Conflict of Interest Policy and Register

1. Purpose

Axiom Data is a small, director-led firm that competes for Commonwealth labour-hire work, partners with other sellers, and places people into agencies where its own directors may also work. That makes conflicts of interest a normal feature of our business rather than a rare one. This policy exists so that every conflict is identified early, written down, disclosed to whoever needs to know, and managed in a way that a client or auditor can see.

2. Scope and application

This policy applies to Ontology Analytics Pty Ltd, trading as Axiom Data (Axiom Data) and to every director, employee, labour-hire worker, contractor and agent engaged by Axiom Data, whether working at Axiom Data's premises, remotely, or on placement at a client site. Where a worker is placed with a client, this policy applies alongside the client's own policies; where the two differ, the worker follows the stricter requirement and raises the difference with Axiom Data.

3. What is a conflict of interest

All three types must be declared and recorded. The test is not whether the person believes they can act impartially; it is whether an outsider could reasonably doubt it.

4. Standing disclosure: directors engaged through other providers

Controls applied to this arrangement:

• The Director holds no role in any Commonwealth procurement, evaluation or contract-management decision in respect of Axiom Data or any other seller.
• Axiom Data does not use, and the Director does not disclose, any non-public information obtained in the course of his agency engagement for the benefit of Axiom Data, its candidates or its partners.
• Where Axiom Data responds to an RFQ from an agency at which a director is personally engaged, the response discloses the arrangement in writing, and the candidate-level financial-interest question is answered truthfully for every candidate.
• The Director does not assess, rank or submit himself as a candidate to any agency where the engagement would overlap with his existing contract without first disclosing the arrangement to that agency.
• The arrangement is reviewed before every RFQ response and at the annual policy review, and the register entry is updated when the engagement changes or ends.

5. Declaring a conflict

1. On engagement: every director, employee and placed worker completes a conflict of interest declaration, declaring any interest, relationship or outside engagement that could conflict with their duties, or confirming that they have none.
2. When circumstances change: a new declaration is made within five business days of the person becoming aware of a new or changed interest.
3. Before each RFQ response: the Director confirms that the register is current and that any conflict relevant to the buyer has been disclosed in the response.
4. Annually: declarations are refreshed at the policy review.

Declarations are made in writing to the Director using the form on the Employee Resources page, or by email to [email protected]. A declaration concerning the Director is made to, and assessed by, an independent adviser nominated by the company (its external accountant or legal adviser), whose assessment is recorded on the register.

6. The Conflict of Interest Register

The register is maintained by the Director, stored with the company's governance records, and records for each declared interest: the person; the nature of the interest; whether it is actual, potential or perceived; the date declared; the assessment; the management actions decided; who the interest has been disclosed to; and the date of the next review. Register entries are retained for seven years after the interest ceases.

7. Managing a conflict

Management actions are chosen to match the risk and are recorded on the register. They include, in increasing order:

• Record and monitor: the interest is noted and reviewed periodically.
• Disclose: the affected client, partner or candidate is told in writing.
• Restrict: the person is excluded from the relevant decision, assessment, submission or information.
• Independent review: a decision touched by the interest is checked by someone without the interest.
• Remove: the person withdraws from the engagement or, where the conflict cannot otherwise be managed, from the interest.

8. Gifts, benefits and hospitality

Gifts, benefits and hospitality from clients, candidates, partners or suppliers with a value over $100, or of any value where they could be seen to influence a decision, must be declined or declared and recorded on the register. Cash or cash equivalents are never accepted. Nothing is offered to a Commonwealth official beyond modest hospitality consistent with the official's own agency rules.

9. Breaches of this policy

A breach of this policy is a serious matter. Depending on the circumstances it may result in counselling, a written warning, removal from a client placement, termination of employment or engagement, and, where the law requires, referral to the relevant authority. Axiom Data will not take adverse action against anyone for raising a genuine concern in good faith.

10. Review

This policy is owned by the Director and is reviewed at least annually, and sooner if legislation, a client requirement or an incident shows the need. The current version, effective date and next review date are recorded in the policy register on the Employee Resources page.