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Conflict of Interest Policy

Purpose

Sydney Art School is committed to upholding the highest standards of educational integrity, professionalism, and ethical conduct in all its operations. We recognise that maintaining public trust and employer trust is fundamental to our reputation as a quality ASQA-accredited Registered Training Organisation (RTO) delivering nationally recognised qualifications and participating in government-funded programs.

This policy ensures that any actual, perceived, or potential conflict of interest is identified and managed transparently and effectively. This protects the integrity of our training and assessment practices, the interests of our learners and clients, and our compliance with regulatory and contractual obligations, including those under ASQA, VET Student Loans (VSL), CRICOS, and NSW Government contracts.

Scope

This policy applies to all directors, employees, contractors, and key personnel of Sydney Art School.

Definition

A conflict of interest occurs when an individual’s private interests (financial, personal, family, relational, or professional) could, or could be perceived to, influence, compromise, or appear to compromise their impartiality, objectivity, or ability to perform their duties fairly and in the best interests of the School, its students, clients, and funding bodies.

Reference to Staff Handbook

This policy should be read in conjunction with the existing sections on Professional Conduct, Ethical Standards, and Governance in the Sydney Art School Staff Handbook. It builds upon and formalises the general principles regarding conflicts of interest already outlined therein.

Identification Procedures

All staff must:

  • Complete a Conflict of Interest Declaration on commencement of employment, annually (by 31 January), and prior to involvement in any tender response, government contract, RFQ, or significant new project.
  • Immediately disclose any new or emerging conflict of interest that arises during the year.
  • Declare any relationships with Federal, State, or Local Government agencies (including the NSW Department of Education, schools, NESA, or other RTOs), as well as any personal or professional interests that could affect educational delivery, assessment decisions, or participation in government programs such as ASQA-regulated training, VET Student Loans (VSL), or CRICOS.

Project-specific screening is conducted by the Registrar or a Director before tender submissions or commencement of delivery under any government-funded or contractual arrangements.

Management Procedures

When a conflict of interest (actual, perceived, or potential) is identified:

  1. It is promptly assessed for materiality and risk level by the Registrar and/or a Director.
  2. It is recorded in the School’s secure Conflicts of Interest Register.
  3. Appropriate management strategies are applied, which may include:
    • Recusal or restriction from the affected activity, decision, or contract
    • Additional oversight, independent review, or supervisory arrangements
    • Divestment of the conflicting interest where practicable
    • Formal notification to the relevant client, funding body, or regulatory authority (e.g., ASQA, Department of Education, or other government agencies) where required by law or contract
  4. All actions are fully documented and retained for audit and review purposes.

Staff Responsibilities

  • Act at all times with honesty, integrity, and in the best interests of Sydney Art School, its learners, clients, and funding bodies.
  • Proactively identify and disclose any actual, perceived, or potential conflicts of interest.
  • Comply fully with any management directions issued in relation to a declared conflict.
  • Maintain the confidentiality of all declared information in accordance with privacy obligations.

Breach of Policy

Failure to disclose a known conflict of interest or to follow required management actions may constitute a breach of professional conduct and may result in disciplinary action, up to and including termination of employment or engagement. Serious breaches may also be reported to relevant regulatory bodies such as ASQA.

Review

This policy will be reviewed annually or sooner if there are significant changes in legislation, ASQA Standards, contractual obligations (including NSW Government VET Teacher Training Provider Panel arrangements), VSL, CRICOS, or other government programs.