declarations of interest procedure for release.pdf

•  Accessing MBIE’s services in a personal capacity (e.g.

contacting Tenancy Services as a landlord or a renter, the
Official Assignee if adjudicated bankrupt, the Companies
Office if a director or shareholder etc).
Some MBIE roles may have a greater risk of a conflict of interest
than others, including:
•  Procurement or similar roles involving MBIE contracts or
suppliers
•  Working in smal  communities
•  Working in high-risk locations
•  Roles with access to personal, in-confidence, sensitive or
restricted information or administering and safeguarding
internal MBIE processes
•  Roles with decision-making responsibilities.
Real conflict of interest
Where a conflict already exists or is about to occur. Some guidance
splits this category into actual conflicts and potential conflicts.
An actual conflict is where the conflict already exists.
A  potential conflict is where a conflict could develop from the
declared interest due to a change in circumstances (e.g. a family
member is considering applying for a role at MBIE).
Perceived conflict of interest
A perceived conflict is where a reasonable person (who may not
have al  of the relevant information) might think that a conflict
exists between personal interests and a person’s role at MBIE.
Declaration of interest
Your declaration(s) in Camms of any conflicts of interest(s).
Management plan
The plan developed by a people leader/manager with their direct
report outlining steps taken to remove or reduce the risk to our
people and MBIE.
3
Declaring an interest – Our people
Key requirements
3.1
Our people must:
a.
Ensure they understand key policy requirements and identify interests outside of work that
might overlap with their role at MBIE
b.
Declare in Camms al  interests relevant to the work that they do and the position they hold
(anyone unable to access Camms must complete a manual declaration form and send this
to their people leader/manager and MBIE’s Integrity team)
Declaration of Interest form [DOCX 150KB]
c.
Provide al  information about the possible conflict to their people leader/manager to ensure
MBIE is ful y aware of the circumstances
d.
Comply with the management plan as agreed with their people leader/manager
e.
Update declarations when circumstances change, including changing roles

Title:
Declarations of Interest Procedure
Next Review:
September 2027
Date of Issue:
September 2024
DCE Sponsor:
Deputy Secretary, Corporate Services, Finance and Enablement
Last Review:
November 2019
Policy Owner:
Head of Integrity
Approved By:
CE
Classification:
UNCLASSIFIED
Page 4 of 11

f.
Review declarations regularly to ensure these are current.
g

What should be declared?
Consider whether your personal interest, obligation or relationship (e.g. your acquaintance at
MBIE, involvement in a community group or shares in a company):
•
is relevant to, or could be perceived by others as conflicting with,  your role and
responsibilities at MBIE, or MBIE’s services or functions more general y
•
could influence your ability to carry out your role, make robust or unbiased decisions, or
exercise a high standard of judgement, or could create a perception of this
•
could undermine the integrity of your work, your team’s work or MBIE more general y
•
may cause confusion for external stakeholders or members of the public about whether you
are representing MBIE or acting in a personal capacity.

3.2
Declarations must be clear and appropriately detailed.  Your manager should have enough
information to make an informed decision about whether there is a conflict of interest and the best
way to manage this.
3.3
If you are unsure about whether to declare an interest, you should discuss this with your people
leader/manager. The Integrity team can also provide further guidance on what should be declared
in Camms.
3.4
If you are undertaking a  joint operation with other agencies, or participating in a cross-agency
working group, you should declare personal and work interests relevant to the work you do and the
role you have in the joint operation or cross-agency working group.

