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Managing conflicts of interest
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Table of Contents
Table of Contents
2
Policy statement and principles
3
What
3
Why
3
How
3
Scope
3
Definitions
3
Actual conflict of interest
4
Perceived conflict of interest
4
Potential conflict of interest
4
Other interests
4
Conflicts of interest
5
Register of interest
6
Identifying conflicts of interest
7
Conflicts of interest in rural or smal communities
7
What other interests could create a conflict of interest?
7
Conflicts of interest in context
9
Conflicts of interest in a response context
9
Conflicts of interest in an investigation context
9
Internal investigations
9
External investigations
9
Conflicts of interest in a resolution context
10
Conflicts of interest in a corporate context
10
Procurement
10
Providing written character references
10
Providing references for firearms licence holders
10
Other situations, including personal and whānau ties
11
Conflicts of interest in an international context
12
Professional boundaries
12
Conflicts of interest in a non-work-related context
13
How to manage conflicts of interest
14
How to participate in the management of the conflict
14
Supervisor and manager responsibilities
15
Appendix: Maintaining professional boundaries
16
Steps you can take to keep yourselves and others safe
16
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Policy statement and principles
What
As noted in the Public Service Commission's model standards, “A conflict of interest means a conflict
between a public duty and private and/or personal interests. Personal interests can be financial or relate
to family, friends or associates. Conflicts of interest may be actual, potential or perceived.”
It is important that conflicts of interest are recognised and properly managed. Conflicts of interest that
are hidden, or poorly managed, create the risk of misconduct (or the appearance of misconduct), and
could undermine public trust and confidence. Conversely, good management of conflicts of interest
protects both the employee(s) involved and Police from al egations of bias or inappropriate conduct.
Why
Integrity is at the heart of our ability to police effectively. A staff member’s conflict of interest can
threaten Police’s integrity because it can bring the organisation’s impartiality into question. And a
perceived or potential conflict of interest can be just as damaging as an actual conflict. The main goal of
identifying and managing conflicts of interest is to ensure that al policing decisions are made - and are
seen to be made - legitimately, justifiably, independently and fairly. The requirement to report conflicts
of interest exists to protect Police’s and Police employees’ integrity, not to question it or test it.
How
In line with Police’s values of Professionalism and Integrity, Police staff are expected to maintain high
standards of behaviour. The public expects Police to carry out its work impartial y at al times. It fol ows
that al employees should be alert to potential conflicts of interest. Al actual, potential or perceived
conflicts of interest should be declared to a supervisor by way of the appropriate declaration.
Supervisors must work with employees who declare conflicts of interest to assess the risks involved, and
to identify appropriate strategies to manage those risks.
Scope
This chapter applies to al Police employees. The principles apply to al Police’s work - every incident
attended, every investigation assigned, and al its corporate work as wel .
Some forms of conflicts of interest are covered by specific policies; see 'Secondary employment',
'Procurement' and 'Gifts, discounts and hospitality'. And some specific guidelines are appended to this
chapter, to help staff maintain professional boundaries.
Definitions
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A conflict between official duties and other interests that could interfere with a Police
Actual
employee’s ability to be impartial, objective and independent.
conflict of
interest
The perception of outside observers that a Police employee’s other interests may
Perceived
interfere with their ability to be impartial, objective and independent, whether or not
conflict of
that is the case.
interest
A situation where other interests have the potential to interfere with a Police
Potential
employee’s official duties in the future, or where their official duties could affect their
conflict
of
other interests in the future.
interest
Interests unrelated to Police - such as those of a personal, family or financial nature.
Other
interests
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Conflicts of interest
Conflicts of interest occur natural y, as Police employees have numerous interests, which can give rise to
conflicts in different situations. Such conflicts occur frequently in a country like New Zealand, and even
more often for those living and working in rural or smal communities where everyone knows everyone.
Conflicts of interest can be actual, perceived or potential, and can arise not only in investigations, but in
al aspects of our work. If a conflict of interest arises, it doesn’t necessarily mean that someone has done
or may do something wrong.
Conflicts of interest are especial y significant in the public sector. In addition to using taxpayer dol ars,
Police has access to private and confidential information and must be seen to act impartial y, without
any possibility of influence by favouritism, personal motives or private benefit.
