Conflict of Interest Policy

A conflict of interest arises where an individual’s personal, relational, financial, or other interests could improperly influence, or be reasonably perceived to influence, their duties, decisions, or responsibilities at the College.
Conflicts may be:

• Actual – a real conflict exists
• Potential – a conflict could arise in the future
• Perceived – a reasonable third party could perceive a conflict

1. Types of Conflicts of Interest
Conflicts of interest may include, but are not limited to:

• Financial interests (e.g. ownership, employment, or benefits from external organisations)
• Personal or family relationships
• Romantic, dating, or marital relationships
• Outside employment or ministry commitments (e.g. board roles, consulting, church and/or parachurch leadership)
• Gifts, hospitality, or favours that may influence decision-making

2. Personal, Dating, and Marital Relationships

2.1 Theological and Ethical Context
In alignment with the College Faculty and Staff Handbook, the College affirms the sanctity of marriage as ordained by God: an exclusive, lifelong covenant between one man and one woman. Staff are expected to conduct their personal relationships in a manner consistent with biblical holiness, Christian witness, and the College’s role as a leader within the Christian community.
Personal conduct in relationships is not merely a private matter but forms part of the College’s formation, governance, and public witness.

2.2 General Principles
All personal relationships must:

• be conducted with sexual integrity, propriety, and respect;
• avoid the misuse of authority, spiritual influence, or power imbalance;
• not compromise student welfare, staff wellbeing, or the learning environment;
• be consistent with the College’s Code of Conduct.

2.3 Staff–Student Relationships
Consistent with the College’s commitment to student welfare and professional boundaries:

• Romantic or dating relationships between staff and students are not acceptable where the staff member is or may in the future be in a position of authority (including in any teaching, supervisory, pastoral, mentoring, or evaluative capacity) in relation to the student. If this does occur, it must be disclosed immediately and will be deemed a breach of this policy and may also be a breach of the College’s Gender-Based Violence Policy and Code of Conduct.
• Where such a relationship already exists prior to the student studying, it must be disclosed immediately, and appropriate steps will be taken by the College to remove any direct or indirect academic, supervisory, or decision-making involvement. If it is unavoidable, the college may seek alternative supervision/marking, online delivery and/or other methods to manage the conflict. This is to be discussed with Human Resources, the relevant manager of the conflicted staff member and/or the principal.
• Sexual relationship outside of marriage between a staff member and student may result in immediate termination of employment for the staff member. If Gender-Based Violence (GBV), Sexual Assault and/or Sexual Harassment is involved, refer to the GBV policy and/or SASH Policy.

2.4 Staff Dating Relationships
Where a romantic or dating relationship exists or develops between staff members:

• The relationship must be disclosed where there is any direct or indirect reporting, supervisory, evaluative, or decision-making relationship.
• Staff must not participate in decisions relating to appointment, assessment, remuneration, discipline, or workload of a person with whom they have a romantic relationship.
• The College may implement management strategies, including changes to reporting lines or duties, to mitigate actual or perceived conflicts of interest.

2.5 Marriage and Family Relationships
Where spouses or immediate family members are employed by the College:

• The relationship must be disclosed at appointment or when it arises.
• No staff member may directly supervise, appraise, discipline, or make remuneration decisions concerning their spouse or immediate family member.
• Consistent with the Faculty and Staff Handbook, marital, personal and/or family conduct that brings serious reputational concern to the College (1 Timothy 3:2) may be subject to investigation and, depending on seriousness, termination of employment.

2.6 Staff Members with Immediate Family Members Enrolled as Students
Where a staff member has an immediate family member (including spouse, child, sibling, parent, or other dependent) enrolled as a student of the College, this must be disclosed to the Principal (or delegate) upon enrolment or upon the staff member becoming aware of the enrolment.
In such circumstances:

• The staff member must not teach, assess, supervise, pastorally counsel in an official capacity, or otherwise exercise academic or administrative authority over their immediate family member.
• The staff member must not have access to confidential academic, disciplinary, financial, or welfare information relating to the student, except where such access is available to the public or authorised through a separate formal process.
• Appropriate adjustments to teaching allocations, supervision arrangements, reporting lines, or administrative responsibilities will be implemented to avoid actual, potential, or perceived conflicts of interest.

