1. Purpose and Scope
The purpose of this policy is to assist members of staff and the Board of Directors to effectively identify, disclose and manage any actual, potential or perceived conflicts of interest, in order to protect the integrity of Nemean Group Pty Ltd (“Nemean or “the Company”) and manage risk.
This policy applies to directors and staff members of Nemean.
2. Policy
It is Nemean’s policy that the directors and staff must:
- avoid positions of conflict or potential conflict:
Accordingly, all Nemean directors and staff must avoid placing themselves in a situation that could be or may lead to a conflict of interest or duty, or a reasonable perception of an actual or potential conflict of interest or duty.
- disclose any material personal interest as soon as practicable;
All Nemean directors must fully and frankly disclose to the Board of Directors material personal interests that relate to the affairs of the Company or external business interests that may lead to an actual or potential conflict of interest or duty, or a reasonable perception of an actual or a potential conflict of interest or duty; and
All Nemean staff must fully and frankly disclose to the Chief Executive Officer (CEO) any material personal interests that related to the affairs of the Company or external business interests that may lead to an actual or potential conflict of interest or duty, or a reasonable perception of an actual or a potential conflict of interest or duty.
3. Definition of Conflict of Interest
A conflict of interest occurs when a member of staff or Board member’s personal interests conflict with their responsibility to act in the best interests of the Company. Personal interests include direct interests as well as those of family, friends, or other organisations, a staff or Board member may be involved with or have an interest in. It also includes a conflict between a staff or Board member’s duty to Nemean and that of another duty outside of the Company. A conflict of interest may be actual, potential or perceived and may be financial or non-financial.
These situations present the risk that a person will make a decision based on, or affected by, these influences, rather than in the best interests of the Company and must be managed appropriately.
4. Avoiding Conflicts of Interest
Conflicts of interest can be avoided by:
- Disclosing their existence / potential existence as soon as practicable;
- Removing the conflicted person from the decision making / assessment / negotiation process; or
- Any other method considered appropriate by the Board/CEO of the relevant entity affected by the conflict or potential conflict.
5. Responsibilities
Directors and staff members of Nemean are responsible for
- Being aware of their obligations to avoid, where possible, conflicts of interest;
- Assessing if their personal and business interests conflict or have the potential to conflict with the discharge of their duties as a director or staff member;
- Formally disclosing all actual and potential conflicts of interest; and
- Complying with any other requirements of this policy.
The Company shall maintain a register of conflicts.
6. Compliance with this Policy
If the Board and CEO has a reason to believe that a staff member subject to the policy has failed to comply with it, it will investigate the circumstances.
If it is found that this person has failed to disclose a conflict of interest, the Board may take action against them, which may include termination of employment.
If a staff member suspects that a Board member has failed to disclose a conflict of interest, they must notify the CEO, or the person responsible for maintaining the register of interests.
7. Privacy
Nemean recognises that the reporting of potential or actual conflicts of interests and duty may involve disclosing personal information. This information will be handled in accordance with Nemean’s Privacy Policy, which is available on our website.
8. Contact
For questions about this policy, please contact:
Dr Thomas Duthy
Founder & CEO
Nemean Group Pty Ltd
tduthy@nemean.com.au
Ph: +61 (0)8 7088 4826