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Declarations of Interest Policy
Declarations of Interest Policy
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Declarations-of-Interest-Policy-
Declarations-of-Interest-Standard
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Guide
1. Objective
The objective of this policy is to ensure that ACC and its people identify, declare,
manage and record interests that may give rise to an actual, perceived or
potential conflict of interest in a timely and effective manner.
2. Scope
This policy applies to all our people, including permanent and temporary
employees, secondees, consultants, contractors and organisations (including
vendors and third parties) engaged to undertake work on behalf of ACC.
3. Policy statements
ACC adheres to Te Kawa Mataaho | Public Service Commission’s Model Standards:
Conflicts of Interest, which outline the Commissioner’s minimum expectations for
organisations in the public service to support the identification, assessment, and
ongoing management and monitoring of conflicts of interests.
This policy, and supporting Declaration of Interests Standard, ensures that ACC’s
declarations of interest arrangements meet the standards of probity expected of
a public organisation and can withstand audit, parliamentary, and public scrutiny.
3.1 Your role at ACC must take precedence over any outside interests,
commitments or associations you may personally hold.
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3.2 You must ensure that your outside interests, commitments or associations
do not adversely affect your work commitment to ACC or conflict with ACC’s
interests.
3.3 You must not state or imply that your personal view on a matter is
representative of ACC’s position or view
Where you share your opinions within the public domain, you should consider
whether a conflict of interest could be perceived to arise between your position
as an ACC employee and the opinion that you have expressed.
3.4 If you are involved with the procurement of goods and services you must
be familiar with the New Zealand Government Procurement Rules and adhere
to the Procurement Policy.
3.5 Any outside interests, commitments or associations that could in any way
adversely affect your work commitment to ACC or conflict with ACC’s interests
must be declared prior to starting at ACC or, if you are already working at ACC,
as soon as the outside interests, commitments or associations arise.
This includes, but is not limited to, anything that may:
a. Conflict with your duties or responsibilities at ACC (e.g. working in a
medical centre that provides services to ACC clients).
b. Compromise your duties or responsibilities at ACC (e.g. working as an
advisor to a claimant advocacy group or taking a role as an advocate for a
client).
c. Impact your financial position.
d. Impair your performance (e.g. working at a second job or as a volunteer
that may result in you being too tired to undertake your duties or
responsibilities at ACC).
e. Compromise your integrity (e.g. being in a management position over a
partner / spouse or relative or being involved in the recruitment or
appointment of an associate, friend, partner / spouse).
f. Compromise your political neutrality (e.g. standing for election, or an
association with a Member of Parliament).
3.6 You are responsible for identifying, declaring, recording and managing
interests that may give rise to an actual, perceived or potential conflict of
interest.
You must:
a. Inform your people leader of any interest that may give rise to a real,
potential or perceived conflict of interest as soon as possible, unless it is
clearly and objectively insignificant.
b. Take any reasonable steps your people leader requires you to take to
manage the interest.
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c. Record the interest on the Interests Register by completing the
Declaration
of Interest Form;
d. Review declarations regularly to ensure they remain current and inform
your people leader and the Workplace Integrity team if a declared interest
is no longer relevant.
e. Advise your new people leader of any existing declared interests (and new
interests) when you transfer to a new role or team in ACC.
3.7 If you are in any doubt as to whether to make a declaration, seek
advice from the Workplace Integrity team.
People leaders must:
a. Have regular conversations with their direct reports about possible conflicts
of interest and ensure they understand key policy requirements.
b. Review and assess declarations in a timely manner. If you're unsure
whether an interest may be a conflict, treat it as one until you have clarified
the situation.
c. Work with the Workplace Integrity team to understand whether a conflict
exists and agree on ways in which any identified conflict may be resolved
or mitigated.
d. Discuss and agree a management plan with the ACC person who has
declared the interest within 10 working days of receipt of the declaration.
e. Approve and upload a signed copy of the management plan to the
Interests Register.
f. Ensure management plans are adhered to.
g. Review open declarations and associated management plans regularly.
4. Accountability and Responsibilities
Role
Responsibility
Governance and oversight
Board
Maintain oversight of the status of this policy.
Approve new and major amendments to this policy.
Chief
Overall responsibility for ensuring ACC meets its obligations under this
Executive
policy.
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Role
Responsibility
1st Line Business Groups: Identify and manage risks in day-to-day
operations
Deputy
Provide leadership to embed this policy within their business group.
Chief
Are responsible for fostering effective processes and awareness of
Executives
managing conflicts of interest within their Business Group.
Ensure their business group is compliant with this policy.
Provide assurance to the Head of Risk & Assurance that their business
group is compliant with this policy, and that any matters of non-
compliance have been dealt with appropriately.
Promote and model high standards of integrity and conduct.
People &
Ensure the recruitment process enables:
Culture
candidates to disclose potential conflicts of interest as part of the pre-
selection process.
Hiring managers and interview panellists to declare any conflicts of
interest as part of the recruitment process.
Our
Comply with this policy and associated guidelines as applicable to their
People
role.
Remain alert to potential breaches of this policy and report potential
and actual breaches to their people leader / manager.
