Managing Conflicts of Interest Policy

Applicable to: This Policy is applicable to all WA health system entities, as defined in this Policy.

Description: To ensure a consistent approach to integrity governance and risks associated with conflicts of interest across the WA health system, and to ensure effective governance of conflicts of interest including monitoring, evaluation and reporting. The Managing Conflicts of Interest Policy specifies the principles and minimum requirements with which WA health system entities must comply.

In line with the Public Sector Code of Ethics and MP 0124/19 Code of Conduct PolicyDepartment of Health employees and Health Service Provider staff members are required to act with honesty and integrity and must:

  • avoid situations which may give rise to conflicts of interest
  • immediately declare any conflicts of interest or possible perception of conflicts of interest, including the disclosure of personal or professional matters that may lead to actual or perceived conflicts of interest.

Conflicts of interest arise when a Department of Health employee or a Health Service Provider staff member's official duty is directly affected or impacted by their personal or private interests.  Actual, perceived and potential conflicts of interest are not inherently unethical or wrong, however they must be declared and managed. 

Failure to declare conflicts of interest creates a risk that may undermine the public’s trust and confidence in the WA health system and may:

  • cause financial harm and loss
  • damage the culture within the WA health system
  • cause loss of confidence in the impartiality and honesty of Department of Health employees and Health Service Provider staff members
  • present opportunities for misconduct, fraud or corruption.

This Policy is a mandatory requirement under the Integrity Policy Framework pursuant to section 26(2)(l) and section 19(1A) of the Health Services Act 2016.

This Policy is also a mandatory requirement for the Department of Health pursuant to section 29 of the Public Sector Management Act 1994.

This Policy supersedes MP 0113/19 Managing Conflicts of Interest Policy and Department of Health Managing Conflict of Interest Policy and Guidelines.

Date of effect: 11 June 2020

Policy Framework

Supporting information