Conflict of Interest Policy

Version: 1.1
Effective Date: 10/08/2026
Review Date: Annually unless otherwise indicated (10/08/2027)
Approved By: Mia Raunik (Business Owner)

The purpose of this policy is to ensure that all services provided by Mia Raunik Support Services are delivered ethically, transparently, and in the best interests of NDIS participants. This policy outlines how actual, potential, and perceived conflicts of interest are identified, disclosed, managed, and monitored to uphold participants' rights to choice and control.

Scope

This policy applies to:

• Directors and business owners

• Employees

• Contractors

• Students

• Volunteers

• Consultants

• Any person acting on behalf of Mia Raunik Support Services

Policy Statement

Mia Raunik Support Services is committed to:

• Acting honestly, ethically and transparently.

• Placing the participant's interests above the business's interests.

• Supporting participants to make informed decisions free from influence.

• Preventing conflicts of interest from affecting service delivery.

• Complying with the NDIS Code of Conduct and Practice Standards.

Where a conflict of interest exists, or may reasonably be perceived to exist, it will be disclosed and managed appropriately.

Definitions

Actual Conflict of Interest - An actual conflict occurs when a person's personal, financial or professional interests directly influence their professional duties.

Potential Conflict of Interest - A situation where a conflict could reasonably arise in the future.

Perceived Conflict of Interest - A situation where others may reasonably believe a conflict exists, even if it does not influence decision-making.

Examples of Conflicts of Interest

Examples include, but are not limited to:

• Referring participants to a business owned by yourself, a family member or close associate without fully disclosing the relationship.

• Receiving gifts, commissions or financial incentives from service providers.

• Accepting payments or benefits for referrals.

• Influencing participants to choose particular providers for personal or business gain.

• Providing services where a close personal relationship may impair professional judgement.

• Using confidential participant information for personal benefit.

• Employing family members without appropriate management of potential conflicts.

• Having outside employment that affects impartiality.

Responsibilities

Mia Raunik Support Services is responsible for:

• promoting ethical decision-making

• reviewing declared conflicts

• implementing management strategies

• ensuring compliance with NDIS requirements

• reviewing this policy annually

• avoid conflicts wherever possible

• disclose actual, potential and perceived conflicts immediately

• act in the participant's best interests

• maintain professional boundaries

• comply with this policy

Declaring a Conflict

All workers at Mia Raunik Support Services must disclose conflicts:

• before commencing work with participants where possible

• immediately upon becoming aware of the conflict

• whenever circumstances change

Declarations should include:

• nature of the conflict

• people involved

• potential impact

• suggested management strategies

Managing Conflicts

Management strategies must include:

• full disclosure to the participant

• obtaining informed participant consent

• declining or ending the service where necessary

Participant Choice and Control

Mia Raunik Support Services is committed to participant choice and control. We are committed to never:

• pressure participants to use a preferred provider

• limit participant choice

• withhold information about alternative providers

• accept referral commissions or incentives

• recommend services based on financial gain

Participants will always receive information about multiple suitable providers where available.

Participants remain free to choose, change or refuse any provider.

Gifts, Benefits and Hospitality

Mia Raunik Support Services will not engage in the following:

• soliciting gifts

• accepting money from participants

• accepting commissions

• accepting benefits that could influence professional judgement

Small tokens of appreciation (for example, inexpensive thank-you cards or homemade gifts) may be accepted where they do not influence service delivery and are documented in participant electronic health record.

Cash or cash equivalents must never be accepted.

Referrals

Where referrals are made:

• recommendations will be based solely on participant needs and preferences

• any existing relationship with the provider will be disclosed

• participants will be offered genuine alternatives wherever possible

• referral decisions will be documented

Soliciting Clients from Concurrent or Previous Employment

To preserve ethical practice and respect participant choice, Mia Raunik Support Services will not solicit, canvass, or otherwise actively encourage a current or former participant or client of a concurrent or previous employer, contractor engagement, or other professional role to transfer their support arrangements to Mia Raunik Support Services.

This includes direct or indirect solicitation, such as:

• contacting a known current or former participant for the purpose of offering services;

• advertising or promoting services directly to a known client or participant base;

• suggesting, prompting, encouraging, or otherwise influencing a participant to make contact with Mia Raunik Support Services; or

• using information obtained through a previous professional relationship to facilitate or encourage a participant's engagement with Mia Raunik Support Services.

A current or former participant of a previous professional role may independently choose to engage Mia Raunik Support Services where the participant makes contact without solicitation, invitation, prompting, encouragement, or other influence from the worker. This may include a participant independently identifying or contacting Mia Raunik Support Services after becoming aware of the service through publicly available information.

Where a current or former participant of a concurrent or previous employer or professional role independently approaches Mia Raunik Support Services, the engagement may only be accepted where all of the following conditions are met:

• the participant's approach was genuinely independent and was not suggested, prompted, encouraged, facilitated, or influenced by the worker;

• accepting the engagement does not breach any contractual, confidentiality, non-compete, non-solicitation, employment, or other professional obligations owed to a current or former employer or organisation;

• the participant has made a free and informed choice regarding their provider and the engagement is reasonably considered to be in their best interests;

• the participant's previous relationship with the worker, including any potential dual relationship or conflict of interest, is disclosed and appropriately considered and managed in accordance with this policy

• appropriate professional boundaries are maintained, including consideration of whether the previous professional relationship creates any risk of role confusion, dependency, confidentiality concerns, or other conflict;

• information obtained through the worker's previous professional role is not used to facilitate the new engagement beyond information that the participant independently provides or that can be appropriately obtained with their consent; and

• the circumstances of the approach, including how the participant came to contact Mia Raunik Support Services, the conflict-of-interest considerations, and the basis for accepting the engagement are documented in the participant's record.

Where these conditions cannot be satisfied, or where the worker reasonably considers that accepting the engagement could compromise professional boundaries, participant wellbeing, confidentiality, or obligations to a current or former employer, the worker must decline the engagement and, where appropriate, support the participant to identify an alternative provider.

Nothing in this section prevents a participant from exercising their right to choose their preferred provider where that choice is made independently and without inappropriate influence, solicitation, or coercion by the worker.

Recording Conflicts

A Conflict of Interest Note will be recorded in a participant’s electronic health record, and include:

• date declared

• description of conflict

• participant impacts

• management strategy

• review date

• outcome

Continuous Improvement

Conflict of interest management will be reviewed through:

• annual policy reviews

• staff supervision

• participant feedback

• internal audits

• complaints analysis

Lessons learned will inform ongoing improvements to business practices.

Related Documents

• Individual Service Agreement

• Complaints and Feedback Policy

• Privacy and Confidentiality Policy

Legislative and Regulatory References

This policy is informed by:

• National Disability Insurance Scheme Act 2013

• NDIS Code of Conduct

• NDIS Practice Standards and Quality Indicators

• National Disability Insurance Scheme (Provider Registration and Practice Standards) Rules 2018

• Privacy Act 1988

• Australian Privacy Principles