1. The purpose of our procedure
This procedure supports the Conflicts of Interest Policy by outlining how Adelaide University identifies, declares, manages and records actual, potential and perceived conflicts of interest, including those that may arise from gifts, benefits and hospitality.
It ensures that conflicts are addressed transparently and consistently, safeguarding Adelaide University’s integrity, decision-making and reputation.
Please read this procedure in conjunction with the Conflicts of Interest Policy, [Financial Conflict of Interest in the US PHS Funded Research Procedure] and the Relationships with Students Procedure.
2. Who our procedure applies to
This procedure applies to the following members of the Adelaide University community:
- members of Council and its committees
- employees (academic, professional, fixed-term, casual, sessional and titleholders)
- volunteers, adjuncts, conjoint, honorary and visiting academics
- contractors, consultants and agency staff engaged by or representing Adelaide University
- graduate research students
- coursework students engaged in research activities
- students appointed as Senior Residents
- directors, officeholders, and staff of controlled entities, and
- any other person appointed or engaged under an agreement to perform work for, or on behalf of, Adelaide University.
All individuals covered by this procedure are collectively referred to as University personnel.
This procedure authorises the Director, Governance Services to maintain associated protocols.
3. Our conflicts of interest procedure
3.0 Identifying conflicts of interest and conflicts of duty
A conflict of interest arises when a private interest has the potential to influence, or be perceived to influence, the impartial and objective performance of the individual’s Adelaide University duties. A conflict of duty arises when there is a conflict between an individual’s Adelaide University duties and the individual’s duty to another organisation or group. Conflicts may be actual, potential or perceived.
Examples of situations where conflicts of interests or conflicts of duty may arise include but are not limited to:
- financial interests such as investments, ownership, or secondary employment with an external organisation that has, or is seeking to have, dealings with Adelaide University
- personal or family relationships, for example recruiting, managing, or making employment decisions about a relative, friend or close associate; or teaching, supervising, assessing, moderating, invigilating or making other academic or administrative decisions about a student who is a relative, friend or close associate
- external roles, including board membership, advisory positions, directorships, or consultancy work that may compromise, or be perceived to compromise, a person’s Adelaide University duties research and intellectual property interests, such as research funding, collaborations, patents, publications, or commercialisation arrangements that may create a conflict of duty or result in personal gain
- procurement and contracting, such as involvement in supplier selection, tender evaluation, or contract management where there is a financial or nonfinancial interest in a current or potential supplier
- offers or receipt of a gift, benefit or hospitality that could reasonably be seen to influence decision-making or create a sense of obligation
- foreign relationships or affiliations, such as positions, funding, or collaborations with a foreign government, organisation, or entity, whether held personally or through a close associate, which must be disclosed and managed in accordance with this procedure and the [Foreign Compliance Policy] to safeguard against foreign interference risks.
3.0.1 Personal relationships
Private interests held by a close associate may also give rise to a conflict if they could influence, or could reasonably be seen to influence, the decisions taken or advice given by University personnel when fulfilling their duties. For the avoidance of doubt, any existing or previous intimate relationship between University personnel and a student for whom they have, or may be perceived to have, a professional responsibility, constitutes a conflict of interest that must be declared and managed as set out in the Relationships with Students Procedure. Students appointed as Senior Residents must declare any existing or previous intimate relationship with a student who is a resident of the accommodation service in which they are appointed.
3.1 Declaring conflicts of interest or conflicts of duty
3.1.1 When to declare
Personal interests that may give rise to a conflict of interest or conflict of duty must be declared:
- upon commencement of employment or engagement with Adelaide University
- before participating in certain activities such as recruitment, procurement or meetings of decision-making bodies
- when required by a research funder, and
- as soon as reasonably practicable when an interest that may give rise to a conflict is identified or a change to a previously declared conflict arises.
Members of Council and its committees, and other University personnel in decision-making roles, are required to declare or reconfirm their declarations of personal interest, including nil returns, annually. If uncertain, the interest should be disclosed. Early and open disclosure protects both the individual and Adelaide University. How to declare Declarations must be made using the [Declaration of Interest Form]. Verbal declarations at meetings of decision-making bodies, or as part of recruitment or procurement processes, must be made at the start of the meeting and recorded in the minutes.
3.2 Assessing and managing conflicts of interest
3.2.1 Assessing and managing interests via the Declaration of Interests Form
Upon receiving a completed Declaration of Interest Form, the relevant line manager, or in the case of a Council or committee member, the Director Governance Services (or nominee), assesses the declared interest and determines whether an actual, potential or perceived conflict of interest of conflict or duty exists. Where an actual, potential or perceived conflict of interest or conflict of duty has been identified, a conflict management plan must be developed to resolve or manage the conflict.
A conflict management plan includes:
- a description of the nature of the interest and how it does, may or may be perceived to influence the individual’s University duties
- details of the management strategies to mitigate the risk that the interest does, may, or may be perceived to, influence the individual in performing their duties.
The conflict management plan may include one or more of the following strategies:
- Registration – recording the conflict to maintain transparency and ensure the adequacy of the management plan.
