Conflict of Interest Policy
1. Purpose
Central Highlands Pickleball Club Incorporated (CHP) is committed to operating with integrity, transparency, accountability and appropriate standards of governance.
The purpose of this Conflict of Interest Policy is to ensure that actual, potential and perceived conflicts of interest are identified, disclosed and appropriately managed.
The existence of a conflict of interest does not necessarily imply wrongdoing.
Conflicts can arise naturally in a community sporting organisation, particularly where Committee members, volunteers, coaches, members and local businesses have multiple roles or relationships.
The important requirement is that relevant conflicts are declared and appropriately managed so that CHP decisions are made in the best interests of the Club.
2. Scope
This policy applies to people involved in CHP decision-making or acting on behalf of the Club, including:
Committee members.
Sub-committee and working group members.
Coaches and session managers where they exercise decision-making authority.
Tournament Directors and officials where relevant.
Volunteers with delegated authority.
Contractors and service providers where relevant.
Any other person participating in a CHP decision where an actual, potential or perceived conflict may arise.
Committee members are additionally subject to the specific conflict-of-interest requirements contained in the CHP Rules of Association.
3. What is a Conflict of Interest?
A conflict of interest may arise where a person's personal, financial, professional or other interests could influence, or reasonably appear to influence, their ability to act impartially and in the best interests of CHP.
A conflict may be:
Actual Conflict
An actual conflict exists where a person's current interests directly conflict with their responsibilities to CHP.
Potential Conflict
A potential conflict exists where a person's interests could conflict with their CHP responsibilities in the future.
Perceived Conflict
A perceived conflict exists where a reasonable person could consider that a person's interests might improperly influence their decision, even if no actual conflict exists.
Perceived conflicts should be disclosed where appropriate because maintaining confidence in CHP's decision-making is an important part of good governance.
Material Personal Interest
A material personal interest is particularly important for Committee members because the CHP Rules of Association impose specific requirements where such an interest exists.
Whether an interest is material will depend upon the circumstances, including the nature and significance of the interest and its connection with the decision being considered.
Where there is uncertainty, disclosure is encouraged.
4. Examples of Conflicts of Interest
Conflicts may include:
Personal or Financial Interests
A Committee member or decision-maker has a personal or financial interest in a business, transaction, contract or decision being considered by CHP.
Family and Personal Relationships
A family member, partner, close friend or other person with a significant personal relationship to a decision-maker may benefit from or be materially affected by a CHP decision.
Employment or Business Interests
A person's employment, business activities or commercial relationships could influence or reasonably appear to influence their judgement when acting for CHP.
Gifts and Hospitality
A person receives gifts, discounts, entertainment, hospitality or another benefit from a person or organisation that does business with CHP or may benefit from a CHP decision.
Other Sporting Organisations
A person holds a Committee, employment, coaching, commercial or other significant role with another sporting club or organisation whose interests may conflict with a particular CHP decision.
Membership or ordinary involvement with another sporting organisation does not, by itself, establish an inappropriate conflict.
Selection and Appointment Decisions
A person participates in a decision concerning the appointment, selection, payment, recognition or other benefit of themselves, a family member, close associate or business partner.
Club Suppliers and Contractors
A Committee member, member or close associate provides paid products or services to CHP and participates in decisions concerning the selection, engagement, payment or management of that supplier.
5. Responsibilities
People covered by this policy are responsible for identifying and disclosing relevant conflicts.
Disclosure
A conflict should be disclosed as soon as reasonably practicable after the person becomes aware of it.
For Committee members, disclosure should ordinarily be made to the President or Secretary and, where relevant, to the Committee.
If the conflict concerns the President or Secretary, it should be disclosed to another appropriate Committee member.
Good Faith
People must act honestly and in good faith when identifying and disclosing conflicts.
Where a person is uncertain whether an interest creates a conflict, they should disclose the circumstances so that the matter can be appropriately considered.
Management
Once disclosed, CHP will determine how the conflict should be managed, subject always to any mandatory requirements contained in the Rules of Association or applicable law.
6. Committee Meeting Declarations
Committee members should be given an opportunity at each Committee meeting to declare relevant actual, potential or perceived conflicts relating to matters to be considered.
A conflict must also be declared when it becomes apparent during a meeting.
Relevant declarations should be:
Recorded in the meeting minutes.
Added to the CHP Conflict of Interest Register where appropriate.
Managed before the affected decision is made.
Where the conflict constitutes a material personal interest, the mandatory requirements in section 9 of this policy apply.
7. Conflict of Interest Register
CHP will maintain a Conflict of Interest Register.
The Register may record:
The person's name.
The nature of the disclosed interest.
The date of disclosure.
Whether the conflict is ongoing or relates to a particular matter.
How the conflict was managed.
Any relevant review or expiry date.
The President and Secretary will ordinarily be responsible for maintaining the Register.
Access will be managed appropriately having regard to privacy, confidentiality and CHP's governance obligations.
