Disclosure of Interest Framework

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.

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 (including a new eForm introduced in 2025)
• 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 has been delayed)

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 Corporate Governance and Risk Office has developed a new eForm to be used in conjunction with the PDF forms outlined below. The Disclosure of Interest eForm can be accessed here.

The DOI Flowchart is now split into two options, being Option A and Option B.

The eForm, Option A,  can be used for all new disclosures and is designed for low risk declarations or situations when you are unsure. Should any additional information be required, the Corporate Governance and Risk Office will be in touch via email to request you complete some or all of the forms under Option B.

Alternatively, hard copy Disclosure of Interest Forms 1 through 6 (Option B) can be used, they include:

• Form 1 – Interest Disclosure Form
• Form 2 – Interest Risk Assessment Form
• Form 3 – Interest Management Plan Form
• Form 4 – Conflict Permission Form
• Form 5 – Interest Review Form
• Form 6 – 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 was due to begin in 2024 but has been delayed. 

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.