- Restriction - limiting involvement in the activity or decision, such as withdrawing from discussions or decision-making or restricting access to information.
- Oversight – appointing a supervisor or impartial third party to oversee the activity affected by the conflict.
- Removal – removing the individual from involvement in the matter.
- Relinquishment - giving up the private interest or external role that is causing the conflict.
- Resignation – used only as a last resort where no other strategy is viable to manage the conflict.
Conflict management plans must be endorsed by:
- Council, where the plan is for a Council or committee members, or the Vice Chancellor, or
- the Vice Chancellor, where the plan is for a Deputy Vice Chancellor, or
- the relevant Deputy Vice-Chancellor, where the plan is for an Executive Director or Dean of School, or
- the relevant Executive Director or Dean of School for all other conflict management plans.
Declaration of interest forms and any associated endorsed conflict management plans are recorded in the central register, maintained by the Director, Governance Services.
3.2.2 Assessing and managing interests declared in meetings and panels
When an interest is declared at a meeting of a decision-making body, or as part of a recruitment or procurement process, the Chair must determine how the interest will be managed.
The Chair may determine that declaration of the interest is sufficient and no further action is required, or that one or more of the management strategies outlined above should be applied.
The assessment and management approach must be recorded in the meeting minutes and the central register of interests.
3.2.3 External disclosures
Where required by a research funder, Research Services must ensure that the declared conflict of interest and any associated management plan are reported to the funder in accordance with the funding agreement or applicable guidelines.
3.3 Gifts, benefits and hospitality
3.3.1 Accepting offers
A token offer may be accepted if it does not meet any of the requirements for refusing offers set out in section 3.3.2 below.
A non-token offer may be accepted if:
- it is for a legitimate business reason, offered in the course of the individual’s Adelaide University duties
- it does not meet any of the requirements for refusing offers set out in section 3.3.2 below
- acceptance is approved by the relevant line manager within their financial delegation, or where the gift is to a Council or committee member, by the Director, Governance Services, and
- it is declared and recorded in the central register of interests.
3.3.2 Refusing offers
Offers of gifts, benefits or hospitality must not be accepted if:
- the offer is a non-token offer that is not for a legitimate business reason
- the offer is money, something used in a similar way to money, or something easily converted to money
- acceptance could lead to an actual, potential or perceived conflict of interest, including offers from a person or organisation about which the individual receiving the offer is likely to make or influence a business decision
- acceptance could bring Adelaide University into disrepute
- the offer is likely to be a bribe or inducement to make decision or act in a certain way, in which case the offer must be reported to the Director, Governance Services, or
- the offer extends to the receivers’ close associates.
Any non-token offer that is refused under this section must be recorded in the central register of interests.
Any offer that is likely to be a bribe or inducement must also be reported under the [Fraud and Corruption Policy].
3.4 Training, awareness and culture
All new University personnel must complete any required induction training, including modules related to integrity and corruption. Refresher training is required at least every two years.
The Deputy Vice Chancellor People and Culture (or nominee) is responsible for ensuring training is provided for individuals receiving declarations of interest and endorsing conflict management plans.
3.5 Record keeping and privacy
All declarations and conflict management plans are recorded in Adelaide University’s central register of interests, maintained by the Director, Governance Services, and managed in accordance with the [Records Management Procedure] and [Privacy Policy].
Access to the central register of interests is restricted to authorised staff. Statistical and de-identified reporting may be used for compliance monitoring.
3.6 Monitoring and review
Conflict management plans are reviewed annually alongside the annual declaration or reconfirmation of interests process, or earlier if circumstances change.
The Director, Governance Services conducts periodic reviews of declarations of interest and compliance with conflict management plans and provides oversight reporting to the Audit and Risk Committee.
3.7 Breaches of this procedure
Failure to disclose or manage a conflict of interest, or to handle an offer of a gift, benefit or hospitality in breach of this procedure, may constitute misconduct or serious misconduct.
Breaches are managed in accordance with the [Staff Misconduct Procedure], relevant industrial instruments or Enterprise Agreement, or terms of appointment or contract, as applicable.
4. Who holds a responsibility within this procedure
Refer to the Delegation Policy for all delegations at Adelaide University.
4.0 Council is required to
- call for declarations of interest at the beginning of every meeting
- endorse conflict management plans for members of Council and its committees, the Vice Chancellor, and Deputy Vice Chancellors, and
- ensure declared conflicts of interest and conflicts of duty are managed and recorded in accordance with this procedure.
4.1 Council committees and other decision-making bodies or panel Chairs are required to:
- call for declarations of interest at the beginning of every meeting
- ensure declared conflicts of interest and conflicts of duty are managed and recorded in accordance with this procedure.
4.2 The Vice Chancellor is required to:
- endorse conflict management plans of Deputy Vice Chancellors.
4.3 Deputy Vice Chancellors are required to:
- endorse conflict management plans of Executive Directors/Deans of School.
4.4 Executive Directors/Deans of School are required to:
- endorse conflict management plans for University personnel within their area of responsibility.
