Conflict of Interest Policy
A conflict of interest exists in any situation when a person has a financial interest, a private or personal
interest, or a business interest sufficient to influence, or appear to influence, the impartial exercise of
their official duties or professional judgements. The aim of this policy is to ensure that real or perceived
conflicts of interest do not hamper efficient and effective governance and management of the Company.
It is impossible to eliminate all situations that may lead to a conflict of interest but such situations can
be managed to avoid the adverse effects that could result.
PURPOSE The purpose of the Conflict of Interest policy is to enable Directors and Staff to recognise and manage
potential or perceived conflict of interest situations in order to protect the Directors and staff and to
preserve public trust in the Company.
SCOPE / APPLICATION This policy applies to al Directors and Staff employed by Far North Holdings Limited.
DEFINITIONS
Definitions of terms used in this policy are at Appendix One.
PRINCIPLES
All Directors and Staff are expected to adhere to the principles articulated below:
1) Directors and Staff should not allow self-interest or personal factors to influence their decision
making.
2) Directors and Staff should take every precaution to avoid a situation where a conflict of interest
or any perception of a conflict or interest could arise in the carrying out of their duties.
3) Staff should take care that their financial, familial, personal or business relationships or interests
do not unfairly disadvantage or advantage other members of staff, or other individuals and
organisations.
(a) Staff are expected to inform their Manager as soon as reasonably possible if an actual,
perceived or potential conflict of interest arises. The Manager is responsible for taking
appropriate steps to resolve the situation and report the circumstance and the steps taken
to the Chief Executiveat the earliest opportunity. In assessing an application consider not
only whether the Staff is likely to act inappropriately but also consider the appearance of
the transaction – what an outside observer might reasonably perceive. Most often, what
needs to be managed (and be seen to be managed) is the risk of the adverse public
perception that could arise from overlapping interests.
(b) If a conflict of interest arises between Staff working in the same area, or who are in a
supervisory relationship with each other, and the conflict cannot be resolved, it may be
necessary for one or more parties to the conflict to be placed in another reporting context.
(c) Staff should not be involved in the appointment process of people with whom they have a
close personal or familial relationship.
4) Staff must ensure the highest standards of behaviour in the accepting of gifts or rewards. Any
gift that might attract the suspicion of improper motive, or which obligates the Staff Member
should not be accepted. If a Staff Member is in any doubt they should declare the gift to their
Manager in accordance with the Company’s gift policy.
Policy Name:
Conflict of Interest Policy
Policy Owner: Chief Executive
Date approved: August 2022
Policy Approver: Remuneration Committee
Review date: July 2025
5) Certain activities could place Staff in a conflict of interest situation with their obligations or duties
to the Company. Staff must not, without the prior written approval of an authorised person, use
for private or personal purposes, the Company’s:
Resources
Name
Time
Information
This includes the use of facilities and services offered by the Company even if these are
provided on normal trading terms.
Each and every such approval granted must be reported to the Board at its next meeting
providing a description of the approval and the reason for granting it.
This policy applies to al Staff employed by Far North Holdings Limited
.
AUTHORITY AND RESPONSIBILITY
1) All Managers are responsible for applying this policy and for ensuring that their Staff adhere to
it.
2) If Staff are unclear about the application of this policy to specific circumstances or situations
that effect them they should seek clarification from their Manager. The Manager may seek
advice from the Chief Executive who in turn may seek to clarify an issue with the Board or
senior auditor responsible for the FNH audit.
Policy Name:
Conflict of Interest Policy
Policy Owner: Chief Executive
Date approved: August 2022
Policy Approver: Remuneration Committee
Review date: July 2025
