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Management of Conflicts of Interest - Procurement and Grants Management

July 7, 2020

The Australian National Audit Office (ANAO) published an article on “Management of Conflicts of Interest in Procurement Activity and Grants Programs” in late June 2020. The article provides an insight into key messages from the ANAO performance audit about the management of conflicts of interest by Australian Government entities in relation to procurement activity and grants programs.

The report suggests that a conflict of interest occurs where a person’s personal interests, affiliations or relationship prejudices impact on their impartiality, or might be perceived by a reasonable person as potentially prejudicing their impartiality, or result in an incompatibility with the duties owed to the entity undertaking a procurement or administering grants.

The Australian Public Service (APS) Code of Conduct, the Public Services Act 1999, the Public Governance, Performance and Accountability Act 2013 (PGPA) Act, Public Governance, Performance and Accountability Rule 2014, the Commonwealth Grant Rules and Guidelines (CGRGs) and the Commonwealth Procurement Rules (CPRs) have provisions relating to conflicts of interest and require that persons must disclose details of any material personal interest.


  • Developing conflict of interest policies. It is the duty of the entity accountable authorities to promote the ethical management of public resources and establish and maintain appropriate systems relating to risk management and oversight and internal controls. This include policies and procedures regarding management of conflicts of interest. Section 16 of the PGPA Rule requires the conflict of interest policies to be approved by the entity accountable authority.
  • Identifying conflict. It is common for entities to rely on declarations from employees, contractors and advisory bodies to identify any conflicts that may require management. These declarations need to be scrutinised and considered against other known information to identify any associations and potential conflicts that have not been declared. There are additional measures that could be put in place to guard against the risk of persons failing to disclose their conflicts of interest:
    • Internal reporting or complaint-handling function for internal staff or external parties to report their concerns
    • Data analytic program to identify suspicious transactions
    • Appointing a probity auditor
    • Conducting background and due diligence checks on potential staff, suppliers, contractors and business partners
  • Managing conflicts. The report highlighted that appropriate management of identified conflicts is an active rather than a passive approach. The active approach has several elements:
    • Avoiding conflict – through declarations and separation of duties
    • Guarding against employment offers from tenderers or grant applicants
    • Promote a consistent approach to managing conflicts
    • Documenting how conflicts have been managed
  • Culture, training and awareness raising. The “tone at the top” set by leaders determines the culture with respect to the management of conflict of interest. An appropriate culture can be encouraged via managers discussing and reviewing conflict of interest declaration forms. It is also important to promote compliance with conflict of interest requirements through regular awareness raising and on-the-job and formal training

Click here, for the complete article published by ANAO.


Centium has vast, hands-on expertise with regards to procurement and probity matters, especially in assisting agencies to manage conflicts of interest management.

Centium can provide:

  • Probity advice in relation to procurement and grants management
  • Bid and tender management
  • Request for Tender (RFT) and requirements preparation
  • Reviews of procurement and probity activities in relation to conflict of interest management
  • Assistance regarding better practice management regarding conflict of interest management
  • Training material to build organisational capacity regarding conflict of interest management
  • Conduct training and awareness sessions (including online / e-learning solutions)

We would be pleased to work with our existing and new clients to share our experiences and/or discuss specific issues relating to procurement, grants administration and/or conflict of interest management.  For more information regarding our probity advisory services, please contract Howard Elliott, Director Probity & Procurement or Penny Corkill, Director Risk & Assurance.

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