What information should I include in my declaration?
•
Consider the level of information a person not familiar with your situation or circumstances
would need to make a decision.
•
This includes information such as (but not limited to):
o  Ful  names of other parties involved and your relationship/connection with them
o  Relevant application, client, file numbers or references etc.
o  For declarations about secondary employment, voluntary work or other community
involvement:
  details about your role and position responsibilities
  your likely hours or anticipated output, any other expectations of you and the
potential impact on your MBIE role.
4
Managing a declared interest – People leaders/managers

Key requirements
4.1
People leaders/managers must also:
a.
Have regular conversations with their direct reports about possible conflicts of interest and
ensure they understand key policy requirements

Title:
Declarations of Interest Procedure
Next Review:
September 2027
Date of Issue:
September 2024
DCE Sponsor:
Deputy Secretary, Corporate Services, Finance and Enablement
Last Review:
November 2019
Policy Owner:
Head of Integrity
Approved By:
CE
Classification:
UNCLASSIFIED
Page 5 of 11

b.
Review declarations made by their direct reports in a timely manner

c.
Discuss the declaration with their direct report
d.
Develop an appropriate and effective management plan with their direct report and ensure
this is entered into Camms within 10 working days
e.
Ensure compliance with the management plan
f.
Review open declarations and management plans regularly.
4.2
The  Integrity team  can provide further guidance to people leaders/managers and their direct
reports at any stage during this process.
A.  Reviewing and assessing the declaration
4.3
Before creating a management plan in Camms, it can be useful to first assess the declared interest
and think about how this may impact your direct report and MBIE.

1 1

When assessing declarations of interest, people leaders/managers should consider factors
such as:
How close is the connection between the declared interest and your direct report’s role and
responsibilities at MBIE?
a.
Consider the level of conflict or overlap between their role and their declared interest –
think about your direct report’s access to MBIE information in their role, stakeholders they
work with regularly and their decision-making responsibilities.
b.
How does the declared interest impact, or potential y impact MBIE’s functions or services
(e.g. tenancy, immigration, employment etc)?
c.
Consider the seniority of your direct report and the public profile of their role/duties – this
may include the nature or significance of the work they do and the position they hold.
d.
For a conflict involving whānau or friends, how wel  does your direct report know the
person? A close relationship may create a conflict of interest, but an acquaintance they
have not spoken to since high school is less likely to be a conflict you need to manage
closely.
How would this conflict be perceived by the public (or others)?
a.
Is there potential for the outside interest to cause confusion for external stakeholders or
members of the public? Think about whether a (reasonable) person may have concerns
that your direct report could be compromised or was not impartial, even if they did not
know al  the facts.
b.
How would this interest be viewed by the media?
c.
If we had to defend our position in public, would someone think we had done the right
thing? Would our actions maintain trust and confidence in our people and MBIE?
d.
Perceived conflicts of interest can be just as ‘risky’ to MBIE as actual conflicts – we stil
need to be careful when managing these to ensure we maintain public confidence in our
people and the work that we do.
1 2

B.  Setting up a management plan
4.4
After the declaration of interest has been reviewed and assessed, a detailed management plan
should be developed by the people leader/manager and their direct report. It is important to ensure

Title:
Declarations of Interest Procedure
Next Review:
September 2027
Date of Issue:
September 2024
DCE Sponsor:
Deputy Secretary, Corporate Services, Finance and Enablement
Last Review:
November 2019
Policy Owner:
Head of Integrity
Approved By:
CE
Classification:
UNCLASSIFIED
Page 6 of 11

that the plan has enough detail, is relevant to the individual circumstances of your direct report and

supports them in keeping themselves and the Ministry safe.
4.5
Declarations of Interest – Examples of Management Plans developed by the Integrity team are
available on Te Taura –  these include suggested wording and possible factors for people
leaders/managers to consider when developing a management plan.

When developing a management plan, a good test is that another people leader/manager, with

no prior knowledge of the declared conflict of interest, could read and understand the plan that
has been agreed to and see how the risk is being actively managed.

