Conflict of Interest
At Hosanna Community Care, we take conflicts of interest seriously. We are committed to transparency, fairness, and protecting participant choice and control. This policy outlines how we manage any potential conflicts to ensure services remain unbiased and participant-centred.

What Is a Conflict of Interest?

A conflict of interest arises when a staff member’s personal interests (or those of their family or friends) might influence their work decisions. This can be real, possible, or even just perceived, and all are important to manage across both our NDIS and aged care services.

Why It Matters?

Under the NDIS Code of Conduct, Practice Standards, and Aged Care Code of Conduct, providers must act with honesty, integrity, and fairness. Conflicts must be declared and managed so that participants and consumers can make informed choices about their supports and services.

Examples of Conflicts of Interest:

– A worker supporting a friend or relative without disclosure
– Offering only Hosanna services without presenting alternatives
– Accepting money or gifts for referrals or decisions
– Investigating a complaint involving a friend or relative
– Managing services for someone you have a personal or financial relationship with
Recommending aged care services when also providing NDIS supports (dual service conflicts)
Financial interests in recommended service providers or equipment suppliers

How We Manage Conflicts of Interest

  1. Immediate Declaration: All staff must report conflicts of interest as soon as they are aware of them.
  2. Documentation: All conflicts are recorded in our Conflict of Interest Register.
  3. Risk Management: We take steps to reduce risk, including:
    – Changing staff duties or reassigning cases
    – Limiting access to information
    – Making referrals to alternative services
    – Ensuring all advice is impartial and in the participant’s/consumer’s best interest
    Regular six-monthly reviews of all declared conflicts
  4. Transparency: We maintain openness with participants and consumers about any conflicts that may affect their services.

Special Situations

If a participant/consumer asks a worker to be their advocate: We explain the conflict and record it. Participants may still choose their own advocate, but we ensure they understand the implications.

If Hosanna provides multiple services (NDIS + Aged Care):
– We inform the participant/consumer about potential conflicts between service types
– We offer other provider options
– We document participant/consumer choices and confirm they’re made freely
– We record this in our Conflict of Interest Register
We report the conflict to the NDIS Commission and/or Aged Care Quality and Safety Commission if required

If Hosanna provides both Support Coordination and direct services:
– We inform the participant about the potential conflict
– We offer other provider options
– We document participant choices and confirm they’re made freely
– We record this in our Conflict of Interest Register
– We will report the conflict to the NDIS Commission if required or requested

Gifts, Fees and Commissions

Hosanna workers cannot accept money, gifts, or commissions that could affect their work decisions. We do not give or receive referral fees from any service providers, whether NDIS-registered providers, aged care services, or other community organizations.

Your Rights

As a participant or consumer, you have the right to:
– Be fully informed about any conflict of interest that may affect your services
– Make decisions free from pressure
– Change providers if needed
Access advocacy support to help understand conflicts and your options
Have a Registered Supporter assist with decisions (aged care consumers from November 1, 2025)
– Give feedback or make complaints without fear of negative consequences
Protection from retaliation if you raise concerns about conflicts

Reporting and Oversight

Internal Process:
– All conflicts documented in the Conflict of Interest Register
– Regular management review and risk assessment
Six-monthly declaration updates required from all staff

External Oversight:
NDIS Quality and Safeguards Commission: 1800 035 544 (for NDIS-related conflicts)
Aged Care Quality and Safety Commission: 1800 951 822 (for aged care-related conflicts)

Quick Summary

– We manage conflicts to protect your rights across all services
– You’ll be informed if a conflict exists that may affect you
– You’ll always have choices and alternatives
– Staff must report any conflicts immediately
Six-monthly reviews ensure ongoing transparency
– No gifts or commissions allowed from any service providers
– You can contact the relevant Commission or an independent advocate for support