Disclosure of Interest Framework

The Disclosure of Interest (DOI) Framework supports the identification, disclosure, and management of interests of ANU representatives that may create risk to the University and its staff. This includes any interest external to the University, to ensure the University maintains sufficient visibility over interests that have a potential to create risks or conflicts of interest.

The DOI Framework, which replaced the previous Conflict of Interest Framework, was approved for implementation by the Vice-Chancellor as endorsed by the Senior Management Group in September 2022 and will be fully implemented over coming months.

Guiding Principles

The 3 guiding principles of the DOI framework are:

• Simplicity: Easy to use for anyone, regardless of their background knowledge of similar frameworks or governance processes.
• Accessibility: Easily accessible and centrally located so all staff have ready access to the Framework and can utilise its functions/capabilities.
• Effectiveness: The Framework captures meaningful information, and ensures that that information is used to create comprehensive and insightful reports to key stakeholders that inform key decisions where necessary.

Key Elements

There are multiple key elements of the Framework, including:

• Policy, procedure and guidelines
• Forms (which will transition to a single digital capture portal in 2024)
• Supporting documentation (such as infographics, roadmaps and a Privacy Impact Assessment - currently under development)
• Structured processes (such as an annualised disclosure process for all staff to engage with via HORUS - to be implemented in 2024)

How to Disclose

Information on the disclosure process is provided in the Disclosure of Interest Policy, Procedure and Guidelines linked to this page.  In addition, a DOI Flowchart has been provided which summarises the process of disclosing your interest, assessing risk and, if necessary, managing that risk.  

The following Disclosure of Interest Forms are also provided (as referenced in the Flowchart):

• Interest Disclosure Form
• Interest Risk Assessment Form
• Interest Management Plan Form
• Conflict Permission Form
• Interest Review Form
• Additional Information Form

Completed disclosure forms should be sent to disclosure@anu.edu.au for inclusion on the Central Interest Register.

Future Steps and Development

The DOI Framework was approved for implementation by SMG in September 2022 and an implementation plan will be developed by CGRO to ensure that the University community is aware of the Framework and how to interact with it.

The Corporate Governance and Risk Office is working with HRD and ITS to develop an online portal which will enable staff to declare interests via HORUS, and will also facilitate a central data repository, so corporate knowledge related to interests is both preserved and accessible. Development of this portal will begin in 2024.

A privacy impact assessment (PIA) will be undertaken with the University’s Privacy Officer to produce a publicly available PIA, ensuring that all relevant legislation, standards and principles are being adhered to with the collection, storage and use or any data obtained via the operation of the framework.

Where emerging risks are identified, and are seen as significant enough to warrant inclusion in the framework, CGRO will review such risks to evaluate how to best implement language or amend documents to address such risks appropriately.

The tools that the Framework will ultimately develop will support the University to manage risks associated with foreign interference, creating an environment where staff are supported to make disclosures and manage their interests appropriately.