Management plan options
4.6
People leaders/managers have a number of options when managing declarations of interest (some
agencies refer to these as the ‘five Rs’ or similar and they usual y cover options such as reassigning,
removing or reducing etc). At MBIE, possible options include:
a.
Reassigning or reallocating work to another staff member, team or business group.
b.
Reviewing or setting up additional oversight – this can be temporary or longer term, and
across a topic, issue or specific piece of work (reviewers can be senior members in the wider
team or unrelated third parties).
c.
Removing the person from a matter or a decision-making process e.g. from meetings when
a specific project is discussed, a recruitment process, a committee or working group.
d.
Restricting a person’s involvement in the matter, their access to some MBIE information, or
otherwise setting up an information barrier to reduce the possible risk to MBIE caused by the
conflict of interest.
e.
Reducing or removing the personal interest, obligation or relationship  that creates the
conflict e.g. sel ing their shares, reducing or ending their community involvement or
secondary employment etc.
f.
Recording the conflict in Camms but taking no further action. This can be an appropriate
management plan where the possible risk to MBIE is very low – the declaration of interest
remains open in Camms and should be reviewed regularly, but no further action is required
unless circumstances change.
g.
Resignation – your direct report’s resignation from a position would be a last resort and may
be appropriate where we cannot remove or reduce a significant risk to MBIE in any other
way – contact People & Culture for guidance on this.
C.  Monitoring and reporting
4.7
People leaders/managers should regularly review the agreed management plan with their direct
report to make sure the plan remains current and is appropriate in the circumstances.
4.8
This can occur during regular conversations as part of MBIE’s performance and development cycle
or more informal y at one-on-one catch-ups etc. These conversations with your direct report wil
provide them with an opportunity to declare any new interests,  update you on any change of
circumstances, and agree on new and/or updated management plan(s).
4.9
Any changes or updates should be recorded in Camms. Where the declaration or management plan
has changed significantly, it may be best to close off the current entry and create a new declaration
and management plan.
4.10
Declarations  of interest are held securely in Camms and access to these records is restricted.
Integrity may report general declarations of interest information (including numbers, categories
Title:
Declarations of Interest Procedure
Next Review:
September 2027
Date of Issue:
September 2024
DCE Sponsor:
Deputy Secretary, Corporate Services, Finance and Enablement
Last Review:
November 2019
Policy Owner:
Head of Integrity
Approved By:
CE
Classification:
UNCLASSIFIED
Page 7 of 11

and trends) to senior or assurance staff as required, however Integrity limits personal information

provided as much as possible.
D. Closing the entry in Camms
4.11
The declaration and management plan should remain open in Camms until the interest no longer
exists. For example, a management plan relating to a board membership should remain open until
the person is no longer on the board, even if there is currently no obvious conflict.
4.12
Alternatively, after reviewing a declaration made by your direct report, you may consider that the
circumstances do not create a perceived or actual conflict and there is no potential risk to MBIE. In
this case, the Camms entry can be closed without creating a management plan but you should note
in the ‘Closure’ tab in Camms why you consider there is no conflict of interest. For guidance on
whether a Camms entry can be closed, contact the Integrity team.
5
Speaking up – Raising concerns or reporting wrongdoing
5.1
Anyone can raise concerns of real or perceived wrongdoing about any declared or undeclared
interests, or about the way any conflict of interest is being managed at MBIE. To raise concerns,
contact the Integrity team at [email address]
5.2
Alternatively, suspected wrongdoing can be reported by:
a.
contacting MBIE’s Integrity Line to report a concern anonymously (available 24/7):
•
0800 33 77 33 within NZ
•
+64 9 927 5905 from overseas
•
www.integrityline-nz.org/reporting-mbie
b.
submitting a Speaking Up event through MBIE’s online event reporting tool, Camms
c.
speaking to your people leader/manager or your manager’s manager.
5.3
To report conduct or behaviour that amounts to ‘serious wrongdoing’ as defined by the Protected
Disclosures (Protections of Whistleblowers) Act 2022, refer to MBIE’s Protected Disclosures Policy
and Procedure.