8. Initial and Ongoing Disclosure
Initial Disclosure
Upon joining the CHP Committee or accepting another role involving significant Club decision-making, a person should disclose known ongoing interests that could reasonably create a conflict with their CHP responsibilities.
Contractors or service providers may also be required to disclose relevant conflicts before being engaged by CHP.
Ongoing Disclosure
Disclosure is an ongoing responsibility.
New conflicts should be disclosed as soon as reasonably practicable after becoming apparent.
A previously disclosed conflict should also be updated where circumstances materially change.
9. Material Personal Interests of Committee Members
Where a CHP Committee member has a material personal interest in a matter being considered at a Committee meeting, the requirements of the CHP Rules of Association apply.
The Committee member must:
Disclose the nature and extent of the interest and its relationship to the activities of CHP.
Ensure the disclosure is recorded appropriately.
Not be present while the matter is being considered at the meeting.
Not vote on the matter.
These requirements are mandatory where the Rules of Association apply.
The Committee cannot simply decide to allow the conflicted Committee member to remain and vote contrary to those Rules.
Where necessary, the Committee may obtain independent advice concerning whether an interest constitutes a material personal interest or how the requirements should be applied.
10. Managing Other Conflicts
Not every potential or perceived conflict will constitute a material personal interest requiring the mandatory procedure in section 9.
For other conflicts, CHP may determine an appropriate and proportionate management response.
This may include:
Recording the conflict but taking no further action where it is minor or immaterial.
Allowing the person to provide relevant factual information.
Preventing the person from participating in particular discussions.
Requiring the person to abstain from a decision or vote.
Requiring the person to leave while a matter is considered.
Restricting access to confidential information.
Appointing another person to undertake the relevant responsibility.
Obtaining independent advice or quotations.
Reassigning particular duties.
Removing the person from involvement in the matter.
In determining the appropriate response, CHP may consider:
The nature of the conflict.
The significance of the interest.
The person's role.
The potential benefit or disadvantage.
Whether the person's involvement is necessary.
The importance of maintaining confidence in the decision.
Whether the conflict can reasonably be managed.
Where the Rules of Association impose a specific requirement, that requirement takes precedence over this discretionary process.
11. Providing Information Before Recusal
Where a Committee member is required to leave consideration of a matter because of a material personal interest, any necessary factual information from that person should, where practicable, be obtained before the Committee begins its consideration and decision-making on the matter, or by another appropriate means.
The Committee member must not use the provision of factual information as a means of improperly influencing the Committee's decision.
Once consideration of the matter begins, the requirements of the Rules of Association concerning the member's absence apply.
12. Contractors and Club Suppliers
CHP recognises that members, Committee members or people associated with CHP may operate businesses capable of providing useful goods or services to the Club.
Such a relationship does not automatically prevent CHP from engaging that business.
Where a Committee member or other decision-maker has an interest in a potential supplier or contractor:
The interest must be disclosed.
The conflicted person must not improperly influence the selection process.
The applicable recusal requirements must be followed.
The Committee should consider whether alternative quotations or comparisons are appropriate.
The engagement should be reasonable and demonstrably in CHP's interests.
The conflict and its management should be appropriately recorded.
CHP is not required to automatically reject the best supplier merely because a connection with a member or Committee member exists.
The important requirements are disclosure, appropriate management and a defensible decision made in CHP's interests.
13. Related-Party Transactions
Where CHP proposes to purchase goods or services from:
A Committee member.
A business owned or controlled by a Committee member.
A close family member of a Committee member.
Another person or business with a significant connection to a Committee member.
CHP should take additional care to ensure the arrangement is transparent and reasonable.
Depending upon the value and circumstances, appropriate safeguards may include:
Obtaining alternative quotations.
Recording why the supplier was selected.
Recording the nature of the relationship.
Ensuring the conflicted Committee member does not participate in the decision.
Recording the Committee resolution.
Periodically reviewing an ongoing arrangement.
The level of documentation should be proportionate to the value and significance of the transaction.
14. Gifts, Benefits and Hospitality
People acting on behalf of CHP must not solicit or accept gifts, benefits or hospitality where doing so could improperly influence, or reasonably appear to influence, a CHP decision.
Minor hospitality or gifts of nominal value may be accepted where:
Reasonable in the circumstances.
Not intended to influence a decision.
They create no material obligation.
Acceptance would not reasonably damage confidence in CHP's decision-making.
Significant gifts or benefits connected with CHP business should be disclosed to the President or Secretary and recorded where appropriate.
15. Confidentiality
Information disclosed under this policy will be handled as confidentially as reasonably practicable.
Information concerning a conflict may be shared where reasonably necessary to:
Assess the conflict.
Determine how it should be managed.
Make or review a Club decision.
Maintain appropriate records.
Obtain legal, governance or professional advice.
Comply with CHP's Rules of Association or applicable law.
Confidentiality does not prevent CHP from appropriately recording a declared conflict in Committee minutes or its Conflict of Interest Register.