Participate in relevant training as required.
Alert their people leader / manager / manager and / or Workplace
Integrity if they become aware of behaviour occurring within ACC that
could contravene this policy.
As required, cooperate fully with any investigation into concerns about
managing interest carried out by ACC.
Additionally, people leader / managers:
Raise the possibility of any real and / or perceived conflicts of interest
with recruitment candidates and consider whether these can be
appropriately manged
prior to making an offer of employment or
engagement.
Embed this policy into operational activities within their team.
Ensure new and existing members of their team are made aware of,
and comply with, this policy.
Ensure that decisions and management plans are documented with
meaningful narrative and supporting evidence within the relevant
timeframe.
Ensure our people are aware of channels available to raise concerns
about how their conflict is being managed and possible breaches of
this policy and support them in doing so.
Ensure that any breaches brought to their attention are documented
and notification of the breach is provided to the Head of Risk &
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Role
Responsibility
Assurance and / or Workplace Integrity team as soon as reasonably
practicable.
2nd Line Specialist Functions: Set ACC-wide expectations, policies and
procedures
Head of
Overall responsibility for the effective implementation of this policy.
Risk &
Prepare a Policy Implementation and Oversight Plan setting out the
Assurance
activity that will be performed each year to implement and maintain
this policy, covering communication, training and guidance,
compliance monitoring, and dealing with breaches.
Ensure this policy is reviewed and updated by the agreed review date.
Workplace
Ensure suitable communication, training, and guidance is provided to
Integrity
business groups to embed this policy into operational activities.
team
Maintain and update associated procedures, guidelines, and templates
so that they remain fit for purpose.
Monitor ACC’s declarable interests and practices and make
recommendations for improvement.
Maintain ACC’s Interests Register.
Provide advice and support to business groups relating to this policy,
including any breach management / mitigation activities as required.
Report any non-compliance with this policy to the Head of Risk &
Assurance.
3rd Line Independent Assurance: Provide independent assurance and
advice
Internal
Provide independent assurance over the design and operation of
Audit
governance, risk management, and internal controls, including 1st and
2nd lines.
Provide advice on controls design and approaches to self-assurance as
required.
Respond to ad hoc requests from business groups for assurance.
5. Measures of success and compliance
management
The policy owner will assess the effectiveness of this policy based on the
following measures of success:
a. Our people declare interests on ACC’s Interests Register.
b. Conflicts have an agreed management plan recorded within 10 working
days and the management plan remains open and current until the
circumstances creating the conflict no longer exist.
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c. There are support mechanisms available to assist people leaders /
managers in improving their skills in managing conflicts of interest.
d. ACC’s interest management arrangements are considered to be
appropriate when subjected to audit, parliamentary, or public scrutiny.
The policy owner will monitor compliance with the policy as follows:
a. Reporting to relevant Governance groups including:
- Training record trends, including completion percentages for business
groups.
- Proportion of declarations with a management plan entered within 10
working days.
b. Quarterly review and reporting of conflicts of interest declared on ACC’s
Interests Register provided to tier two and three people leader / managers
for their Business Group or Business Unit (with identifying information
removed).
Compliance information, including any identified breaches, regarding the
performance of this policy will be provided to the relevant business group and
the Compliance team on a quarterly basis.
6. Non-compliance
Failure to comply with this policy may be considered a breach of the Code of
Conduct, with potential disciplinary consequences for non-compliance.
Any action taken as a result of a breach (actual or potential) of any of the
obligations set out in this policy will be conducted in good faith, a fair process
will be followed, and the person involved will have a full opportunity to respond
to the concerns or allegations and have access to appropriate support, advice or
representation.
Non-compliance with this policy may be reported in accordance with ACC’s speak
up arrangements. These provide a safe and confidential channel for raising
concerns about breaches or misconduct.
7. Contacts
For any queries related to this policy, please contact the Workplace Integrity
team at [email address].
8. Definitions
In this policy:
Conflict of interest is any situation where your duties or responsibilities at ACC conflict, or
could be seen to conflict, with some other interest you might have
outside of work 1.
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Conflicts of interests may be:
a. Real – where you have competing interests (the conflict already
exists); or
b. Potential – where competing interests could or will arise in the
future (but do not yet exist); or
c. Perceived – where other people might reasonably think that
you have competing interests or have been compromised.
Declaration of
Your declaration(s) of any conflicts of interest(s).
interest
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 ACC.
9. References
This policy should be read in conjunction with:
a. Code of Conduct;
b. Declarations of Interest Standard – An ACC Guide;
c. Procurement Policy and Guidelines;
d. Supporting, Representing or Advocating for a Relative, Acquaintance or
Friend through the ACC Claim Process Policy;
e. Receiving Gifts and Hospitality Policy and Standard;
f. Social Media Policy; and
g. Speak Up Policy and Standard.
This policy should also be read in conjunction with the Auditor-General’s
Managing Conflicts of Interest: A Guide for the Public Sector, which contains
useful about different types of conflicts of interest (Part 3) and examples of
conflicts of interest in everyday life (Part 7).
1 Office of the Auditor General’s Managing Conflicts of interest: A guide for the
public sector
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