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Register of interest
A Register of Interests has been established to act as a central record of relevant interests held by Police’s
senior leaders - at a minimum, those working at Superintendent-level and above. The Register is not
designed to resolve conflicts that may arise in the normal course of a senior leader’s work; for example,
when involved in a particular procurement process. Rather, it creates an opportunity to register ahead-
of-time known interests that could give rise to perceived, potential or actual conflicts of interest.
Proactively identifying and disclosing such interests is consistent with our focus on transparency and
accountability, good corporate stewardship, and helps reinforce New Zealand Police’s high-integrity
culture.
Annual declarations must be made by al senior leaders within Police, covering al those working in
Superintendent-level roles right up to the Commissioner. This includes District Commanders, Directors,
Assistant Commissioners and Executive Directors, as wel as members of the Executive Leadership Team.
Declarations can be made at Declaration of interest | Ten One - New Zealand Police Intranet and should
be updated as required.
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Identifying conflicts of interest
Our own conflicts of interest are often the most difficult to identify, particularly perceived or potential
conflicts of interest. In considering whether a conflict exists, Police employees should ask themselves
whether they would act differently if they didn’t have other interests. They should also ask themselves
how a reasonable observer would be likely to perceive their actions, given their other interests. Would a
reasonable observer believe the employee would act differently if they didn’t have other interests?
Final y, they should consider whether their professional reputation would be damaged if friends,
col eagues, or the public became aware of their involvement in a situation where they had other
interests. In other words, would their actions stand up to scrutiny?
If unsure whether a conflict exists, it is better to err on the side of transparency and discuss the situation
with your supervisor.
Conflicts of interest in rural or small communities
Police employees working in rural or smal communities need to be especial y alert to the potential for
perceived or actual conflicts of interest, particularly if they have family members residing, or working, in
the same community. It is particularly important for employees in rural or smal communities to regularly
review their ‘other interests’ and consider the potential for conflicts of interest. Prior to joining
community organisations, consider the potential for conflicts of interest and document, with your
supervisor, how they wil be managed. When dealing with family, friends and acquaintances, it is
important to careful y consider your actions and document them for review.
What other interests could create a conflict of interest?
A conflict of interest can arise through a relationship, an activity or strong personal views. Conflicts of
interest vary in seriousness and degree. Because of the wide range of interests and roles that employees
have, it is not possible to list every possible situation that could give rise to a conflict of interest. The
Office of the Auditor-General has assembled a raft of guidance around conflicts of interest including
instructional videos and a quiz. It is important to be alert to the potential of conflicts in al situations.
Some examples of interests that could conflict with duties include:
- relationships with family, friends, current former partners, or work col eagues
- being a member of a club, team, society or association
- a financial interest in a company, trust or property
- holding another public office
- political or union affiliations
- expressing views on social media
- secondary employment (see 'Secondary employment', including as a social media influencer)
- personal relationships that evolve from professional relationships
- the acceptance of gifts, discounts or hospitality (see the 'Gifts, discounts and hospitality' chapter)
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- a legal obligation, such as being a trustee
- a financial obligation, such as a loan
- providing written character references
- intervening to assist a family member or friend in a dispute
- attending Court in a support role.
Certain roles we perform are at higher risk of conflict of interest than others, such as:
- internal investigations
- working in isolated, rural or smal communities
- procurement (see 'Procurement' in the Police Manual and the Office of the Auditor-General’s Quick
guide to conflicts of interest and video on Personal dealings with a tenderer for a contract
- acting as a Police representative in a governance role for a third-party organisation
- exercising discretionary powers
- licensing or vetting
- using information obtained from NIA or other Police systems
- maintaining relationships with the media (see ‘Dealing with the media’ chapter in the Police
Manual)
- managing staff or contractors, including security consultants
- reviewing decisions in which Police played a role.
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Conflicts of interest in context
Conflicts of interest in a response context
When responding to incidents, Police employees may be immediately faced with situations where a
conflict of interest exists. It is important to be alert to this possibility, and to avoid conflicts if possible.
