Conflict of interest policy template
A free, ready-to-edit conflict of interest policy template for Australian workplaces. Require staff and board members to disclose personal or financial interests, and set out exactly how those conflicts are managed — no signup required.
Conflict of interest policy
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By downloading, you agree to our template disclaimer
This conflict of interest policy template reflects Australian workplace and governance standards at the time of publication and is provided as a general guide to adapt for your business. It does not constitute legal, HR, or professional advice and should not be relied on as a substitute for advice specific to your business, workforce, or circumstances.
Why your workplace needs a conflict of interest policy
A conflict of interest (COI) policy protects your organisation by making sure decisions are made ethically. It requires employees and board members to disclose personal or financial interests that could clash with their professional duties — and sets out exactly how to manage or eliminate those conflicts when they arise.
Undisclosed conflicts erode trust, expose you to reputational and legal risk, and can invalidate decisions. A clear policy removes the grey area: it defines what a conflict is, when it must be declared, and what happens next. It works hand-in-hand with your code of conduct and gifts & benefits policy to keep decision-making clean.
Declarations should be recorded and tracked over time — a declaration register kept in your HR software gives you a single, auditable source of truth for every disclosed interest.
What a conflict of interest policy should cover
The building blocks of a comprehensive COI policy
Purpose & scope
Who the policy applies to — employees, contractors and board members — and why it exists.
Types of conflict
Actual, perceived and potential conflicts, with clear examples of each.
Declaration process
How, when and to whom a conflict must be reported.
Management plan
What happens once a conflict is declared — from restriction to removal.
Declaration register
A record of all disclosed conflicts and how each was managed.
Disciplinary action
The consequences of failing to declare a conflict or breaching the policy.
What's included in this template
A complete framework for disclosing and managing conflicts
Purpose & scope
The objective of the policy and who it applies to.
Definitions
Plain-language definitions of actual, perceived and potential conflicts.
Examples of conflicts
Financial interests, related-party dealings, secondary employment and personal relationships.
Declaration process
How and when employees and board members must disclose an interest.
Management plan
Options for managing a conflict, from oversight to removal from decisions.
Declaration register
A template for recording and tracking all disclosed conflicts.
Roles & responsibilities
Who reviews declarations and decides on the management approach.
Disciplinary action
Consequences for non-disclosure or breach of the policy.
Review & acknowledgement
Policy maintenance and employee sign-off.
Identifying and managing conflicts
Get the definitions and the management plan right
Actual, perceived and potential
An actual conflict is a direct clash between official duties and private interests. A perceived conflict is where it merely appears one exists. A potential conflict is an interest that could develop into a conflict in future. Cover all three — perceptions can damage trust just as much as reality.
Have a management plan ready
Declaring a conflict is only half the process. Decide in advance how each will be managed — typically by removing the conflicted person from the relevant decision or negotiation — and record the approach in your declaration register.
Managing a declared conflict
Declare
The individual discloses the interest as soon as they become aware of it.
Assess
A manager or board reviews whether a real or perceived conflict exists.
Manage
The conflicted person is restricted from, or removed from, the relevant decision.
Record
The conflict and how it was handled are logged in the declaration register.
Not every interest is outlawed — but anything that could reasonably appear to compromise judgement should be declared and managed. When in doubt, disclose.
Non-profits and charities have specific obligations — the ACNC provides a sector-specific template and governance standard. Whatever your structure, pair the policy with a fair misconduct process so non-disclosure has consistent consequences.
Who should use this template?
Any organisation where decisions could be influenced by private interests
Especially important for boards, committees, non-profits and charities with governance obligations.
Compliance & governance resources
Official guidance to help you align your COI policy with Australian standards.
Keep declarations on the record
RosterElf helps Australian businesses store policies, capture employee acknowledgements at onboarding and keep an audit trail of who has agreed to what — all in one place.
Related guides
Roll out and enforce the policy effectively
Related templates
Strengthen your ethics and governance framework
Code of conduct policy
The overarching behavioural standards a COI policy supports.
View templateGifts & benefits policy
Set rules for accepting gifts, hospitality and favours.
View templateEthical conduct policy
Define the ethical standards expected across the business.
View templateBehaviour management policy
Set expectations for workplace behaviour and how managers address conduct issues.
View templateWorkplace relationships policy
Set clear rules for personal relationships between colleagues.
View templateConflict of interest policy FAQ
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A conflict of interest policy is a document that requires employees and board members to disclose any personal or financial interests that could clash with their professional duties, and sets out how those conflicts are managed or eliminated. It protects the organisation by keeping decision-making ethical and transparent.
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Yes. Tailor the examples of conflicts to your sector — a charity, a tech company and a healthcare provider each face different scenarios. If you’re a charity or non-profit, align the policy with the ACNC governance standards; public-sector bodies should reference their integrity framework.
Before you download
General information only — not legal advice
This document is a general HR template provided for informational purposes only. It is not legal advice and may not reflect the latest changes in legislation or apply to every workplace situation. RosterElf Pty Ltd and the template provider accept no liability for any loss arising from reliance on this document. Users should seek independent legal advice and customise the template to ensure it complies with all relevant laws, awards and workplace requirements.