Policy Corporate Governance Declaration of Interest-Senior Management and Specified Staff Procedure

Declaration of Interest-Senior Management and Specified Staff Procedure

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The intent of this Procedure is to ensure that the Vice Chancellor is aware of any private interests or relationships of staff in senior leadership positions or other sensitive positions which could influence, or could be perceived to influence decisions staff are taking or advice they are giving. This procedure identifies who at JCU is required to provide a Declaration of Interest and how they will be managed.

This Procedure gives effect to the principles in the University’s Staff Code of Conduct.

This Procedure addresses HESF Standards 5.2: Academic and Research Integrity, and 6.2: Corporate Monitoring and Accountability.


The procedure applies to all members of staff and affiliates of the University at all times while engaged in University business or otherwise representing the University.


Except as otherwise specified in this Procedure, the Conflict of Interest Policy or the Staff Code of Conduct, the meaning of terms used are as per the Policy Glossary.

Senior Management

All Deans, Directors and Deputy Vice Chancellors, and the Vice Chancellor.

Specified staff

Those staff who are not identified as Senior Management but whose roles may require transparency about private and financial interests given the nature or the sensitivity or susceptibility of the work to fraud and corruption or where authority and delegations may present public interest concerns.


1. Purpose of the declaration

1.1  The purpose of the declaration of interest is to ensure that the University is aware of any interests that could be seen to influence decisions making by Senior Management and Specified Staff of the University. These interests include personal interests and relationships that could involve real, perceived or potential conflicts of interest in terms of the staff member’s duties and responsibilities.

1.2  The completion of a declaration of interests also provides Senior Management and Specified Staff with the opportunity to consider whether any of their financial or personal interests might give rise to a real, perceived or potential conflict with their duties and take action to remove or minimise the potential for that to occur.

2. Staff required to make a declaration

2.1 Because of their leadership and decision-making roles, all Senior Management, including those staff acting in those roles for longer than three months, are required to complete a declaration of interest under this Procedure.

2.2  Non-Senior Management staff whose responsibilities also require them to be particularly transparent about their private financial and personal interests are also required to complete a declaration of interest under this Procedure.

2.3  The extent to which this Procedure is applied to non-Senior Management staff will depend on:

2.3.1 assessments of the sensitivity or susceptibility of their work to fraud and corruption or where their authority and delegations may be subject to public interest or foreign interference concerns;

2.3.2 the administrative and resource implications and the risks involved, remembering that all staff are required to identify and manage conflicts of interest, irrespective of whether they are required to make a declaration.

2.4  It is the responsibility of the Vice Chancellor to determine those non-Senior Management staff who are identified under this Procedure as Specified Staff.

2.5  Specified staff captured by this Procedure are:

2.5.1 Deputy Director and Head, Planning and Development, Estate Directorate;

2.5.2 Deputy Chief Financial Officer; and

2.5.3 Manager, Strategic Procure-to-Pay, Financial and Business Services.

2.5.4 Relevant staff identified in foreign arrangements notified under Australia’s Foreign Relations (State and Territory Arrangements) Act 2020 and in accordance with the Foreign Arrangements Notification Procedure.

2.6  Other staff may be identified from time to time depending on the particular roles and responsibilities of the staff member and JCU’s probity concerns. Example situations where transparency and openness about private and personal financial interests are particularly important include:

2.6.1 positions undertaking an investigatory or regulatory role;

2.6.2 positions that allocate contracts or disperse Government funds;

2.6.3 positions that are responsible for the protection and management of sensitive commercial or personal information.

2.6.4 positions engaged in research or other collaborations with foreign entities or as part of the Defence Industry Security Program (DISP).

2.7 These Declarations using the template at Appendix 1 are to be made within 10 working days of starting employment at JCU or when identified as Specified Staff, and registered with the Chief of Staff.

3. Types of interests and relationships that need to be disclosed

3.1  Types of interests that may need to be declared include:

3.1.1 real estate investments;

3.1.2 shareholdings;

3.1.3 trusts or nominee companies;

3.1.4 company directorships or partnerships;

3.1.5 financial or private affiliation, partnership or engagement with a foreign government, political organisation, agency, university or individual;

3.1.6 significant liabilities;

3.1.7 gifts (see the Reportable Gifts and Benefits Procedure);

3.1.8 paid, unpaid or voluntary outside employment that could or could be seen to impact upon the staff member’s responsibilities with JCU (see the Staff External Professional Activities and Outside Employment Procedure).

3.1.9 association or affiliation, partnership, membership or any financial (cash or in-kind) support for education and research with a foreign government, political organisation, military, policing or intelligence agency.

3.2 Ownership of personal assets such as a personal or family home, works of art, jewellery, furniture, antiques etc., are unlikely to have any real or perceived impact on staff member’s responsibilities and would not normally need to be declared, since their possession is unlikely to involve a conflict of interest or any other threat to the staff member’s probity, except in the case of people working in these fields.

4. Annual Review and Change in Circumstances

4.1 The Declarations are reviewed annually in January as coordinated by the Chief of Staff.

4.2 Staff who have made a Declaration but have a change in circumstance during the year must make additional disclosure to the Chief of Staff within 10 days of the change.

Privacy and Confidentiality

4.1  Information arising from Declarations will be managed in accordance with the Information Privacy Policy.

4.2  Information held may be used for University purposes including audit, reporting, compliance monitoring and other purposes required by Government or legislation.


Appendix 1 – Declaration of Interests Form – Senior Management and Specified Staff

Related documents and legislation

Conflict of Interest Policy

Conflict of Interest Procedure

Reportable Gifts and Benefits Procedure

Staff External Professional Activities and Outside Employment Procedure

Staff Code of Conduct

Code of Conduct - University Council

Conflict of Interests – University Council

Risk Management Policy

Risk Management Framework

Information Privacy Policy

Public Interest Disclosure Procedure

JCU Code for the Responsible Conduct of Research

Disclosure of Interest and Management of Conflicts of Interest Procedure

Guidelines to Counter Foreign Inference in the Australian University Sector 2021

Managing Conflicts in the Public Sector Guidelines

Crime and Corruption Act 2001

Public Interest Disclosure Act 2010

Public Sector Ethics Act 1994

Foreign Influence Transparency Scheme Act 2018


NOTE: Printed copies of this procedure are uncontrolled, and currency can only be assured at the time of printing.

Approval Details

Policy DomainCorporate Governance
Policy Sub-domainCulture

Policy Custodian

Vice Chancellor

Approval Authority


Date for next Major Review


Revision History


Approval date

Implementation date



23-105/05/202311/05/2023Amended to reflect the updated guidelines to counter foreign interferenceChief of Staff




Procedure established to support the Conflict of Interest Policy and give effect to the Staff Code of Conduct. Approved by Vice Chancellor.

Chief of Staff


Conflict of Interest, conflict of commitment; actual; perceived; potential

Contact person

Chief of Staff