Title:
Declarations of Interest Procedure
Next Review:
September 2027
Date of Issue:
September 2024
DCE Sponsor:
Deputy Secretary, Corporate Services, Finance and Enablement
Last Review:
November 2019
Policy Owner:
Head of Integrity
Approved By:
CE
Classification:
UNCLASSIFIED
Page 8 of 11

Appendix 1 – Common types of interest

a.  Involvement in a recruitment panel
If you are acting as a member of a recruitment panel you must declare al  real and perceived conflicts of
interest with applicants and step down if you have a close personal relationship with any applicant as soon
as you become aware of this, i.e. prior to shortlisting occurring.
Applicants with a close personal relationship with the recruiting manager wil  not normal y be considered for
appointment. The recruiting manager may seek an exemption from the Deputy Chief Executive or the Chief
Executive in extraordinary circumstances.
b.  Secondary employment
It is important to understand that your MBIE role and responsibilities may affect the ways you engage in
activities outside of your work for MBIE.
You must declare any secondary employment that could be a conflict of interest, whether on a paid or
voluntary basis. This is to ensure that you can perform your duties honestly and impartial y and avoid any
situations which may compromise (or be seen to compromise) your integrity in the work that you do and the
position you hold.
In most cases you can undertake secondary employment while working for MBIE, however there may be
some circumstances where secondary employment may impact on your ability to perform your MBIE role.
As a general rule, if there is scope for confusion because others might reasonably think that the two roles are
similar, related or the same, then a real or perceived conflict of interest exists and careful management wil
be required by you and your people leader/manager.
When discussing and agreeing on a management plan, people leaders/managers wil  take into consideration
a range of factors, including the closeness and materiality of any secondary employment to the work that
you do and the position that you hold at MBIE. People leaders/managers wil  also consider the potential for
an impairment to safety, wel being or performance as a result of you working extended hours.
c.  Financial interests
You must declare any contracting, consulting, directorships or other business ventures that you are involved
with, material in nature, whether on a paid or voluntary basis. This is to ensure that you can perform your
duties honestly and impartial y and avoid any situations which may compromise (or be seen to compromise)
your integrity in the work that you do and the position you hold.  You must also declare if you are adjudicated
bankrupt or have shares in a company relevant to MBIE’s functions or services (e.g. building, energy markets,
immigration etc).
Financial interests such as company shares, managed funds or smal er investments offering monthly plans
(e.g. Sharesies) should also be declared if they create a real or perceived conflict of interest.
If you are unsure whether you need to declare a financial interest, discuss this with your people
leader/manager or contact the Integrity team.
d.  Interests related to my wider community
You must take care that you do not inadvertently find yourself in situations where others might reasonably
think that you could be or have been compromised, such as:
•
accessing or using Ministry data, information or systems for the benefit, interest or advantage of
another person, group or organisation
•
publicly  criticising or commenting in a personal capacity on policies with which you have been
professional y involved.

Title:
Declarations of Interest Procedure
Next Review:
September 2027
Date of Issue:
September 2024
DCE Sponsor:
Deputy Secretary, Corporate Services, Finance and Enablement
Last Review:
November 2019
Policy Owner:
Head of Integrity
Approved By:
CE
Classification:
UNCLASSIFIED
Page 9 of 11

