Conflict of Interest Policy

Status: v1.0
Tier: Tier 1 – Core Corporate & Platform Policy
Owner: Governance and Compliance Function
Approval Authority: Board of Directors
Effective Date: 5 January 2026
Next Review: 12 months from approval

1. Purpose

This policy sets out how Global Talent Pathway identifies, discloses, manages, and resolves conflicts of interest to ensure decisions are made impartially, transparently, and in the best interests of the organisation.

Its purpose is to:

  • protect organisational integrity,

  • maintain trust with candidates, employers, suppliers, and regulators,

  • prevent improper influence on decision-making, and

  • manage legal and reputational risk.

2. Scope

This policy applies to:

  • Board members and officers,

  • Advisory Board members,

  • employees,

  • contractors and consultants,

  • agents and representatives,

  • suppliers, employers, and recruiters where relevant to decision-making.

This policy applies across all Global Talent Pathway activities and jurisdictions.

3. Policy Statement

Global Talent Pathway requires conflicts of interest to be identified, disclosed, and managed appropriately.

Having a conflict of interest is not prohibited. Failing to disclose or manage a conflict is.

4. What Is a Conflict of Interest

A conflict of interest arises where a person’s personal, professional, or financial interests could improperly influence, or be perceived to influence, their duties or decisions.

Conflicts may be:

  • Actual – a real conflict exists,

  • Potential – a conflict could arise in the future,

  • Perceived – a reasonable observer could perceive a conflict.

All three must be disclosed.

5. Common Examples

Conflicts may include, but are not limited to:

  • financial interests in suppliers, employers, or competitors,

  • personal relationships affecting recruitment or supplier decisions,

  • outside employment or consulting roles,

  • gifts or benefits creating a sense of obligation,

  • advocacy or public positions that conflict with organisational neutrality in decision-making.

6. Disclosure Obligations

All persons within scope must:

  • disclose conflicts as soon as they arise,

  • update disclosures when circumstances change,

  • provide sufficient detail to enable assessment.

Disclosure must occur:

  • on appointment or engagement,

  • annually (where required), and

  • before participating in any decision affected by the conflict.

7. Managing Conflicts

Once disclosed, conflicts may be managed through measures such as:

  • recusal from discussions or decisions,

  • restriction of access to information,

  • reassignment of duties,

  • divestment of interests,

  • termination of conflicting arrangements.

The appropriate management response will be proportionate to the risk.

8. Decision Authority

Conflict management decisions are made by:

  • the Board (for Board or Advisory Board members),

  • executive management (for staff and contractors),

  • delegated authorities as appropriate.

Decisions and actions are documented.

9. Failure to Disclose

Failure to disclose or manage a conflict of interest may result in:

  • disciplinary action,

  • termination of employment or contracts,

  • termination of supplier or employer relationships,

  • other appropriate remedial action.

10. Gifts, Benefits and Hospitality

Gifts, benefits, or hospitality must:

  • be declared where required,

  • comply with the Fraud, Bribery & Corruption Policy,

  • not influence or appear to influence decisions.

Prohibited gifts or benefits must not be accepted.

11. Reporting Concerns

Concerns regarding undisclosed or unmanaged conflicts must be reported through the Complaints & Disclosures Gateway.

Whistleblower protections apply where relevant.

12. Recordkeeping

Conflict disclosures and management actions are:

  • recorded securely,

  • access-restricted,

  • retained in accordance with the Records Management & Retention Policy.

13. Relationship to Other Policies

This policy operates alongside:

  • Fraud, Bribery & Corruption Policy,

  • Whistleblower Policy,

  • Complaints Policy,

  • Modern Slavery & Human Trafficking Policy,

  • Ethical Recruitment & Fair Work Policy.

In the event of inconsistency, Tier 1 policies prevail.

14. Review

This policy will be reviewed annually and updated as required.