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KindPath Collective Inc

Conflict of Interest Policy

Version 1.0 | Effective: 29 August 2026 | Review: 29 August 2027 | Owner: Director

1. Purpose

To identify and manage situations where a personal, family, or financial interest could conflict — or appear to conflict — with KindPath’s obligations to a participant or to the organisation.

2. Legislative and standards basis

  • Associations Incorporation Act 2009 (NSW) — committee member conflict of interest disclosure obligations.
  • NDIS Practice Standards, Module 2: Governance and Operational Management — Conflict of interest.
  • NDIS Code of Conduct.

3. Policy statement

KindPath discloses conflicts of interest rather than hiding or minimising them, and manages disclosed conflicts through documented, proportionate controls rather than pretending independence exists where it doesn’t.

KindPath’s most significant current conflict of interest is structural and already known: the Director is also a direct support worker for at least one participant, and the Director’s spouse is engaged (informally, at present) as a support worker for the same participant. This is not treated as a problem to hide — it is disclosed here and managed through the controls below. The Director is not, and should not act as, the sole check on their own family member’s practice with a participant — this is precisely the gap the Human Resource Management Policy’s supervision requirements, and this policy’s escalation pathway, exist to address.

4. What must be disclosed

  • Any family or close personal relationship between a worker and a participant (or a participant’s family).
  • Any financial interest a worker or the Director has in a participant’s choices (e.g. being paid privately by a participant for services alongside NDIS-funded support, as currently occurs).
  • Any situation where a worker’s personal relationships could affect their objectivity in decisions about a participant’s support, funding use, or safeguarding.

5. Procedure

  1. Conflicts are disclosed to the Director (or, for a conflict involving the Director, noted for the committee once active, and in the interim, documented transparently in this register with reasoning for how it’s managed) as soon as they’re identified — not after something goes wrong.
  2. Every disclosure is logged in the Conflict of Interest Register (Module 6): who, the nature of the interest, and how it’s managed.
  3. Management options include: independent oversight of the specific decision or relationship (e.g. a third party involved in reviewing a specific participant's support arrangements where a family relationship is involved), recusal from a specific decision, or — where a conflict cannot be adequately managed — ending the specific arrangement.
  4. Private financial arrangements between a worker and a participant that sit alongside NDIS-funded support (for example, being paid personally for music production work) are disclosed, kept clearly separate from NDIS claims, and reviewed to ensure they don’t create pressure on the participant or blur what is a funded support versus a personal arrangement.

6. Roles and responsibilities

  • Director: maintains the register; actively seeks independent input on conflicts involving themselves or their family, rather than self-assessing alone.
  • Workers: disclose conflicts proactively.

7. Related documents

Conflict of Interest Register (Module 6) · Governance Charter Summary · Human Resource Management Policy

8. Review

Annually, and whenever a new conflict arises.