Declarations of Interest
The University’s approach to managing personal interests which may give rise to an actual, perceived or potential conflict, has changed.
Monash acknowledges that its staff and associated workforces engage in a wide variety of external activities and considers that these are in the public interest and of benefit to the University and to the individuals involved. It is also recognised that external interests may give rise to conflicts of interest, which require active management to protect the transparency, integrity and impartiality of the individual and the University.
Monash has adopted a declaration approach underpinned by policy and procedure, which streamlines and creates a central register of conflict of interests associated with personal interest across the following categories;
- Foreign Affiliations and Association (embedded throughout the below categories)
- Commercial and Financial Interests
- Procurement
- Paid Outside Work /External Engagements
- Research and Commercialisation
- Competing Professional Interests
- Recruitment, Supervision & Teaching
- Gifts, Benefits and Hospitality.
By declaring interests regularly and identifying any conflict of interest early, it is possible to:
- Protect individuals and the University from actual, perceived or potential bias, impartiality or interference; and
- Manage conflict of interest more efficiently, transparently, accountable and timely.
An undisclosed interest or unmanaged conflict of interest can undermine the reputation of individuals and public confidence in the organisation, which is critical for our professional, education and research activity.
Please see the Declaration of Interest (DOI) Procedure for more information.
All staff and associated workforces are required to declare personal interests annually to identify and manage conflicts of interest.
Heads of Organisational Units must also actively manage conflicts of interest that are disclosed to them
To help you meet your responsibilities, you must:
- submit a declaration each year – even if you think you don't have a conflict, you're required to answer the questions regarding personal interest annually.
- manage any identified conflicts of interest - you will be requested to develop a management plan for interests that give rise to actual, perceived or potential conflict.
- update your declaration of interest when a new conflict of interest arises - even if you have already submitted a declaration for the calendar year.
Understanding Conflict of Interest
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A conflict of interest occurs when a staff member's private interest competes with their professional obligation to Monash and could (actually, potentially or be perceived to) improperly influence how they perform their official University duties.
Having a Conflict of Interest is common, and is not necessarily negative or adverse in employment, provided it is declared and managed appropriately. A conflict of interest may be described as:
- Potential - Where private interests are not, but could come into, conflict with your University work activity
- Perceived - Wher it appears, or could be perceived that your private interests do or would improperly influence the performance of your University work activity
- Actual - Where a direct conflict exists between your current official University duties and existing private interests.
The Conflict of Interest Examples and Action Guidelines set out a range of activities and how the University views these in relation to conflict of interest as categorised below:
- activities which are normally or ordinarily permissible;
- activities that appear to present potential conflicts of interest or commitment; and
- activities that clearly present such serious problems/issues as to be incompatible with University policies.
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After completing your Declaration of Interest Form, you will be requested to submit a Management Plan for each interest disclosed where a conflict of interest is identified.
A Management plan's purpose is to accurately describe the conflict in writing, create explicit agreements to protect against conflicts impacting the performance of your duties, and facilitate oversight of such matters.
A robust management plan should include (to any extent not described in the DOI form submission):
- the nature of your personal interest;
- the interests of the University with which your personal interest conflicts, has the potential to conflict or may be perceived as conflicting;
- the likelihood of the interests conflicting;
- an outline of risk mitigation strategies to be implemented; and
- any recommended measures to be taken.
Strategies to manage conflicts of interest may include:
Strategy Example Agreement to disclose the details of the conflict of interest in relevant circumstances. Disclosing at the commencement of meetings where your conflict of interest may be perceived to influence any decisions made (minimum management) Restricting your involvement or actions in the situation that is leading to the conflict of interest Excusing yourself from meetings during discussion of related agenda items. Removing yourself entirely from any activity associated with the conflict of interest. Withdrawing from committees where your conflict of interest can not be mitigated. Engaging a third party to oversee part or all of the process that is impacted by the conflict of interest. Delegating specific decisions to an independent colleague or supervisor. Relinquishment of the private interest that is creating the conflict. Discontinuing your external activity or commitment. -
The world-class performance and reputation of Monash is intrinsically linked to the globally engaged and open nature of our universities, and the majority of University international interactions are positive and beneficial to the University and Australia more broadly.