The College recognises that family members studying within a theological community may be a natural outcome of shared Christian commitment. However, safeguarding academic integrity, fairness, and student wellbeing requires that clear professional boundaries be maintained at all times.
Failure to disclose such a relationship may constitute a breach of this policy and may result in disciplinary action as outlined in this policy.

3. Gifts and Hospitality
3.1 General Principles
In relation to gifts and hospitality, the College expects all Relevant Persons to act in a manner that upholds Christian integrity, good stewardship, and the College’s public witness. Accordingly:

• Gifts and hospitality must never be solicited.
• Gifts and hospitality must not create, or reasonably be perceived to create an obligation, sense of favour, or influence over decision-making.
• The appearance of impropriety or favouritism is to be avoided, even where no actual conflict exists.
• Decisions of the College must always be made on merit, without regard to personal benefit.
• Where uncertainty exists, the presumption should be in favour of disclosure and seeking guidance.

These principles apply regardless of the monetary value of any gift or hospitality and are to be read together with the specific thresholds and requirements set out below.

3.2 Scope of Gifts and Hospitality
The gifts and hospitality provisions of this policy apply to all instances where gifts, benefits, or hospitality are connected, or could reasonably be perceived to be connected, to a person’s role, responsibilities, or association with the College.
Accordingly, this policy applies to:

• gifts, benefits, or hospitality offered to, received by, or given by staff or Board members, or their immediate family members, where such offers can reasonably be attributed to the individual’s official duties, decision-making responsibilities, or association with the College, regardless of whether the gift or hospitality is accepted or declined;
• gifts of appreciation or gratitude received by staff from students, former students, or their families;
• gifts, benefits, or hospitality received in connection with externally hosted meetings, events, conferences, or professional engagements;
• externally funded travel, accommodation, meals, or conference registration that is not otherwise approved or funded through the College’s travel or professional development arrangements;
• prizes, awards, grants, discounts, or other benefits provided for personal use, where these arise from, or are connected to, the individual’s role or association with the College.

For the avoidance of doubt, the following matters are out of scope of this policy and are governed by other College policies or procedures:

• gifts, benefits, or hospitality provided by the College to its staff or Board members in the course of employment or service;
• gifts, benefits, or hospitality exchanged between staff members purely in a personal capacity and unrelated to College business or decision-making;
• philanthropic gifts, donations, sponsorships, or bequests made to the College
• College-funded or College-approved travel and accommodation arranged in accordance with the College’s travel or professional development procedures;
• meals, entertainment, sponsorships, or other expenses properly incurred and reimbursed under the College’s approved expenses;
• honoraria, stipends, or payments for activities such as thesis examination, peer review, external assessment, preaching at Churches, speaking at Christian conferences/retreats, or one-off lectures or seminars, where these are governed by separate College policies or contractual arrangements;
• prizes, awards, scholarships, or grants awarded primarily for educational or research purposes rather than for personal benefit.

3.3 Gifts Thresholds
The College recognises that modest gifts and hospitality may arise in the ordinary course of professional and ministry-related relationships. Such gifts must not compromise, or reasonably be perceived to compromise, impartial decision-making or Christian witness.

• Gifts or hospitality with a value of up to $200 are considered token and may be accepted without formal disclosure, provided they are infrequent, modest in nature, and not connected to any decision-making, tender, procurement, assessment, or evaluative process involving the College.
• Cumulative gifts or hospitality from the same source that, in total, exceed $400 within a 12‑month period must be disclosed, even if individual items are each below the threshold.
• Gifts or hospitality exceeding $200 (single item) and/or exceeding $400 (cumulatively) must be disclosed and recorded in accordance with the College’s conflict of interest procedures and may only be accepted with appropriate approval and management.
• Gifts or hospitality with a significant or high value (generally exceeding $400, whether as a single item or cumulatively within a 12‑month period) are not normally permitted and may only be accepted with the written approval of the Principal, or the Chair of the Board where the Principal is the recipient.
• Gifts or hospitality offered during, or in connection with, a procurement, recruitment, assessment, or contractual decision must not be accepted, regardless of value.
• Cash or cash-equivalent gifts (including gift cards) must not be accepted under any circumstances.