16. Failure to Disclose
Failure to disclose a material conflict may constitute a breach of CHP policies or Rules.
Examples may include:
Knowingly failing to disclose a material financial interest.
Participating in a decision contrary to the Rules of Association.
Voting on a matter where the Rules prohibit participation.
Using confidential CHP information for personal benefit.
Improperly influencing a decision for personal, family or commercial benefit.
Providing materially false information about a conflict.
Deliberately concealing a relevant interest.
Where a possible undisclosed conflict is identified, the person concerned should ordinarily be given an opportunity to explain the circumstances before an adverse finding is made.
17. Breaches and Outcomes
A suspected breach may be considered under CHP's:
Rules of Association.
Code of Conduct.
Member Protection Policy.
Committee Protection Policy.
Complaint Handling Process.
Other applicable policies.
Non-disciplinary outcomes may include:
Guidance or education.
Requiring disclosure of the interest.
Requiring appropriate management of the conflict.
Removal from involvement in a particular decision.
Reassignment of a delegated responsibility.
Review or reconsideration of an affected decision where appropriate.
Where CHP proposes formal disciplinary action against a member, including a formal reprimand, suspension of membership rights or expulsion, the disciplinary procedure contained in CHP's Rules of Association must be followed.
This policy does not create an alternative disciplinary procedure.
18. Effect on Decisions
The discovery of an undisclosed or improperly managed conflict does not necessarily mean that a previous CHP decision is automatically invalid.
CHP should consider:
The significance of the conflict.
Whether the conflicted person's participation materially affected the decision.
The requirements of the Rules of Association.
Applicable law.
Whether the decision should be reconsidered without the conflicted person's involvement.
Whether independent or professional advice should be obtained.
Where appropriate, the Committee may reconsider the matter through a properly constituted and conflict-free decision-making process.
19. Raising Concerns About Another Person's Conflict
A person who reasonably believes that another person may have an undisclosed conflict may raise the matter with the President or Secretary.
The concern should identify, where possible:
The decision or matter involved.
The nature of the suspected conflict.
Relevant supporting information.
The existence of a personal relationship, business interest or association does not automatically establish wrongdoing.
CHP will consider whether a relevant conflict exists and how it should be managed.
Knowingly making a materially false or malicious allegation about another person's interests may itself be considered under applicable CHP policies.
A concern that is raised genuinely but ultimately not established is not, merely for that reason, a false or malicious allegation.
20. Committee Positions and External Interests
Committee members are not prohibited from:
Operating businesses.
Coaching pickleball.
Working for sporting organisations.
Belonging to other pickleball clubs.
Participating in tournaments.
Holding roles in other community organisations.
Having personal relationships with CHP members.
These circumstances do not automatically constitute inappropriate conflicts.
The relevant question is whether the external interest creates an actual, potential or perceived conflict in relation to a particular CHP responsibility or decision.
Where it does, the interest must be disclosed and appropriately managed.
21. Relationship With Other Policies
This policy should be read together with:
CHP Rules of Association.
CHP Code of Conduct.
CHP Member Protection Policy.
CHP Committee Protection Policy.
CHP Complaint Handling Process.
CHP Privacy Policy, where applicable.
Other applicable CHP governance policies.
22. Relationship With the Rules of Association
This policy operates subject to the Central Highlands Pickleball Club Incorporated Rules of Association and applicable law.
Nothing in this policy is intended to limit, replace or override a conflict-of-interest requirement, duty, right or procedure established by the Rules of Association or applicable law.
Where there is any inconsistency, the Rules of Association and applicable law prevail.
23. Policy Administration
The President and Secretary will ordinarily oversee the operation of this policy and maintenance of the Conflict of Interest Register.
This policy will be reviewed annually or earlier where required because of:
Changes to legislation.
Changes to CHP's Rules of Association.
Changes to governing-body requirements.
Changes to CHP operations.
Governance issues identified by the Committee.
Lessons arising from an actual conflict.
24. Acknowledgement
Committee members and other people exercising significant decision-making authority on behalf of CHP are expected to understand and comply with this policy.
By accepting such a role, a person acknowledges their responsibility to:
Act appropriately when performing CHP duties.
Identify relevant conflicts.
Disclose conflicts promptly.
Comply with applicable management measures.
Comply with mandatory recusal requirements.
Avoid improperly using their CHP position or confidential information for personal benefit.
Final Principle
Conflicts of interest are not inherently wrongdoing.
In a community sporting club, personal, professional, commercial and sporting relationships will naturally overlap.
CHP's approach is based on:
Declare it. Record it. Manage it.
Where a Committee member has a material personal interest, CHP will apply the mandatory requirements of its Rules of Association.
For other conflicts, CHP will use reasonable and proportionate measures to ensure decisions remain transparent, defensible and in the best interests of the Club.
Central Highlands Pickleball Club Incorporated (CHP)
Version: 1.1
Effective Date: September 2025
Last Review Date: August 2026
Responsible Body: CHP Committee
Approved by: CHP Committee
Review: Annually or as required