Governance

Conflicts of Interest Policy

Actual, potential and perceived conflicts should be identified early, disclosed to the appropriate decision-maker and managed so commercial incentives do not silently compromise client interests or independent judgement.

Examples

Conflicts may arise from competing client engagements, personal/financial interests, referral commissions, supplier relationships, gifts/hospitality, access to confidential competitor information or a person's role in a decision.

Controls

Controls may include disclosure, recusal, information barriers, reassignment, independent review, client consent where appropriate, restrictions on use of information or declining/ending work where the conflict cannot be managed satisfactorily.

Records and escalation

Material conflicts and agreed mitigations should be recorded. Suspected concealment or unethical handling can be escalated through the Speak-Up procedure.

Last reviewed: 27 August 2026.