POL-10 — Conflict of Interest Policy

A conflict of interest exists where a person's private interests could influence — or appear to influence — their professional decisions at CONVI. This policy ensures that conflicts are identified early, disclosed formally, and managed before they affect participant care or organisational integrity.

Document reference	POL-10
Version	v1.1 (supersedes v1.0)
Status	Current — Authoritative
Changes in v1.1	Added: personal relationships with participants outside service delivery (Section 5); participant to employee/business partner pathway (Section 6)
Review cycle	Annual

1. What Is a Conflict of Interest

A conflict may be actual (private interest has already influenced a decision), potential (could do so), or perceived (a reasonable person would believe it could). All three types require disclosure. Common examples in disability support include:

A worker is a friend, family member, or former intimate partner of a participant
A worker has developed a personal relationship with a participant outside the professional context
A director or worker receives gifts, benefits, or hospitality from a participant, their family, or a supplier
A worker is providing unsanctioned private support to a participant outside of CONVI arrangements
A director or worker has a financial stake in a competing provider

2. Disclosure Obligations

All CONVI staff and directors must disclose actual, potential, or perceived conflicts of interest to the Director in writing as soon as they become aware. Disclosures are recorded in the CONVI Conflict of Interest Register (REG-05).

Failure to disclose a conflict of interest is a serious breach of the Code of Conduct and may result in disciplinary action, including termination.

3. Managing Conflicts of Interest

Management approach	When used
Removal	Person removed from the decision or activity entirely. Used where conflict is significant.
Restriction	Person excluded from certain information or specific aspects of a decision.
Disclosure without restriction	Conflict noted on record; person continues. Used where the conflict is minor and transparency is sufficient.
Monitoring	Conflict recorded and monitored for changes.

4. Gifts & Benefits

Workers and directors may accept gifts of nominal value (under $20) from participants or families — home-baked items, cards. Recurring gifts or gifts creating an obligation require disclosure. Workers must not accept:

Cash or cash equivalents of any value
Gifts over $20 in value
Gifts from suppliers or commercial parties that could influence decisions
Invitations to events or meals that could create an obligation

A gift that cannot be declined without causing significant offence is accepted, disclosed to the Director within 24 hours, recorded in the Gifts Register section of REG-05, and its treatment determined by the Director.

5. Personal Relationships with Participants Outside Service Delivery

Any CONVI worker or director who develops a personal relationship with a current participant — including a friendship that extends to social contact outside of CONVI-delivered sessions — must disclose this to the Director in writing.

Where a director or worker and a participant engage in personal social activities outside the NDIS service delivery context, the following conditions apply:

The personal activity must not be claimed as an NDIS session under any circumstances
The personal relationship must be disclosed in REG-05 and reviewed regularly
The Director must assess whether the personal relationship creates a risk of influence on clinical decisions, billing, or advocacy positions
Where a perceived conflict exists, the Director considers whether the formal NDIS service relationship should transition to another provider

6. Participant to Employee or Business Partner Pathway

A CONVI participant may over time be considered for employment or a business relationship with CONVI. The following process governs this:

The person must cease all NDIS service receipt from CONVI before employment commences
A minimum of one full NDIS plan period — or three months, whichever is longer — must pass between end of service relationship and commencement of employment
No financial arrangement — investment, partnership, shareholding — is entered into while the person remains a CONVI participant. This is absolute.
Any financial arrangement requires independent legal advice for both parties before execution

7. Participant Financial Transactions

Workers must not:

Lend or borrow money from a participant or their family
Accept payment outside CONVI's billing arrangements
Be named as a beneficiary in a participant's will or estate
Assist a participant to change their will, power of attorney, or financial arrangements

POL-10 | v1.1 | May 2026 | Convi Pty Ltd (ACN 677 127 703) as Trustee for Attard Family Australia Trust | ABN 60 342 025 267

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