Conflicts of interest policy

This policy applies to –

Organisational

• St John of God Health Care Inc and any related body corporate, collectively referred to as “SJGHC”

Individual

• SJGHC Caregivers (all employed personnel) Contractors

• Visiting Medical Officers Students 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 SJGHC. Collectively referred to as "caregiver"

Subject matter

Conflict of Interest

A Conflict of Interest (COI) 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 SJGHC's reputation and good governance.

A COI 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 SJGHC.

COIs 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.

Policy

Identifying a Conflict of Interest

1. Caregivers must –

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

Declaring Conflicts of Interest

1. Caregivers must –

1. Declare all unavoidable and potential COI to their Approving Manager, in accordance with the Conflicts of Interest Procedure.

2. Record the COI in SJGHC's Conflicts of Interest Register in accordance with the Conflicts of Interest Procedure.

3. Review their COI annually or when requested, in accordance with the Conflicts of Interest Procedure.

2. Caregivers must –

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

Managing Conflicts of Interest

1. SJGHC will -

1. Consider any willful contravention of this policy to be serious misconduct.

2. Maintain a central record of all declared COI, which will be reviewed at least annually.

2. Board, Management and Executive Committee members must –

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

3. Approving Managers will –

1. Complete an assessment of the interest against the caregiver's duties in accordance with the Conflicts of Interest Procedure and confirm whether a COI exists.

2. Determine the appropriate Management Plan in SJGHC's COI Register in accordance with the Conflicts of Interest Procedure.

Breach of policy

Failure to comply with this Policy by a member of SJGHC may be considered a breach of the Code of Conduct and may result in disciplinary action.

Glossary

Approving manager

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

• For all hospital/service caregivers - Hospital CEO

• For all hospital CEOs - COO

• For all service CEOs - GCEO

• For all group services caregivers - Respective Chief

• For all Chiefs, COO, General Counsel & SJG Foundation CEO - GCEO

• For the GCEO - GCFO

• For Medical Practitioners - Hospital CEO

• For board members - Board Chair

• For project steering committee members - Relevant Executive Sponsor

• For Executive & Management Committee members - Relevant Committee Chair

Conflicts of Interest Declaration Form

The electronic form currently available via Workday requests and 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 or potential 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.