Policy Declaration of Interest-Senior Management and Specified Staff Procedure

Declaration of Interest-Senior Management and Specified Staff Procedure

Print Friendly and PDFPrint Friendly


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 or could be seen to influence the decisions the staff are taking or the advice they are giving.

Conflicts of Interest occur where staff with a particular interest could be influenced, or might appear to be influenced, in the performance of their duties. This procedure outlines 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 such as integrity, impartiality, accountability and transparency.


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, Pro Vice Chancellors and Deputy Vice Chancellors, Provost and Vice Chancellor (ie, Band 5 and above of the HR Delegations Register).

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

1.2  The completion of a declaration of interests also provides Senior Management with the opportunity to consider whether any of their financial or personal interests might give rise to a real or perceived 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 acting in those roles for longer than three months, are covered by the Declaration of interest Procedure.

2.2  These Declarations using the template at Appendix 1 are to be made within 10 working days of starting employment at JCU, and registered with the Chief of Staff.

2.3  Non-Senior Management staff whose responsibilities also require them to be particularly transparent about their private financial and personal interests are also captured by this Procedure.

2.4  The extent to which the Procedure is applied to non-Senior Management staff will depend on assessments of the sensitivity or susceptibility of the work to fraud and corruption or where their authority and delegations may be subject to public interest concerns, 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.

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

2.6  Specified staff captured by this Procedure are:

2.6.1 Deputy Director Planning and Development, Estate Directorate;

2.6.2 Deputy Director, Financial and Business Services; and

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

2.7  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:

2.7.1 positions undertaking an investigatory or regulatory role;

2.7.2 positions that allocate contracts or disperse Government funds;

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

3. Types of interests and relationships that may 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 Secondary Employment Procedure).

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. 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

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


Approval Details

Policy Sponsor/s

DVC Services and Resources

Approval Authority

DVC Services and Resources

Date for next review


Revision History


Approval date

Implementation date






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