In some cases, officers may not disclose a conflict of interest as they have failed to recognise it or have concealed it.
Authorities should be alert to any red flags that may indicate undisclosed conflicts of interest such as officers:
- having overly close relationships with suppliers and/or contractors
- not sharing tasks and activities related to particular suppliers, contractors or stakeholders
- receiving gifts, benefits and hospitality
- avoiding taking leave
- having a family member who has a business that is related to the authority’s functions.
Other ways to detect undisclosed conflicts of interest include:
- evaluating internal reports and stakeholder complaints
- analysing data to identify suspicious transactions or relationships
- reviewing gifts, benefits and hospitality registers
- reviewing information accessed by officers
- reviewing internal audit reports to identify any areas for further scrutiny or improvement (for example, use of non-approved suppliers).
This is not an exhaustive list so authorities should consider other ways to detect undeclared conflicts of interest that suit their operating context and risks.