However, there are those who seek to interfere in the university sector. This can manifest itself as seeking to inappropriately influence course content, research directions, or student and staff actions. University staff may be vulnerable to such efforts through the nature of their work.
In accordance with the Guidelines to Counter Foreign Interference In the Australian University Sector, Monash asks its staff, through the declaration of interest process, to declare and monitor key interests which could pose a risk, including identification of foreign affiliations, relationships and financial interests. This includes:
Commercial & Financial Interests
- Are you receiving any financial support (cash or in-kind) for education or research-related activities from a country other than Australia?
Outside Work and External Engagement
- Do you hold any position (paid or unpaid) or honorific titles in any foreign university, academic organisation or company, or are you under any other obligations to a foreign university, academic organisation or company? (e.g. membership of a talent recruitment program)
- Do you have any association or affiliation with a foreign government or foreign military, policing or intelligence organisation?
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Foreign Affiliations & Associations that present a risk of foreign interference or potential risk should be treated as a conflict of interest. This means, when requested, you should submit a suitable management plan (as above) which outlines appropriate risk management and mitigation to protect both your own interest and the interests of the University.
Things to consider;
- Consider the entity (organisation, individual or group)
- Consider technology and research sensitivity
- Consider commercial, financial or IP conflicts
- Consider the actual, potential or perception in regards to corruption, bribery or undue influence.
Head of Unit Guidance
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Through an online workflow system (UniCRM) The Head of the Organisational Unit (HoU) is responsible for the following;
- Assessing & Reviewing Declaration of Interest Submissions
“Would a reasonable, disinterested observer think that an individual’s personal interests conflict, or appear to conflict, or could conflict in the future, with the individual’s duty to act in the University’s best interests?”
- Reviewing and endorsing management plans
“Would a reasonable, disinterested observer think that the management plan appropriately mitigates, overcomes, or removes any actual, potential or perceived conflict, and be satisfied that duties for the University are performed in a manner that is impartial and free from bias or personal benefit?”
- Create and promote a culture of disclosure.
Ensure all staff in your organisation unit complete the Declaration of Interest and promote regular updates when conflicts arise. Ensure new starts are directed to Declare. Follow up on non-disclosure.
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The HoU is responsible for DOI submission review and management; however, at their discretion, they may seek input and advice from the Dean/Portfolio Head/Executive Director by escalating in the system. (No automated workflow)
For complex conflicts that cross multiple categories and involve more senior staff or higher risk profiles, subject matter experts are available to review and guide appropriate management plans through the communication option in the system.
Inbuilt system allocation based on pre-determined risks will assist in reducing workflow by;
- automatically closing declarations with no interest for review
- automatically closing interests that do not give rise to conflict (where this is possible to assess based on pre-determined system filters).
- application of system filters for foreign affiliations as associations
The University’s Declaration Officer will confirm all endorsed plans.
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To aid in assessment of risk, the in-system Foreign Affiliation and Association ‘Management Plan Trigger’ will only apply to pre-identified countries which the University has assessed as presenting a higher risk of foreign interference or corruption. Monash has used a combination of three relevant indices to develop a list of ‘Countries of Interest’ as below;
- Corruption Perception Index (Below 50)
- Academic Freedom Index (Any D or E status)
- Global Freedom Index (Not Free and Partly Free)
These indices highlight countries in which liberal democratic values are not reflected in governance to the extent that they are in Australia. Interests in these countries require review.
Flagging these associations and affiliations does not necessarily preclude or limit the maintenance of the relevant interest. However, you should ensure that you understand the nature of the interest in education or research-related activities in any of these countries and treat any foreign interference or undue influence risk like a conflict of interest.
Note that management of foreign affiliations and associations may also overlap conflict of interest management associated with outside work, commercial or financial interests.