For declaration any gifts or hospitality please fill in the form in Appendix B for the Gifts and Hospitality Declaration and Register.

4. Disclosure Requirements
All staff and faculty must:

• Disclose any actual, potential, or perceived conflict of interest as soon as it arises
• Complete a Conflict-of-Interest Declaration upon appointment
• Update disclosures promptly if circumstances change

Disclosures must be made to:

• Human resources and the Chief Operations Officer and/or;
• The Principal;
• The Chair of Board (for the Principal or Board members).

4. Management of Conflicts
4.1 Disclosed Conflicts
The College will assess disclosed conflicts and determine appropriate management strategies in a manner consistent with the Faculty and Staff Handbook and the College governance practice. Management strategies may include:

• recusal from decision-making;
• reassignment of duties or reporting lines;
• establishment of oversight or accountability measures;
• pastoral engagement where appropriate;
• in rare cases, termination of a role or ceasing of other outside commitments.

All actions will be undertaken fairly, confidentially, and in accordance with Australian employment law and the College policies.

4.2 Undisclosed Conflicts
The College recognises that conflicts of interest may sometimes arise unintentionally or may not be immediately recognised. This section establishes a fair, transparent, and proportionate process for addressing situations where a conflict of interest has not been disclosed in accordance with this policy. An undisclosed conflict of interest may be identified through:

• self-disclosure after the fact;
• routine governance, audit, or register review;
• supervisory review;
• a report or complaint made in good faith;
• Board oversight processes.

4.2.1 Initial Assessment
Where a potential undisclosed conflict is identified:

• For staff: the matter will be reviewed by the Principal, Chief Operations Officer and/or Human Resources (or delegate).
• For the Principal: the matter will be reviewed by the Chair of the Board.
• For Board members: the matter will be reviewed by the Chair of the Board (or Deputy Chair where appropriate).

4.2.2 Review Process
The reviewer will conduct a preliminary assessment to determine:

• whether a conflict existed (actual, potential, or perceived);
• whether the failure to disclose was inadvertent, negligent, or deliberate;
• whether any decision, process, or outcome may have been affected.

4.2.3 Outcomes
Outcomes will depend on the seriousness of the matter and may include:

• formal recording and management of the conflict;
• corrective action (e.g., reconsideration of affected decisions);
• counselling or training regarding disclosure obligations;
• formal warning;
• disciplinary action in accordance with employment policy;
• referral to the Board (where governance implications arise).

The outcome will determine the next steps of the process and may refer back to 4.1 to manage the discovered conflict.

5. Confidentiality
All disclosures will be handled sensitively and confidentially, subject to legal and governance requirements.

6. Breach of Policy
Failure to disclose a conflict of interest or appropriately manage a conflict of interest may result in disciplinary action or further management, which may include:

• Further discussion for the management of the conflict as outlined in section 4 of this policy with the relevant supervisor, human resources, Board member or Principal;
• Formal warnings;
• Removal from a role or committee;
• Termination of employment or engagement;
• Other procedures and/or actions to further manage the conflict as permitted under College policies and Australian law.

7. Alignment with TEQSA and the Higher Education Standards Framework (HESF)
The College is committed to compliance with the Tertiary Education Quality and Standards Agency (TEQSA) requirements and the Higher Education Standards Framework (Threshold Standards) 2021.
This policy supports, in particular:

• HESF 6.1 (Corporate Governance): by promoting ethical decision-making, transparency, and management of conflicts of interest.
• HESF 6.2 (Corporate Monitoring and Accountability): by requiring disclosure, documentation, and appropriate oversight of conflicts.
• HESF 3.2 (Staffing): by ensuring professional conduct, appropriate boundaries, and integrity in staff relationships.
• HESF 2.3 (Wellbeing and Safety): by maintaining a safe, respectful, and trustworthy learning and working environment.

The implementation of this policy assists the College to demonstrate sound governance, risk management, and Christian ethical leadership consistent with regulatory expectations.