Kaizen Living PTY LTD Policy

Conflict of Interest Policy

This policy sets out how Kaizen Living PTY LTD identifies, discloses, manages, monitors and records actual, perceived and potential conflicts of interest in the delivery of supports and services, in line with the NDIS Practice Standards.

Version 1.0 · Scheduled for review May 2027

Purpose and aims

This policy supports compliance with the NDIS Practice Standards, including the requirement that perceived and actual conflicts of interest are proactively managed and documented through organisational policy and practice.

It aims to ensure that participants receive supports that are ethical, transparent and centred on their rights, choice and control; that workers act with integrity, honesty and transparency; and that conflicts of interest do not improperly influence decision-making, referrals, service recommendations or access to supports.

Scope

This policy applies to all workers, including directors, key personnel, managers, employees, contractors, students, volunteers and any other persons engaged by Kaizen Living PTY LTD. It applies across all services, supports, procurement, referrals, recruitment, partnerships, purchasing decisions and any other activity where a conflict of interest could arise.

What is a conflict of interest?

A conflict of interest is a situation where a person or organisation has an actual, perceived or potential opportunity to place their own interests, or the interests of another person or entity, ahead of the interests of a participant or the proper performance of their duties.

Actual conflict of interest: a conflict that currently exists and is influencing, or could influence, a decision or action.
Perceived conflict of interest: a conflict that may appear to exist to a reasonable person, whether or not it is in fact influencing the decision or action.
Potential conflict of interest: a conflict that may arise in the future because of a person's interests, relationships or responsibilities.

Our commitment

Kaizen Living PTY LTD is committed to acting in the best interests of participants and to managing conflicts of interest in a way that protects participant rights, safety, dignity, choice and control.

Workers must not exploit their position for personal, financial, business or other gain, or allow any external relationship, secondary interest, gift, benefit, referral arrangement or competing duty to improperly influence the delivery of supports or organisational decision-making.

Participants must be provided with accurate, timely and transparent information about support options, including options not delivered by Kaizen Living PTY LTD, so they can make informed decisions free from pressure, coercion or improper influence.

Disclosure requirements

All workers must disclose any actual, perceived or potential conflict of interest as soon as they become aware of it, including on commencement and whenever circumstances change.
Disclosures must be made in writing to management using the approved declaration process.
Failure to disclose a relevant conflict of interest may result in corrective action in accordance with organisational procedures.

Managing conflicts

Where a conflict of interest is identified, Kaizen Living PTY LTD will assess the risk, determine appropriate controls, document the decision, communicate relevant information where appropriate, and review the effectiveness of the management strategy. Controls may include restriction from decision-making, supervision, reassignment of duties, alternative referral pathways, participant disclosure, procurement safeguards or removal of the conflicting arrangement.

Removing the worker from a decision or process.
Assigning the participant to another worker or manager.
Providing the participant with alternative service options.
Implementing additional oversight or approval controls.
Prohibiting acceptance of gifts, incentives or commissions.
Ending or changing the relevant arrangement where the conflict cannot be appropriately managed.

Participant protection

Participants will not be disadvantaged because they choose not to use a related provider, recommended supplier or additional service. Workers must not require, pressure or incentivise participants to use a particular service, provider, product or arrangement where doing so would limit informed choice and control.

Gifts, benefits and hospitality

Workers must not solicit gifts, benefits or hospitality and must declare any offer that could influence, or reasonably be perceived to influence, their professional judgement. Kaizen Living PTY LTD may prohibit acceptance of gifts or set thresholds and approval requirements through related procedures.

Recordkeeping and monitoring

All conflict disclosures, assessments, management actions and reviews must be documented and retained in accordance with privacy, confidentiality and records management requirements. All declarations and management outcomes are recorded in the Conflict of Interest Register, and controls are reviewed periodically and whenever circumstances change.

Roles and responsibilities

Governing body / key personnel: approve this policy, promote a culture of integrity, ensure appropriate governance controls are in place, review significant conflicts and monitor compliance.
Managers / supervisors: receive disclosures, assess risks, decide management strategies, ensure participant protection, maintain records and escalate significant matters where required.
Workers: identify and declare conflicts of interest, cooperate with management strategies, avoid improper influence and act at all times in the best interests of participants.
Participants: may raise concerns where they believe a conflict of interest has affected, or may affect, the supports or information they receive.

Breaches

Suspected breaches of this policy must be reported to management and may be managed under complaints, misconduct, disciplinary, incident or governance processes as applicable.