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Assess the Entity (Organisation, Individual or Group)
- Do you and your staff member, to the extent that is reasonable and consistent with the level of risk, consider the entity is being upfront and transparent in its dealings?
- Is the entity upfront and transparent about affiliations and, if relevant, ownership/subsidiary status, parent partners and intent? These may include existing vendor relationships, sourcing partners and stakeholders with an interest in the primary entity.
- Have foreign partners expressed a concerning level of interest in obtaining the details of research/education activity?
- Have foreign entities offered to purchase or invest in research? If so, from whom and what were the terms of the offer? Does it look too good to be true?
Assess technology and research
- Is your research strategic/novel/ground-breaking or could it otherwise fill in an important piece of the puzzle for a competitor?
- Does the foreign affiliation include sensitive technology and research? Consider the Federal Government’s critical technologies list.
- Does your research have multiple uses? Can you imagine a scenario in which your research could be used for malicious purposes regardless of intended use?
Risk assessment and mitigation strategies
Considerations for managing risk related to foreign affiliations might include;
- Do the benefits of the activity outweigh the risks?
- What elements of the activity need to be adjusted to mitigate risk (if any)?
- Are researchers and their international partners aware of their legal obligations, including declaring and managing conflicts of interest?
- Are there potential reputational or ethical risks to Monash associated with the collaboration or activity disclosed?
- What access will the partner have to Monash IT networks? If they do have access, does this pose an additional risk?
- Is there any physical separation or protection required to safeguard the research?
- Who is responsible for maintaining and applying risk mitigation?
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Considerations around commercialisation might include:
- Ownership arrangements for any intellectual property (IP) that is generated
- How existing IP, research data, confidential or personally identifiable data is protected
- identification and protection of commercially valuable research or research that may benefit Australia’s economic interest
- university IP policies and procedures.
- Issues that may arise include personal financial gain from the use of university research, which assists outside organisations by providing inappropriate access to university IP.
- How the staff member's resources are used, when the work overlaps with their duties for the University
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Staff must declare Gifts, Benefits & Hospitality in accordance with the University's Procedure. If staff forget to declare within 20 days, they may disclose acceptance or declination of a gift, benefit or hospitality as part of their Declaration of Interest.
- Staff must not accept a gift that gives rise to a conflict of interest
- Such a conflict cannot be managed, as such a plan should not be requested
- If a gift is declined, then no management plan is required, and the case can be closed in the system.
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Conflict of Commitment is an often overlooked element of managing personal interests. Commercial and Financial Interests and Outside Work and External Engagements may give rise to a conflict of commitment (time, duration), which impacts the ability of the individual to undertake agreed work for the University. Key considerations include;
- Is the commitment manageable alongside contract obligations? (work-life balance, over-commitment)
- Can the staff member use contracted Univesity time, and resources to work on outside interests, and how will this be managed?
- Does the management plan prioritise University Obligations
- Are changes to University Obligations necessary, and are these operationally viable?
System User Guides
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Need an overview of UniCRM and how to navigate workflows for conflict of interest?
- Declaration of Interest - System User Guide [online guide]
- Declaration of Interest - System User Guide [PDF]
For Content enquiries please contact the University's Declaration Officer.
Help and Support
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If you require further support on the Declaration of Interest process, please seek advice from your Supervisor, Dean or Head of School/Unit.
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If you have a general question about the procedure or completing the form, please contact Access HR on +61 3 990 20400 or hr@monash.edu.
If you have a specific question about your personal circumstances, please contact the Monash Declarations Officer at declarationsofficer@monash.edu.
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Contact the Monash Declarations Officer at declarationsofficer@monash.edu for support and guidance in managing Declarations of interest, system support or specialist queries.
If you or your work unit would like to coordinate additional support or information about this process, please contact your HR Business Partner, who can coordinate a time for the Declarations Officer to drop into existing team meetings.
Frequently Asked Questions (FAQs)
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Staff and Associates
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From 2023 it is a requirement under the Declaration of Interest Procedure for all staff and associated workforces to disclose personal interests and manage any arising conflicts which have, may be perceived to or potentially could have a bearing on you meeting the obligations of your role impartially and without bias. It is an important measure to ensure transparency and integrity of individuals and the University in accordance with the University's Staff Code of Conduct.
