Conflicts of interest — named openly.

Effective: 20 May 2026

1. Purpose

Nurtured Spark Pty Ltd is committed to delivering services fairly, transparently and impartially. This Conflict of Interest Policy explains how we identify, disclose and manage situations where a personal interest of a director, employee or contractor could compete with their professional duty to a participant or to the organisation.

The policy helps us meet our obligations under the National Disability Insurance Scheme (NDIS) Code of Conduct and the NDIS Practice Standards, the Australian Association of Social Workers (AASW) Code of Ethics (2020), and the professional standards of any other regulator that applies to our staff.

2. Scope

This policy applies to every person performing work for Nurtured Spark — directors, employees, contractors, students, and volunteers — whether paid or unpaid. It covers all the services we deliver: NDIS supports, Department of Veterans' Affairs (DVA) Veteran Social Work, and Private Senior Care.

3. What is a conflict of interest?

A conflict of interest arises when an individual's private interests interfere with, or could reasonably be seen to interfere with, their professional duties. Conflicts can be:

• Actual — a direct conflict between current duties and an existing private interest.
• Perceived — where it could reasonably appear that private interests are influencing professional decisions, even if they are not.
• Potential — where a private interest could foreseeably conflict with future duties.

Conflicts may be financial (pecuniary) or non-financial.

3.1 Examples of financial interests

• Holding shares in, or being a director of, another disability or healthcare provider.
• Receiving commissions, kick-backs, or referral incentives.
• Secondary employment with another provider, plan manager or support coordinator.
• A family member's financial interest in a business we transact with.

3.2 Examples of non-financial interests

• Personal, family or close friendship relationships with a participant, their family, or another provider.
• Acting as both a participant's social worker and their support coordinator, or as their plan manager.
• Obligations to professional, community, cultural or religious groups that touch on a participant's life.
• Strong personal views about a service direction that could colour clinical judgement.

4. Conflicts specific to social work and disability practice

Social work and disability practice carry particular risks because of the nature of the relationship — the imbalance of information, the intimacy of home-based care, and the small communities we operate in. We are guided here by the AASW Code of Ethics and Sections of the NDIS Practice Standards covering conflicts of interest, governance and risk management.

We are proactive about disclosure. If a staff member is unsure whether a relationship or interest amounts to a conflict, they are required to raise it with a director before acting, not after.

5. Identifying and disclosing conflicts

Every staff member must:

1. Identify actual, perceived and potential conflicts at the earliest opportunity.
2. Disclose them in writing to the Directors using our Conflict Disclosure Form.
3. Update the disclosure whenever circumstances change.
4. Make disclosures during onboarding, at every annual review, and at the start of any new participant engagement that might create a conflict.

The Directors maintain a confidential Register of Interests recording each disclosed conflict, its nature, and how it is being managed. Access to the register is restricted to those who need it.

6. Managing disclosed conflicts

Once a conflict is disclosed, the Directors decide on the appropriate management strategy. Options include:

• Avoidance — declining or transferring the engagement.
• Restriction — limiting the staff member's involvement in particular decisions or sessions.
• Recusal — the staff member steps out of relevant meetings, decisions, or votes.
• Removal — ending the activity that gives rise to the conflict.
• Disclosure to the participant — with their informed consent to continue.
• External supervision — for clinically complex situations.

The chosen approach is recorded in the Register of Interests along with the date and the responsible director.

7. Specific commitments to participants

• No undisclosed referral fees. We do not pay or receive commissions for client referrals in or out.
• Limit on internal referrals. Where Nurtured Spark could provide an additional service ourselves, we will tell the participant about other suitable options. We cap referrals retained inside Nurtured Spark to no more than 25% of total external referral opportunities for any given participant need, and we document the reason for any internal referral.
• Separation of roles. Where the NDIS Practice Standards or AASW require a separation of support coordination, plan management and direct service provision, we keep those roles separate.
• Gifts and benefits. Staff must not accept gifts of more than nominal value from participants, families, suppliers or other providers. Anything beyond a token gift must be declared and either returned, donated, or recorded.
• Family and friend referrals. Where a staff member has a personal relationship with a prospective participant, the matter is reassigned to another staff member wherever possible.
• Secondary employment. Staff must disclose any concurrent paid or unpaid roles with other providers, plan managers, or peak bodies.

8. Directors' responsibilities

The Directors are responsible for:

• Maintaining a system for identifying, disclosing and managing conflicts across the organisation.
• Maintaining the Register of Interests and reviewing it at least every six months.
• Reviewing this policy annually and after any incident that highlights a gap.
• Ensuring staff are trained on this policy at induction and annually.
• Reporting notifiable conflicts to the NDIS Quality and Safeguards Commission or other regulators where required.

9. Confidentiality of disclosures

Information disclosed under this policy is kept confidential. It is shared only with the people who need to know in order to manage the conflict effectively, and is handled in line with our Privacy Policy.

10. Breaches of this policy

Failure to disclose a known conflict, or failure to follow an agreed management plan, is a serious matter. The Directors will investigate any suspected breach. Outcomes may include additional training, formal warning, removal from particular work, or termination of employment or contract. Where appropriate, we will also notify regulators such as the NDIS Quality and Safeguards Commission or AHPRA.

11. Raising a concern

Participants, families, colleagues and other providers can raise a concern about a possible conflict of interest at Nurtured Spark at any time. We will take it seriously, investigate fairly, and let you know the outcome. Concerns can be raised privately without affecting your services.

12. References

• Australian Association of Social Workers. (2020). Code of Ethics. aasw.asn.au.
• NDIS Quality and Safeguards Commission. NDIS Code of Conduct. ndiscommission.gov.au.
• NDIS Quality and Safeguards Commission. NDIS Practice Standards — Provider Governance and Operational Management.
• Office of the Australian Information Commissioner. Australian Privacy Principles. oaic.gov.au.
• Office of the Commonwealth Ombudsman. Conflict of Interest Guidelines.

13. Contact

For questions about this policy or to raise a conflict-of-interest concern, contact:

Directors, Nurtured Spark Pty Ltd
Email: admin@nurturedspark.com.au
Phone: 1300 677 166
Post: Nurtured Spark Pty Ltd, Metropolitan & Regional Victoria, Australia
ABN: 31 634 001 415