National Operations Policy Manual - October 2018

Camp Australia National Operations Policy ManualConflict of InterestPurposeThe purpose of this policy is to:  Assist staff to identify situations in which a conflict of interest may arise;  Provide guidelines and assistance to employees to avoid or deal appropriately with conflicts of interest; and  Outline the consequences of a failure to avoid conflicts of interest.PolicyAll employees owe a legal duty to act in the best interests of Camp Australia in performing their dutiesin preference to the employee’s own personal interests. This duty is set out in your written contract ofemployment.Employees must not engage in other employment where the activity conflicts with their position as anemployee of Camp Australia. Employment includes a second job, conducting a business, trade orprofession, or active involvement with other organisations.This policy in no way diminish your right to engage in outside activities of a civic, religious, political, orcharitable nature or other activity where you can be used for the benefit of the community, providedthose activities are not otherwise a breach of this policy.A conflict of interest arises if an employee accepts employment with, or other substantial businessinterest in, a competitor. It also arises if they accept employment, other relationship or a substantialbusiness interest in a supplier or client of Camp Australia. The following guidelines are intended toassist in making decisions regarding potential conflicts, however do not include all possible situationsthat might create a conflict of interest.Conflicts of interest include, though are not limited to:  Directly or indirectly competing against Camp Australia in any capacity.  Providing competitive assistance to other companies or organisations that are competing with Camp Australia.  Engaging in outside employment or other activities that encroach on the time or attention necessary to carry out your responsibilities to Camp Australia.  Having a significant financial interest in, holding any position with, or receiving compensation or other benefits from any party that competes with Camp Australia or any of its clients or any party that does business or seeks to do business with Camp Australia or any of its clients.  Encouraging a client of Camp Australia to “do business\" with you or accepting an offer of employment with a client of Camp Australia.  Use of Camp Australia time and/or resources to engage in conflicts of interest.ExamplesExamples of conflicts of interests that would amount to a breach of this policy and must be immediatelydisclosed to Camp Australia include:Example 1: A Coordinator working at a service where Camp Australia provides after school care, setsup a family day care business. She advises parents she will be offering before school care services.Example 2: An Assistant who is unable to obtain Holiday Club shifts with Camp Australia acceptsvacation care shifts with another OSHC provider.Example 3: A field staff member offers to provide evening and weekend babysitting to parents currentlyusing a Camp Australia service.Example 4: A Regional Manager is asked by a friend to provide consulting advice and documentationto help her set up an OSHC service.Example 5: An Educator is asked by a parent whose children attend OSHC to sign them out and escortthem home following After Care.Dealing with conflicts of interestCamp Australia National Operations Policy Manual 2018 Page 185©This document is the property of Camp Australia and is not to be reproduced in any formReviewed: October 2018 Version: 1.27

Camp Australia National Operations Policy ManualEmployees must, at all times, act in a manner that will avoid actual, potential or perceived conflicts ofinterest.Whether a particular situation creates a conflict of interest between your personal activities orrelationships and your responsibility to Camp Australia depends upon the circumstances. However,you must immediately report to Human Resources at [email protected] every situationthat could have the possibility of creating a conflict between you and Camp Australia.HR will then determine whether the situation warrants further attention. A key issue in determiningwhether or not there is a conflict will be whether Camp Australia has suffered any disadvantage as aresult of your actions.Failure to disclose conflicts of interestA failure to avoid or disclose conflicts of interest is a matter of utmost seriousness. Depending on thecircumstances, disciplinary action may be taken against an employee who has a conflict of interest.This may include immediate termination of employment for serious misconduct.Employees must:  declare any potential, actual or perceived conflicts of interest that exist on becoming employed by Camp Australia to management  declare any potential, actual or perceived conflicts of interest that arise or are likely to arise during employment by Camp Australia to management  avoid being placed in a situation where there is potential, actual or perceived conflict of interest if at all possibleIf an employee declares such an interest, Camp Australia will review the potential areas of conflict withthe employee and mutually agree on practical arrangements to resolve the situation.Employees must disclose to their manager any other employment that might cause a conflict of interestwith Camp Australia. Where there are external involvements that do not represent a conflict of interest,these must not affect performance or attendance whilst working at Camp Australia. If such involvementdoes affect performance or attendance it will be considered a conflict of interest.Employees must not set up or engage in private business or undertake other employment in direct orindirect competition with Camp Australia using knowledge and/or materials gained during the course ofemployment with Camp Australia.Engaging in other business interests during work hours will result in strong performance improvementaction.Failure to declare a potential, actual or perceived conflict of interest or to take remedial action agreedwith Camp Australia, in a timely manner, may result in performance improvement proceedings includingdismissal.------------------------------------------------------------------------------------------------------------------------------------ACKNOWLEDGEMENT OF CODEI have read and agree to abide by the Code of Conduct and Conflict of Interest policy during myemployment with Camp Australia.Name ………………………………………..............................Signature ……………………………………………………………Date ……………………………………………………………Camp Australia National Operations Policy Manual 2018 Page 186©This document is the property of Camp Australia and is not to be reproduced in any formReviewed: October 2018 Version: 1.27