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You must use the form to declare all personal interests that may influence, or may be perceived to influence, your performance in the position for which you have been engaged, on;
- an annual basis as directed by the University, and/or:
- at any other time where you identify a new material personal interest;
- and/or within 30 days of any change in circumstances.
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Declaration of Interest forms are submitted to the Head of the Organisation Unit and may be shared with the relevant Dean/Portfolio Head/Executive Director or subject matter expert as required to ensure appropriate management of any identified conflict.
If your declaration does not give rise to conflict or requires review for conflict, it will automatically be recorded without needing further review.
Declarations and management plans will be stored on a central register (held by the Chief People Officer and their delegate the Declarations Officer), who will confirm all endorsed plans.
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The form will guide you through the required information associated with each category.
You should be transparent, honest, accountable and proactive in declaring and managing your interests and associated conflicts.Your declaration may be reviewed by your Head of Unit, Dean/Portfolio Head/Executive Director and/or subject matter experts of the relevant category.
It is important for these reviewers to understand the nature of the interest, the likelihood of the risk occurring and the consequences if the risk materialised, and key management actions to mitigate the conflict.
If you do not provide sufficient information in your declaration, you will be contacted for further information.
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Depending on the nature of your interests, the form is expected to take between two and 30 minutes to complete.
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You can update your interests by reaccessing the Declaration of Interest form and adding or editing previous entries. Please note due to the adoption of feedback, resubmission is not available to those who undertook the 2022 pilot/test process.
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Close personal relationships should be disclosed, and it should be noted if there are any teaching, supervision or recruitment activities that could be perceived to be influenced by the close personal relationship. Depending on the situation, we may require a management plan to mitigate the risk of a conflict of interest occurring in activities that may be perceived as favouritism, lead to undue advantage or disadvantage, or have questionable professional ethics.
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Staff will be required to annual review and submit interests that they hold. From the second year of operation, the declaration of interest will pre-fill the information from the previous declaration of interest submission.
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Not in the first year of operation. The declaration of interest will not be able to pre-fill information from previously submitted disclosures, including disclosures for Conflict of Interest, Paid Outside Work, Gifts, Benefits and Hospitality, or Declaration of Private Interests and Related Parties.
From the second year of operation, the declaration of interest will pre-fill the information from the previous declaration of interest submission -
It is intended that the Declaration of Interest will be the single form required to meet the University risk management requirements for personal interest and conflict of interest. However, some point-in-time disclosures/approvals will continue to be required. (Tender Processes, Academic Promotion Committees)
The Declaration of Interest includes questions regarding any unpaid or paid outside work but does not replace the requirement for staff to seek prior approval for paid outside work as defined in the Paid Outside Work Procedure.
The Declaration of Interest includes a question regarding gifts, benefits and hospitality, which serves as an annual reminder for staff of their obligations to declare but does not replace the requirement for staff to declare the acceptance or rejection of gifts, benefits and hospitality within 20 days as required by the Gifts, Benefits and Hospitality Procedure.
The Declaration of Interest will replace the Declaration of Private Interest and Related Parties disclosure for Key Management Personnel.
The Declaration of Interest will not replace the Student Admissions Declaration for Senior Management.
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You should speak with your supervisor/head of the unit in the first instance if you have queries about a Declaration of Interest or how to manage a conflict of interest associated with your work.
For general procedure advice, staff can contact Access HR on 9902 0400
For specific advice regarding your personal disclosure or managing a conflict of interest that can not be supported by the above resources, please contact the University's Declaration Officer (declarations.officer@monash.edu)
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Monash University will use the information collected to review and manage risk, including actual, potential or perceived conflicts of interest and foreign affiliations or associations for research and education-related activities conducted in a personal capacity.
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The Chief People Officer makes the request to complete the declaration of interest in their capacity as Conflict of Interest Advisory Officer to the University. This activity is delegated to and supported by the University’s Declaration Officer.