Police employees who are personal y associated with the parties involved in an incident may not be seen
as having acted objectively.
In some situations, it may be necessary to act immediately (for example, to protect life or property). In
those situations, Police employees must discharge their duties first, and declare any conflict of interest as
soon as possible afterwards. In other situations, steps should be taken to avoid the conflict, such as
dispatching a different employee, if possible.
There is a natural overlap and interdependence of people living in isolated, rural or smal communities. It
may not be possible for employees to avoid dealing with people with whom they have a personal
connection. In those cases, it is important to document that potential conflict of interest, document why
a decision was made, and ensure those decisions can be reviewed by a supervisor at a later date.
Conflicts of interest in an investigation context
Internal investigations
Particular care must be given to the potential for conflicts of interest in the case of internal investigations
(where the subject is a Police employee), whether they are criminal or employment investigations. Police
is never more open to al egations of bias than when it is investigating its own employees. It is essential
that investigations are independent, and that Police’s independence has been considered in each case.
For this reason, al investigators assigned to internal investigations (IPCA category A and B) must declare
(on the file) whether or not a conflict of interest exists. The Independence of Investigation Conflict of
Interest Declaration form may be used for this purpose. For IPCA categories C and D, the form must be
completed if an actual, perceived, or potential conflict of interest exists. This ensures that the potential
for conflict has been considered in al investigations. This form must be attached to the file, and a PDF
version must be attached in Blueteam.
Supervisors should never investigate sexual or other serious complaints against staff under their direct
supervision. An independent investigator should be appointed to ensure the enquiry is impartial and
carried out in a diligent and robust manner.
External investigations
Conflicts can also arise in external investigations (where the subject is not a Police employee) for a broad
range of reasons, some of which are those listed above. Police investigators should also evaluate their
independence when conducting external investigations and complete an Independence of Investigation
Conflict of Interest Declaration form in situations where an actual, perceived or potential conflict exists.
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Conflicts of interest in a resolution context
It is general y the resolution of an incident or investigation that is most likely to face scrutiny. It is
important when Police is involved in informal resolutions, pre-charge warnings or other supported
resolutions and prosecution that employees ensure that their objectivity is seen to be maintained.
Employees involved at this stage of any incident or investigation should be aware of the potential for
conflicts of interest, and declare any actual, perceived or potential conflicts of interest to their supervisor
(or rural supervisor) as soon as they become aware of the conflict.
Conflicts of interest in a corporate context
Procurement
Conflicts of interest must be considered in every request for proposals or tender process, or when
engaging contractors. As outlined in the ‘Procurement’ chapter, al employees must declare to their
supervisor any personal interest or involvement which may affect, or could be perceived by others to
affect, their impartiality in any aspect of their work. Any employee participating in a tender process must
complete a Conflict of interest and confidentiality agreement (on the Procurement templates page),
whether or not a conflict exists.
Providing written character references
From time to time, Police employees may be asked to provide a written character reference for someone.
Police employees may only provide such written references as private individuals and should not sign-off
using their Police job titles when doing so. Police letterhead must not be used.
From time to time, Police employees may be asked to provide online references for a national security
clearance. In those cases, the reference goes straight to the New Zealand Security Intel igence Service
(NZSIS) and can only be used within the NZSIS vetting process. Such references ask employees to speak
to their personal knowledge of the security clearance applicant and must be completed without
reference to Police resources (such as NIA). A Police job title or email address may be used for these
purposes.
In other cases, employment references may be requested in an online format using suppliers such as X-
Ref. These are forwarded directly to the prospective employer and are requested from the referee in their
role as a former manager, or sometimes as a co-worker. If the prospective employee was someone who
worked in a Police setting, sharing the details of your respective roles wil natural y form part of the
reference, and does not represent a conflict of interest.
Providing references for firearms licence holders
References and/or testimonials by Police employees on behalf of a firearms licence holder should not be
made. This extends to members of Police with friends or associates of a firearms licence holder.
Firearms licensing decision-making occurs by way of a centralised function by a smal group ofdelegated
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staff within Police’s Firearms Safety Authority business unit (Te Tari Pūreke) to ensure consistency and
appropriateness, with an emphasis on personal and public safety.