4.5 Line Managers are required to:
- receive disclosures of interests
- following a disclosure, determine whether a conflict of interest or a conflict of duty exists
- develop and monitor conflict management plans for endorsement by the relevant endorser
- approve or decline non-token offers, and
- escalate complex conflict of interest or conflict of duty cases to the [Director, Governance Services].
4.6 The Director, Governance Services is required to:
- maintain Adelaide University’s central register of interests
- receive disclosures of interests from Council and committee members
- approve acceptance of a non-token offer to a Council or committee member
- Receive reports of bribes to record in the central register and ensure reports are also escalated in accordance with the [Fraud and Corruption Policy]
- conduct periodic reviews of declarations of interest and compliance with conflict management plans and provide oversight reporting to the Audit and Risk Committee.
4.7 The Deputy Vice Chancellor People and Culture (or nominee) is required to:
- ensure conflicts of interest and conflicts of duty disclosure processes (including offers of gifts, benefits and hospitality) are integrated into recruitment, induction and performance review processes
- ensure integrity and corruption training is incorporated into induction and a structured refresher cycle,
- ensure staff who receive disclosures of interest and/or endorse conflict management plans receive training.
4.8 University personnel are required to:
- identify and disclose personal interests that may give rise to an actual, potential or perceived conflicts of interest or conflicts of duty
- respond to and disclose offers of gifts, benefits and hospitality in accordance with this procedure
- cooperate in developing and implementing conflict management plans where a conflict of interest or a conflict of duty is determined, and
- complete any required training, including refresher training.
5. Definitions used in our procedure
Please refer to our Adelaide University glossary for a full list of our definitions.
Adelaide University community means a broad range of stakeholders who engage with Adelaide University and includes (but is not limited to) all students, staff, and non-staff members of Adelaide University including alumni, honorary titleholders, adjuncts, visiting academics, guest lecturers, volunteers, suppliers and partners who are engaging with and contributing to the work of Adelaide University.
Close associates mean a spouse, family member, friend, colleague, business, group, club or other association of University personnel.
Conflict of duty means a conflict between an individual’s Adelaide University duties and the individual’s duty to another organisation or group.
Conflicts of interest means an individual has a private interest that could influence, or could reasonably be seen to influence, how the individual performs their Adelaide University duties. A conflict can be:
- actual – there is a conflict between the individual’s private interests and their Adelaide University duties
- potential – an individual has a private interest that could foreseeably conflict with their Adelaide University duties in the future
- perceived – it is reasonable for people to believe that an individual’s private interests could influence their Adelaide University duties, now or in the future.
Controlled entity means a person, group of persons or body corporate over which Adelaide University has control.
Legitimate business reason means it furthers the conduct of official Adelaide University business.
Non-token offer means a gift, benefit or hospitality that is, or may be perceived to be by the recipient, the person making the offer, or by the public, of more than inconsequential value. All offers of a gift, benefit or hospitality that are worth more than $100 are non-token offers and are therefore declarable.
Private interest means a financial or non-financial interest, whether direct or indirect. It can be direct where it relates to the individual’s own interests, or it can be indirect where it relates to the interests of another person or group that is or has recently been closely associated with the individual or the individual has an ongoing interest in.
Titleholder means any person upon whom Adelaide University has conferred an honorary academic title.
Token offer means a gift, benefit or hospitality with a value of $100 or less that is of inconsequential or trivial value to both the person making the offer and the recipient.
6. How our procedure is governed
This procedure is categorised, approved and owned in line with the governance structure of Adelaide University and the offices and officers listed below.
| Parent policy | Conflicts of Interest Policy |
|---|---|
| Policy category | Council |
| Policy owner | Vice Chancellor and President |
| Procedure owner | Director, Governance Services |
| Procedure category | Corporate |
| Approving authority | Co-Vice Chancellors/Vice Chancellor and President |
| Responsible officer | Director, Governance Services |
| Effective from | 1 January 2026 |
| Review date | 1 year from the Effective date |
| Enquiries | Interim Central Policy Unit |
| Replaced documents | None |
7. Legislation and other documents related to our procedure
Refer to the Delegation Policy for all delegations at Adelaide University.
| Category | Documents |
|---|---|
| Related policy documents | Delegation Policy Delegation Procedure [Fraud and Corruption Policy] [Financial Conflict of Interest in the US PHS Funded Research Procedure] [Staff Code of Conduct] [Staff Misconduct Procedure] Relationships with Students Procedure [Public Interest Disclosure Procedure] [Records Management Procedure] Privacy Policy |
| Referenced legislation | Adelaide University Act 2023 |
| Related legislation | Corporations Act 2001 (Cth) |
8. History of changes
| Date approved | To section/clauses | Description of change |
|---|---|---|
| 19 December 2025 | N/A | New procedure |
At the time of writing, Adelaide University’s organisational structure, position titles, and committee names have not been confirmed. Square brackets [ ] indicate placeholders for these details. Brackets are also used to identify policy elements that are subject to further decision-making or confirmation. These will be updated once final decisions are made.