Conflict of Interest Policy for DSS employees and contractors

DSS Employee means a person employed by the Department under the Public Service Act 1999, whether full-time or part-time, in an ongoing or non-ongoing capacity.

Contractor means a person employed by an external company who is providing services under the supervision of DSS, DSS specifies how the work is to be undertaken and has control over the final form of any resulting output.

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This document outlines the responsibilities of DSS employees and Contractors to address real or perceived conflicts of interests that may arise in relation to the administration of DSS programmes.

It also provides advice to organisations funded under DSS programmes who believe that a DSS employee that they have dealings with may not be acting impartially due to a real or perceived conflict of interest.

Conflict of Interest Disclosure Process

What is a conflict of interest?

A conflict of interest may occur when there is a real or perceived conflict between a DSS employee’s or contractor’s personal interest, pecuniary (financial) or non-pecuniary (personal), and their official duties. Where there is a real or perceived conflict of interest it is inappropriate for the DSS employee or contractor to be involved in or to make decisions that may be affected by or impact upon their personal interest.

Pecuniary interest is an interest that a DSS employee or contractor may have in a matter because of the reasonable likelihood or expectation of appreciable financial gain or loss to the employee or contractor.

Non-pecuniary interest is an interest that a DSS employee or contractor may have in a matter because it may involve family or other relationships and/or friendships or other interests that do not involve financial gain or loss.

Basic Information

  • Financial interests may cover such things as real estate, shareholdings, trusts or nominee companies, company directorships or partnerships, other investments, assets or substantial sources of income, gifts, sponsored travel and hospitality
  • Personal interests may include personal relationships such as sporting, social or cultural activities as well as family, sexual or other relationships
  • DSS employees  must notify their manager where there is a real or potential conflict of interest
  • DSS employees  should take reasonable steps to avoid or remove themselves from the real or potential conflict of interest
  • DSS employees wishing to engage in outside employment, including in a voluntary capacity, who suspect there may be a real or perceived conflict of interest with their DSS responsibilities, should seek approval to undertake these activities prior to commencing the outside employment
  • DSS  SES employees are required to provide a statement of their private interests to be examined for potential conflicts of interest
  • Contractors are required to advise of potential conflicts of interest as part of their contract.

Examples of a conflict of interest

  • Departmental employee is the director of a family company that may be affected by policy changes being considered in his or her work area.
  • Departmental employee may be assessing tenders from companies in which they or a relative have an interest. This involvement could lead to the perception that they were subject to bias.
  • Departmental employee is in a position to assess grants to a community group to which they belong.
  • Departmental employee on a selection panel has a personal relationship with an applicant for the position. This could be seen as providing an unfair advantage and may be a violation of the APS Code of Conduct.

What should a DSS employee or contactor do if a conflict of interest arises?

A DSS employee or contractor must:

  • advise their manager immediately if they believe that a conflict of interest will arise with their official duties and their financial or personal interests by completing the Conflict of Interest Disclosure Form;
  • take immediate action to ensure that they remove themselves from the potential conflict of interest situation, including removing themselves from involvement in any related recommending, approval or decision-making process. They may need to be assigned to different duties on a short or long term basis to ensure the conflict is avoided; and
  • advise their manager of any future change in their personal circumstances that may affect the action already taken.

What are DSS managers required to do in relation to conflicts of interest?

Managers have the responsibility to decide whether:

  • there is, or could be, a conflict of interest;
  • it is reasonable and necessary to ask the DSS employee or contractor to divest the interest;
  • to change the DSS employee’s or contractor’s  duties or to transfer the employee to other duties where there is no conflict;
  • it is appropriate to allow the DSS employee or contractor  to continue their current duties with or without some modifications; and/or
  • to terminate a contract.

Managers must discuss the issue with and advise the employee or contractor of the action to be taken and the reasons for the decision.

Completed Conflict of Interest Disclosure Forms

DSS employees must forward completed conflict of interest disclosure forms to the Section Manager, Workplace Relations and Conduct Section in People Branch for storage on the employee’s personnel file.

What should you do if you believe a DSS employee with whom you have dealings has a real or perceived conflict of interest?

You should contact the DSS National Office Complaints Team by phone on 1800 634 035, by email to or in writing to DSS Complaints, PO Box 7576, Canberra Business Centre, ACT 2610.

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