A reference/testimonial/opinion made by a Police employee for a firearms licence holder creates a
significant conflict of interest for Police with the regulatory responsibilities of Te Tari Pūreke. It has the
risk of negatively impacting trust and confidence and creating reputational damage for Police,
particularly in the case of any subsequent firearm licence related Court appeal.
While references can be provided by a Police employee in their personal capacity as a member of the
public, it is preferable to avoid these situations entirely given they may create a perceived conflict of
interest. Please seek advice from your manager or Te Tari Pūreke if you have any concerns.
Other situations, including personal and whānau ties
Conflicts of interest can occur in other situations that arise through work, such as recruiting or managing
employees, or making decisions that can affect organisations or individuals. Police employees need to
consider the potential for conflicts of interest in al their work, and declare any actual, perceived or
potential conflicts of interest to a supervisor as soon as they become apparent.
Of note, it wil sometimes be necessary to acknowledge and put in place arrangements to manage the
risks of perceived or potential conflicts of interest that arise when people with personal ties work
together in the same place or reporting line. This wil especial y be the case where one person has
supervisory or decision-making authority over the other’s work; either directly or indirectly. The risks of
such perceived or potential conflicts of interests are likely to be heightened for those in senior leadership
positions.
Where such ties exists - for example, whānau relationships; or people who are partners - employees
should declare the perceived or potential conflict of interest.
In some cases, it wil be necessary or otherwise appropriate to formalise how those with personal ties
intend to manage the perceived or potential conflict of interest, by preparing a written management
plan. There is no set format which must be used for such a plan. The important thing is that it’s made
clear what steps wil be taken to prevent the perceived or potential conflict leading to any actual
problems, and confirm the proposed management actions wil not unfairly discriminate against or
adversely impact those who have the personal ties.
By way of example, for a conflict of interest management plan involving partners who work in the same
group, Service Centre or Area/District, it might be agreed that an alternative reporting line wil be used in
any situation where decisions about one the people’s direct work needs to be made by the other person -
for instance, skipping up a level in the hierarchy, so that such decisions are made by someone even more
senior, who does not have any personal ties to either individual.
Because there is no prescribed form, different people wil use different approaches to develop a conflict-
of-interest management plan. Some may prepare a POL258; others might write a memo or set things out
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in an email. The important thing is there is clear paper trail, and the agreed management plan is shared
with, and signed-off-by, the senior manager in the part of the organisation where the perceived or
potential conflict of interest has arisen.
Conflicts of interest in an international context
Operating in an international environment requires additional vigilance to potential conflicts of interest
or situations that may be perceived as conflicts. When engaging with foreign organisations, attending
events or conferences, or working alongside agencies from other nations, there are risks that may not be
apparent in a domestic setting. For instance, participation in events in countries with geopolitical
sensitivities or in the presence of officials from nations not al ied with New Zealand can give rise to
perceptions of conflict or potential security and/or foreign interference concerns. Some invitations to
meet with foreign nationals can also give rise to perceptions of influence.
Scenario example: A New Zealand Police staff member attends a conference as part of their role in a
country not aligned with New Zealand. Although there may be no direct conflict of interest, such
attendance may be viewed as sensitive given the diplomatic and security context. Consequently, the
situation could lead to external or internal perceptions of a conflict, or even misconceptions about New
Zealand Police’s al iances or engagements.
To ensure clarity and mitigate risk, staff travel ing for business to international locations need to assess
the sensitivity of these situations careful y and discuss any potential conflicts or perception risks with
their manager in the first instance. For guidance about geopolitical sensitivities, contact the National
Intel igence Centre or International Services Group. In addition, staff invited to or intending to travel or
interact with foreign officials must declare those invitations and/or interactions beforehand. This applies
whether the interactions wil occur official y or in the employee’s personal time, and whether those
interactions are in New Zealand or overseas.
Actual or perceived conflicts of interest should be declared and managed in accordance with this policy.
This provides a clear line of sight for management and promotes transparency in decision-making
around international engagements.