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If you do not submit a declaration of interest or manage a conflict of interest may constitute a breach of your obligations under the Declaration of Interest Procedure. Action in response to such a breach may include disciplinary and other action, up to and including potential termination of employment for employees and cessation of other engagements for other persons.
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All information is collected in accordance with the University’s Data Protection and Privacy Procedures.
Information declared as part of the process will be held confidentially and stored in accordance with the Record Keeping Policy.
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Declaration of Interest form submissions and corresponding management plans will be held for ten years after form submission. After this, we take all reasonable steps to ensure that the personal data processed is archived in accordance with the University’s Recordkeeping policy and Recordkeeping: Retention and Disposal of University Records procedure (Australia only). Permanent deletion of all records is completed seven years after employment (provided the 10 years from form submission has passed).
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Declaration of Interest forms are submitted to the Head of the Organisation Unit and may be shared with the relevant Dean/Portfolio Head/Executive Director or subject matter expert as required to ensure appropriate management of any identified conflict or risk.
The information collected will be accessible by restricted Monash HR staff, including the Declaration Officer and Chief People Officer, for compliance reporting purposes and for management of conflicts of interest.
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A copy of your declaration of interest form will be provided to you in a PDF following submission.
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At the direction of the University, Contractors may be required to submit a DOI as part of our associated workforces. If you are engaged with access to University systems and hold a SAP ID you would have received a direction to complete the DOI for 2024 and should do so.
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If you continue to hold the interest from your approved COI disclosure, this should be captured as part of your 2024 Declaration of Interests. You can attach or copy-paste previously approved management plan.
Head of Unit
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All submissions are available in UniCRM and viewable under ‘My Cases’. You will receive periodic emails (daily digest) with links to forms submitted for review. Alternatively, you can view outstanding items anytime by accessing UniCRM directly (Through ‘MyMonash’>’ Tools).
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All staff submissions and associated management plans for your staff are searchable in UniCRM under the individual's record.
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Staff with nothing identified by the new system as a conflict of interest are automatically notified that they have no conflict of interest to manage. These are intentionally not assigned to you for review to reduce unnecessary workflow. If you would like to see a list of staff that have/have not completed their Declaration of Interest. Please refer to the online dashboard (available only to organisation unit chiefs for your relevant work unit).
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A dashboard is available to the Head of the Unit to view a list of submission statuses for their work unit. You can view your org unit dashboard via Power BI
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Staff submissions are assigned to the head of an organisational unit. If you are the head of an organisation unit and you are not receiving submissions or are receiving submissions for staff outside of your organisation unit, please notify your HRBP.
Assignment of declarations is automated based on assignment in HR systems; errors are rare but may arise when the head of unit duties are temporarily dedicated or if there is a significant change in structure.
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The DOI procedure assigns responsibility for reviewing interests and endorsing conflict of interest management plans to the head of an organisational unit. Depending on the structure of your work unit this may be, Director, Head of School/Department etc. This has been deemed the appropriate level to review and manage associate risks. Line managers may be required to oversee conflict of interest management plans at the direction of the Head of Unit.
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No. For the initial submission of the new Declaration on Interest it is not possible to delegate review and approval to a person other than the Head of Unit. This is to ensure Heads of Unit are aware of risks and management strategies associated with conflicts of interest, including foreign affiliations or associations.
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There is no automated workflow from Head of Unit to the next level manager. The Head of Unit has the option to collaborate and seek advice from more senior staff and can do so by tagging them to review. For example ” @firstname.lastname - I have reviewed the submission and recommended a COI Plan, but given the complexity / risk seek your input/or would like to bring to your attention for recommendation before approval. Plans will workflow to the Declarations Officer for review to ensure consistency with the procedural requirements.
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Please contact the University's Declaration Officer at declarations.officer@monash.edu
Refer to the launch email for a link to current drop in sessions (online support)
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Please contact the University's Declaration Officer at declarations.officer@monash.edu or your HRBP to discuss your needs.