If you find that your personal views or beliefs on a topic or issue are in conflict with the Government to the
exte nt that you  cannot perform your  duties,  you  must immediately declare this to your  people
leader/manager.
e.  Political views and involvement
You are expected to be political y neutral in al  of your workplace interactions, irrespective of what your
personal views may be.
It is important that you make it clear to others when you are commenting as a private individual. You must
not publicly criticise or comment in a personal capacity on Ministry policies with which you have been
professional y involved. Further guidance is available in the Integrity team’s Political neutrality - Quick guide
– this was prepared during an election year, but the general principles and guidance stil  apply.
You may be a member of a political party, however you must not reveal advice given to the Government and
you must abide by your duty of confidentiality to MBIE.
If you intend to hold office in local or central government you must declare this ahead of time so that your
people leader/manager can discuss an appropriate management plan with you.
If you find that your personal views or beliefs on a topic or issue are in conflict with the Government to the
extent that you cannot perform your duties in a political y neutral way, you must immediately declare this to
your people leader/manager.
f.  Whānau/family or friends
You should declare any whānau and close friends that work for or with MBIE (including but not limited to
vendors, suppliers or regulated entities) to avoid others perceiving an unfair advantage or questioning your
impartiality.
People leaders/managers wil  take into account the closeness and materiality of the relationship to ensure
that you can perform your duties honestly and impartial y and avoid any situations which may compromise
(or be seen to compromise) your integrity in the work that you do and the position you hold.
You  must not access or work on matters for your  whānau  and  close  friends, or  provide them with
unauthorised advice or assistance.  This includes accessing MBIE systems and databases to view MBIE
information related to your whānau or friends e.g. tenancy or immigration databases etc. It does not matter
whether you know this information already – MBIE systems and information should only be used for a
genuine work purpose, not for your personal benefit or for the benefit of others.
g.  Career or profession
You should declare any close business associates where there is a conflict of interest due to their:
•  work with MBIE
•  work for entities that lobby MBIE or the Government
•  work for entities that seek a product, service or expertise from MBIE.
People leaders/managers wil  take into account the closeness and materiality of the working relationship to
ensure that you  can perform your  duties honestly and impartial y and avoid any situations which may
compromise (or be seen to compromise) your integrity in the work that you do and the position you hold.
Some professions have obligations that require their members to have a higher duty of care, i.e. lawyers,
accountants, etc.
If you find that your professional obligations on a topic or issue are, or could be, a conflict of duty with MBIE,
you must immediately declare this to your people leader/manager.
h.  Declaring gifts, hospitality or entertainment I am offered from third parties

Title:
Declarations of Interest Procedure
Next Review:
September 2027
Date of Issue:
September 2024
DCE Sponsor:
Deputy Secretary, Corporate Services, Finance and Enablement
Last Review:
November 2019
Policy Owner:
Head of Integrity
Approved By:
CE
Classification:
UNCLASSIFIED
Page 10 of 11

Refer to MBIE’s Gifts, Hospitality and Entertainment Policy.
i.    Purchasing or procurement activities
If you are involved in procurement (purchasing, buying or tendering on behalf of MBIE), you must meet al
additional conflicts of interest requirements under the Procurement Policy. Contract managers should also
ensure that conflicts of interest for MBIE staff involved in the contract process (including Tender Evaluation
Panel members) are recorded in Camms as required by this policy.
j.  Al ocation of grants and other funding
If you are involved in assessing or awarding grants or funding, you  must take care that you  do  not
inadvertently find yourself in situations where others might reasonably think that you could be or have been
compromised, e.g. influencing or participating in a decision to award grants or other funding where you are
connected to or associated with a person, group or organisation that submitted an application etc.
Your people leader/manager wil  take into account the closeness and materiality of the relationship to ensure
that you can perform your duties honestly and impartial y and avoid any situations which may compromise
(or be seen to compromise) your integrity in the work that you do and the position you hold. If required, your
people leader/manager wil  then set up a management plan to manage any real or perceived conflicts of
interest.
k.  Social media
It’s important that you make it clear to others when you are commenting as a private individual. You must
take care that you do not inadvertently find yourself in situations where others might reasonably think that
you could have or have been compromised by something you’ve said online. Refer to MBIE’s Code of Conduct
for more information.

Title:
Declarations of Interest Procedure
Next Review:
September 2027
Date of Issue:
September 2024
DCE Sponsor:
Deputy Secretary, Corporate Services, Finance and Enablement
Last Review:
November 2019
Policy Owner:
Head of Integrity
Approved By:
CE
Classification:
UNCLASSIFIED
Page 11 of 11