Conflict of Interest Policy

Purpose and scope

This policy meets our obligations under the NDIS Code of Conduct and the NDIS Practice Standards, including the Provider Governance and Support Coordination standards. It applies to every director, manager, employee, support worker, contractor and volunteer of Nova Cares.

What counts as a conflict

• Actual — a real clash between a participant's interests and ours, or a worker's private interests.
• Potential — a situation that could become a clash.
• Perceived — a situation a reasonable person could see as influencing our judgement, even if it doesn't.

Common examples in our work

• Recommending our own services when we also provide support coordination or plan management.
• Delivering both accommodation (SIL/SDA) and daily supports to a participant.
• Accepting or offering gifts, commissions, referral fees or inducements from other providers.
• Supporting a family member, friend or someone a worker has a close relationship with.
• Workers taking private paid work with a participant outside Nova Cares.
• Engaging a supplier owned by a staff member or relative.
• Acting as a participant's decision-maker, nominee, witness or beneficiary.

Our commitments

• We tell participants, in writing and in plain language, about every conflict relevant to them before a service agreement is signed.
• We always present alternative providers, and we make clear that participants can choose another provider or change providers at any time without penalty or loss of other supports.
• Support coordinators offer options from a range of providers and record the reasons for any referral to Nova Cares services.
• Staff are never paid bonuses, commissions or incentives for directing participants to our own services.
• We do not give, accept or solicit gifts, benefits or inducements beyond token items, and all offers are recorded in the gifts and benefits register.
• Workers do not support close relatives or friends unless approved in writing by management with documented safeguards.

How we manage a conflict

• Declare — the worker tells their manager as soon as they become aware, and on commencement and annually thereafter.
• Record — the conflict is entered in the Conflict of Interest Register with the date, parties, risk rating and treatment.
• Assess and treat — options include disclosing to the participant, reallocating the worker or coordinator, separating decision-making and service delivery, independent oversight, or declining the work.
• Monitor — management reviews the register quarterly and the board reviews it annually; outcomes feed into our continuous improvement plan.

If we get it wrong

Failure to declare a conflict is a serious breach and may lead to disciplinary action, including dismissal, and to notification of the NDIS Quality and Safeguards Commission. Participants, families and workers can raise concerns with us at ndis@ausfr8.com or directly with the NDIS Commission on 1800 035 544. Nobody is disadvantaged for speaking up.