Conflicts of interest policy

The purpose of this policy is to:

Promote and support a culture of honest, ethical conduct and behaviour, excellent corporate governance and transparency in line with St John of God Health Care's (SJGHC) Vision, Mission and Values.
Outline the minimum requirements for all caregivers, Medical Practitioners and directors to identify and disclose any Conflicts of Interest so that they can be recorded and managed effectively.
Contribute to the St John of God Health Care Strategic enabler of Strengthening Our Culture.

This policy applies to:

St John of God Health Care Inc and any related body corporate, collectively referred to as “SJGHC”
St John of God Health Care caregivers (all employed personnel)
Contractors
Visiting Medical Officers
Student and volunteers
Diocesan Catholic Chaplains and representatives of other faiths
Trustees
Board
Other health practitioners, accredited or contracted, who provide care or services to patients, clients and caregivers of St John of God Health Care.

Collectively referred to as "caregiver".

Conflicts of interest policy

A conflict of interest is defined as a situation in which an individual may:

Derive personal benefit from actions or decisions made in their official capacity; and / or
Make a decision on behalf of the organisation that could cause detriment to St John of God Health Care's reputation.

A conflict of interest in and of itself is not wrong or unethical. However, identifying and managing the situation is important to maintain alignment to our Vision, Mission and Values, and public confidence in St John of God Health Care.

Conflicts of interest aren't just about intention. Even a gift may give the appearance of undue influence, and create a potential or perceived conflict. Consideration must be given to the facts and how they could be interpreted by others.

Identifying a conflict of interest

Caregivers must:

Proactively identify and avoid actual, perceived or potential conflicts of interest, wherever possible, to maintain confidence in SJGHC and our values.

Declaring conflicts of interest

Caregivers must:

Declare all unavoidable conflicts of interest to their approving manager, in accordance with Conflicts of Interest Procedure.
Record the conflict of interest in St John of God Health Care's Conflicts of Interest Register in accordance with Conflicts of Interest Procedure.
Review their conflicts of interest annually, in accordance with Conflicts of Interest Procedure.

Caregivers must:

Manage any perceived conflict of interest related to gifts, benefits and/or hospitality in accordance with Gifts, Benefits and Hospitality Policy.

Managing conflicts of interest

St John of God Health Care will:

Consider any willful contravention of this policy to be serious misconduct.
Maintain a central record of all declared conflicts of interest, which will be reviewed annually.

Board, management and Executive Committee members must:

Declare their conflict of interest to the committee’s Chairperson in writing, in accordance with Conflicts of Interest Procedure.

Approving managers will:

Complete an assessment of the interest against the caregiver's duties in accordance with Conflicts of Interest Procedure and confirm whether a conflict of interest exists.
Determine the appropriate Management Plan in St John of God Health Care's Conflicts of Interest Register in accordance with Conflicts of Interest Procedure.

Breach of policy

Failure to comply with this Policy by a member of St John of God Health Care may be considered a breach of the Code of Conduct and may result in disciplinary action.

Glossary

Approving manager

For the purposes of Conflicts of Interest Policy, this means:

For all hospital/service caregivers: CEO
For all hospital CEOs: COOH
For all service CEOs: Relevant GD
For all group services caregivers: Respective GD
For all GDs, COOH, General Counsel & SJG Foundation CEO: GCEO
For the GCEO: GCFO
For medical practitioners: CEO
For board members: Board chair
For project steering committee members: Relevant Executive Sponsor

Conflicts of interest declaration form

The electronic form used to declare conflicts of interest in accordance with this policy, either electronic or hard copy.

Conflicts of Interest Register

The register in use at SJGHC for the purpose of recording declared Conflicts of Interest in accordance with this policy.

Management plan

An agreed method on how to manage declared Conflicts of Interest, recorded on the Conflicts of Interest Register.