Professional boundaries
Police employees should always tread very careful y lest professional relationships with members of the
public develop into close personal relationships (where the relationship is intimate). Such relationships
compromise professional boundaries and may lead to a conflict of interest because of a power
imbalance. Imbalances of power are likely to exist in professional relationships with members of the
public that Police deal with due to:
- members of the public being required to disclose private, confidential or highly personal
information to Police
- the ability and power held by Police to make decisions relating to certain members of the public,
e.g. Police has the power to arrest, to detain, to further a complaint or issue an infringement, or
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otherwise affect outcomes for that person
- a member of the public being vulnerable due to personal circumstances.
In some cases, personal relationships with members of the public can be inappropriate, such as those
with:
- witnesses in a current investigation and their family members
- informants
- vulnerable persons where a duty of care exists
- any person in custody
- complainants in a current investigation in which the Police employee is involved.
Any professional involvement with people with whom a Police employee has a pre-existing personal
relationship is likely to create a conflict of interest. A Police employee is expected to take steps to
manage any personal relationship where a conflict of interest arises, including declaring any such
(potential) relationship, to a supervisor.
To help keep yourself and the organisation safe, specific guidance around the issue of maintaining
professional boundaries has been included as an appendix to this chapter.
Conflicts of interest in a non-work-related context
As a Police employee, the lines of separation between our personal and professional lives are often
blurred. It is often the case that your actions/views wil be seen as those of New Zealand Police by the
public.
It is important that Police employees not misuse their positions to benefit themselves, their col eagues or
others they have a close connection with (such as family members). By way of example, wearing Police
uniform or displaying Police identification cards may, in some situations, be seen as an attempt to
inappropriately influence or intimidate. (Scenarios could include negotiating purchases or services,
intervening in a dispute in support of a family member or friend, showing a Police ID when off duty to
gain entry to licensed premises or restricted areas, attempting to influence through social media posts.)
Police employees who attend Court in a support role for an accused person and identify themselves as
Police employees could unwittingly give the impression that the organisation supports the accused
person. Such actions could also be misinterpreted as being an attempt to intimidate or influence
witnesses in the Court proceedings.
As individuals, we have an increasing online presence on various social media platforms, both through
our work and through our personal lives. Connections can be made between those various platforms by
members of our community, media and others seeking to corrupt police employees. Always consider the
SELF CHECK before posting and make it clear that opinions you express are your own, and not those of
New Zealand Police. Check the Social Media Police manual chapter’s section on Personal use of social
media for tips on how to keep yourself and Police safe online.
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How to manage conflicts of interest
If possible, avoid the conflict
Police employees may be able to avoid conflicts of interest by abstaining from involvement in the
decisions or actions that could be compromised by their other interests. Likewise, they should avoid
activities where they could be seen to be at an advantage because of information or other resources they
have access to because of their role with Police. For example, Police employees should fol ow the same
channels as members of the public in order to access Police data for their own research.
In a response or investigative context, another employee could be assigned to the incident or
investigation. If that is not immediately possible, any decisions required could be deferred to another
employee.
For those in governance roles, conflicts can most readily be avoided if they are considered prior to
discussions. It is good practice to have a ‘declaration of interests’ agenda item at the start of every
meeting, such as: “Does anybody present need to declare any interests that might be considered
prejudicial to their independence in relation to the items on the agenda?”
The same principles should be kept in mind when conducting al work - when responding to incidents,
assigning or conducting investigations and participating in decisions in various roles. Police employees
should always consider whether an outside observer could have reason to question their independence.
How to participate in the management of the conflict
Police employees should discuss the conflict of interest and how it could be managed with a supervisor
and cooperate with the management plan. Employees who know the subject of an investigation or were
former col eagues of the subject may not necessarily be excluded from further related activity (e.g.
ongoing work for an investigation) for that reason. Employees who are concerned that the management
plan does not properly address the conflict, should raise those concerns with a supervisor, and escalate
them if necessary.
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Supervisor and manager responsibilities
Supervisors or managers should foster an environment where employees feel free to discuss issues such
as conflicts of interest. When a conflict of interest is identified, they should discuss the risks associated
with the conflict with the individual employee.
