensure their teams are educated and up to date with al  learning
modules relevant to conflicts of interest.
•  Ensuring all interest declarations and conflicts of interest are

documented sufficiently in Arawhata.
Released
•  Writing and implementing management plans where required,
seeking support from Integrity Services when there is uncertainty,
and ensuring these are uploaded in Arawhata.
•  Ensuring that all their people complete the annual declaration
process and related learning modules as part of Public Service and
Integrity Week.
Kāinga Ora People
•  Ensuring they are observant of this policy, relevant procedures and
guidance.
•  Complying with this policy and Standards of Integrity and Conduct,
this includes:
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Role
Responsibility
o  Declaring interests and relationships in accordance with this
policy as and when they arise and as part of the annual
declaration requirement (including NIL declaration);
o  Seeking third party’s interest declarations in accordance with
this policy where they are responsible for managing the
relationship with the third party who work / partner with
Kāinga Ora;
o  Recording all offers of gifts and hospitality in Arawhata even
when they are declined; and
o  Adhering to agreed management plans relating to a conflict of
interest and raising issues for management attention promptly.
Integrity Services
•  Providing staff training and education for identifying and managing
(Subject Matter
conflicts of interest.
Experts)
•  Providing ongoing support to the business from general advice to
Act
assistance with management plans.
•  Monitoring and measure compliance with the policy and providing
regular reporting to DRO, CELG and FRAC.
•  Collaborating closely with the People and Procurement teams to
ensure that conflicts of interests are managed in ac
Information  cordance with the
policy.
•  Conducting an on-going periodic review of the Conflicts of Interest
Framework (including this Policy
Official ) in Kāinga Ora and identifying areas
for continuous improvement.

the
People Team
•  Providing advice and guidance to hiring managers on hiring practices
and assistance in obtaining accurate information in conflict-of-
interest declarat
under ions.
•  Providing advice and support to Integrity Services and people leaders
to ensure that conflicts of interest are managed in accordance with

this policy.
•  Support
Released ing internal training through the review and update of LMS
modules related to conflicts of interest management; and
•  Where issues of non-compliance with this policy occur breaching
employment terms and conditions, people leaders wil  seek advice
from people partners in accordance with this policy and the
Standards of Integrity and Conduct Policy (POL-337) and associated
Procedure (POL- 337a)
Procurement
•  Providing ongoing support to the business groups from general
advice to assistance with management plans in relation to
procurement interests.
•  Ensuring that conflicts of interest are managed in accordance with
this policy by:
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Role
Responsibility
o  Ensuring that conflict of interest guidance covered within
Procurement policy and procedures are aligned to this policy;
and
o  Discussing significant conflict of interest matters related to
Procurement for escalation and reporting.
Te Kurutao Group
Manager responsible for treaty settlements must ensure all of their staff
Māori
are familiar with the specific guidance for treaty settlements.
Definitions
29. The following definitions apply when interpreting this policy:
Term
Definition
Kāinga Ora people  All Kāinga Ora employees, including (permanent, casual, and fixed term
Act
employees) as well as contractors, consultants, secondees, cadets,
apprentices, interns and board members.
Interest (that
•  Any interest that may compromise Kāinga Ora or Kāinga Ora people’s
could constitute a
roles as a public agency / servant.
conflict)
•  Refer to classification of interests table (paragraph 12, page 3).
Information
Conflict of Interest  •  Any situation where your duties or responsibilities as an employee or
office holder in a public organisation conflict, or could be seen to
conflict, with another interest you
Official might have outside of work.
the
Impartial
Treating people fairly, without personal favour or bias.
Accountable
Taking responsibility and answering for work, actions, and decisions.
Responsive
Understanding and me
under eting people’s needs and aspirations.
Relationship
  Associations that could impact (and/or how other impartial people may
reasonably consider the association could impact) the impartiality of

Kāinga Ora or its people.
  Many cult
Released  ures have a broad concept of family. These can include
connections through biological relatives, common ancestors, household
and community upbringing, marriage or an equivalent and more.
  Whakapapa Māori will not, of itself, create an interest. However, when
an interest of predetermination, financial, non-financial or role interest
arises, whakapapa may be associated.
‘High risk’
•  A set of circumstances that creates a higher risk that professional
judgment or actions regarding a primary interest will be unduly
influenced by a secondary interest, and the resulting matter will attract
stakeholder and/or media scrutiny and/or comment.
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Related legislation, regulation, policies, processes,
and guidance documents
30. This policy guides all Kāinga Ora people to act consistently with the following legislation and
guidelines to embed a culture of declaring, managing, and reporting on conflicts of interest:
•  Crown Entities Act 2004
•  Public Service Act 2020
•  Model standards - Te Kawa Mataaho Public Service Commission
•  Managing conflicts of interest: A guide for the public sector — Office of the Auditor-General
•  Managing conflicts of interest and confidentiality | New Zealand Government Procurement

31. Relevant policies:
•  Standards of Integrity and Conduct
•  Speak up against Wrongdoing
•  Protected disclosures
Act
•  Procurement Policy/Kaupapa Here Whiwhinga

32. Relevant processes and guidance:
•  Accepting gifts and hospitality Policy, Process and Support Info (SH-PRO-701);
•  Procurement Process
Information
Review
Official
33. This policy will be reviewed annual y or as and when directed by the CE.
the
Document control  under
Date
Reviewed/Modified by
Comments/Descriptions of changes
September 2024  Te Tira Māori Pae Tātaki
Endorsed the policy
September 2024   Chief Executive Leadership  Endorsed the policy
Group (CELG
Released  )
October 2024
General Manager PGC
Approved the policy
Details of previous versions of policies and procedures will be stored in Kāinga Ora
document management system (Objective).
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