Conflicts of Interest Guidance1 - Registrars, Supervisors and Training Practices
1.Purpose
The Royal Australian College of General Practitioners Ltd (RACGP) is committed to good governance and the highest ethical standards. The participation of members in their professional association can brings with it perceptions of bias whether they participate as employees, contractors or volunteers on advisory committees. This guidance aims to assist Registrars, Supervisors and Training Practices with the ongoing identification, declaration and management of actual potential or perceived conflicts of interest. This Guidance supports the RACGP Conflicts of Interest Guidance.
Management of conflicts of interest is important to ensure public trust and confidence in the RACGP. Members performing roles are also reminded of the RACGP Membership Code of Conduct requiring them to act professionally and with integrity. This obligation means disclosing and managing any relationships that could give rise to a conflict of interest.
Registrars, Supervisors and Training Practices are obliged to fully disclose and manage conflicts of interest as part of their accreditation requirements (Supervisors and Training Practices) or membership and program participation (Registrars and Supervisors)
This document is to be read in conjunction with the Conflict of Interest Guidance document.
2.Application
Management of actual, potential or perceived, conflicts of interest is the responsibility of all Registrars, Supervisors and Training Practices. Always being alert to conflicts and not participating in decisions where you have a conflict or declaring potential conflicts and discussing them with Coordinators is a continuing obligation.
"Importantly a conflict of interest does not depend on the character of the individual concerned, but on the specific situation." i
3.Conflicts General Principles- public trust
It is not always possible to avoid a situation where a conflict of interest exists, particularly as a membership professional association, however it is important that these situations are correctly managed. Personal or other interests, whether these are financial, relate to family friends or associates, must not influence decision making.
- Actual conflict of interest is where there is a real conflict between a duty to the RACGP and a personal interest.
- Potential conflict of interest is one which may arise in the future.
- Perceived conflict of interest where the public could reasonably form the view that a conflict exists or could arise that may improperly influence a decision or performance of a function.
Decision-makers must consider whether conflicts arising from personal interests, friendships, or relationships may create a perception of bias. This is particularly relevant in education and training. The context and nature of the role dictate the level of scrutiny required.
The following examples typify common conflicts situations occurring in a training context.
These examples, while illustrative and indicative, are not definitive. The RACGP retains the right to decide to take actions which vary from the examples presented when becoming aware of any type of conflict. The conflict situation may call for measures not described in the examples. Similarly, the examples are not to be taken as definitive advice on what action to take in any circumstances.
Note that it is your responsibility to comply with program requirements concerning conflict of interest including full disclosure as soon as the conflict becomes apparent.
4.Examples of conflict of interest
- You are completing your training term in a practice where you also hold an ownership stake as a shareholder or silent partner. This creates an actual conflict of interest, because your financial interest in the business could influence or appear to influence decisions about your training, supervision, or assessment. Management includes disclosing this conflict to your Training Coordinator / Program Coordinator, ensuring it is recorded in the register, and removing yourself from training in this practice. If relocation cannot occur immediately, an independent supervisor may be engaged temporarily, and you may need to consider relinquishing your ownership if you wish to continue training in this location.
- You are training in a practice that is owned by your parent, partner, or another close relative. This creates a perceived conflict of interest, (and possibly an actual conflict of interest) because others could reasonably believe that you’re training or assessment may be influenced by the relationship, even if you do not personally benefit financially. Management includes disclosing and recording the conflict, ensuring your relative is not involved in any training or assessment decisions, restricting their access to information about your performance, and appointing an independent supervisor or assessor if you remain in the practice.
- You are working in a practice where a close family member is also employed. This creates a perceived conflict of interest, (and possibly an actual conflict of interest) because the relationship may influence workplace interactions, feedback, or assessment outcomes, even if your relative is not your supervisor. Management includes disclosing and recording the conflict, ensuring your relative is removed from any training related responsibilities, restricting their access to your performance information, and monitoring the placement closely. If impartiality cannot be maintained, you may need to move to another practice.
- Alongside your training, you operate an exam preparation website, tutoring service, or coaching business for other registrars. This creates a potential conflict of interest, (and possibly an actual conflict of interest) because your secondary employment may create risks involving confidentiality, commercial advantage, unauthorised use of intellectual property or perceived unfairness. Management includes disclosing and recording the secondary employment, restricting your access to sensitive training or assessment materials, removing you from tutoring registrars in your own practice or region, and monitoring the situation. If the conflict escalates, you may need to relinquish the external business.
- Your parent is directly involved in your supervision, assessment, or training decisions. This creates an actual conflict of interest, because the relationship directly affects your training outcomes and undermines objectivity. A parent cannot impartially supervise or assess their child. Management includes identifying and disclosing the conflict, removing your parent from all supervision and assessment responsibilities, restricting their access to your performance information, and appointing an independent supervisor or assessor. If the conflict cannot be safely managed, you may need to relocate to another practice.
5.Management of Conflict of Interest
There are a range of options to manage conflicts of interest. Often a combination of strategies will be required. Discussing the conflict with your Coordinator and recording the disclosure of a conflict of interest in a register is an important step, however this does not necessarily resolve the conflict.
Management of any potential conflict should minimise its effects in the best interests of the RACGP. It may be necessary to assess the situation and determine whether one or more of the following strategies is also required: restrict, recruit, remove and relinquish or resign (see in Table 2). Table 2 is indicative only and is not exhaustive or definitive. Depending on the circumstances, the RACGP may require specific or multiple management controls.
Table 1:
|
Management Strategy
|
When most suitable
|
|
Recording or disclosing the conflict
|
Used for all conflicts (actual, perceived, potential).
Required whenever a personal, financial, or professional interest intersects with training.
|
|
Restrict
|
Use when the conflict is perceived or manageable, and the person can remain involved with limitations.
|
|
Recruit
|
Use when impartiality requires an independent third party, or when the conflicting interest must be reduced.
|
|
Remove
|
Use when the conflict is actual or high‑risk, or when impartiality cannot be maintained.
|
|
Relinquish or resign
|
Use when the conflict cannot be managed through other strategies, or when the private interest cannot be relinquished.
|
6.Questions to ask
In considering how a conflict of interest is to be managed, particularly arising from personal connection or relationship you can ask yourself:
- Role: What decision will they make in this role? What information do they have access to?
- Relationships: What relationships could amount to a personal interest?
- Connection: Is there a logical connection between the decision to be made and the personal interest?
- Objective test: What would a reasonable observer think? My view is not relevant.
- Other matters: Are there other contextual matters to consider? Is the conflict material? What is the amount, scope, and likelihood of any expected benefit?
Will my involvement in the decision undermine public trust and confidence in RACGP?
7.Conflicts of Interest Declarations
Discuss conflicts with your manager or the chair of the board or committee. If you or your manager are unsure how to assess or manage your particular situation, further advice can be sought from legal@racgp.org.au.
When you:
- Become accredited (Supervisor or Training practice); or
- Participate in any program (Registrar);
you must:
- Identify and declare any actual, potential, or perceived conflicts of interest you may have by completing the relevant conflict of interest declaration;
- Keep the declaration updated for the duration of the training program or accreditation period on an ongoing basis. This includes including new conflicts which develop; and
- Manage the conflict by taking the agreed actions on an ongoing basis.
8.Further information
Any potential conflicts should be discussed with your Coordinator.
1. This Guidance supports the RACGP Conflict of Interest and Related Party Transactions Policy – if there is any inconsistency the Policy will prevail.
i. NSW ICAC Managing Conflict of Interest in the NSW Public Sector. June 2019 @ 5