It is the supervisor’s responsibility to determine whether the conflict could prevent the involved
employee from being able to make unbiased decisions, or whether a reasonable observer may consider
the involved employee to be biased. Supervisors should seek advice from their own supervisor if they are
unsure of the potential impact of the identified conflict.
Together with the involved employee, supervisors should assess the risks involved with the conflict and
consider strategies to manage it. Conflicts of interest can be managed in a range of ways, depending on
the circumstances:
- noting the conflict of interest only, if in the supervisor’s view the conflict of interest wil not cause
bias or give the perception of bias
- obtaining the agreement of involved parties about the participation of the conflicted employee
- imposing additional oversight over the conflicted employee’s work
- assigning work to another employee
- assigning work to an employee outside the District, Service Centre or work group
- an employee stepping back or away from the role that is causing the conflict.
In cooperation with the involved employee:
- assess the seriousness of the conflict - is the risk low, medium or high? (Consider the Risk Matrix
found in the Risk Management Summary to identify strategies appropriate to the risk level)
- document the conflict of interest and how the conflict was managed
- support staff when issues arise, ensure there are channels in place for people to raise concerns
about how their declared conflict(s) of interest are being managed or breaches of the conflicts of
interest policy.
- monitor the conflict of interest, if required, for any changes in circumstance
- consider strategies to avoid future conflicts.
Management plans can take many different forms. As previously mentioned, the important thing is that a
management plan is documented.
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Appendix: Maintaining professional boundaries
As an organisation, we need to maintain our professional boundaries in al of our dealings with members
of the public. There is a continuum of behaviour from under involvement to over involvement, and the
professional relationship sits in the middle.
Breaches of this professional relationship occur when a police employee becomes over involved with a
person they are dealing with through work. Over involvement may occur gradual y, and accidental y. A
police employee may feel the over-involvement is justified because they are trying to help the person.
Over-involvement with a member of the public may result in a conflict of interest which can be mitigated
through early identification and resolution. If not addressed, the over-involvement could seriously harm
the member of the public, particularly if they are vulnerable to begin with.
Failing to maintain our professional boundaries presents a risk to the public, our col eagues and the
organisation as a whole. If the public’s trust and confidence in Police is undermined, this affects our
ability to keep our communities safe and feeling safe.
Steps you can take to keep yourselves and others safe
-
Take responsibility for maintaining professional boundaries - help members of the public
understand when their requests or behaviour are beyond the limits of the professional
relationship.
-
Document all contact in NIA.
-
Involve a support person or a police col eague where possible when meeting/corresponding,
particularly if meeting in remote locations or the person’s home.
-
If the person makes contact outside working hours, when replying state that you wil make
contact when actual y back at work.
-
Keep colleagues/supervisors informed about meetings/dealings with the person - if you feel
hesitant to do this, ask yourself if the behaviour is professional.
-
Consider the cultural values of the person you are dealing with - seek advice from cultural
advisors.
-
Raise concerns with a colleague if there is reason to believe they are behaving inappropriately.
Sometimes employees may not be aware that their actions are inappropriate.
-
If in doubt, ask yourself whose needs are being met- yours or the member of the public. Make
sure your behaviour doesn’t cause confusion about your role.
-
Develop and follow a plan of contact.
Possible warning signs that a professional relationship may be crossing a line and that an inappropriate personal or sexual relationship is developing:
- The employee reveals feelings and aspects of his/her/their personal life to the member of the
public.
- The relationship becomes emotional y close.
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Managing conflicts of interest
Proactively released by New Zealand Police
- The relationship carries on outside the professional setting, outside normal working hours or after
the professional relationship has ceased.
- The employee dwel s on the relationship when away from work.
- The employee provides personal contact information.
- The person insists on speaking with a particular employee and refuses to speak to other
employees.
- The employee denies previous interaction with someone they are dealing with.
- The employee accesses the person’s NIA record without justification.
- The employee gives or accepts social invitations.
- Texting or other forms of direct messaging that is not professional y focused.
- Any contact the employee makes with the person via social media.
- Intimate touching.
This document was current at 12 May 2025. Police policies are reqularly reviewed and updated.
The most current version of Police policies are available from www.police.govt.nz
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Document Outline
