Conflict of Interest Policy

1. Purpose and Scope

Steady Guide is committed to acting with integrity, honesty and transparency. We provide NDIS Support Coordination and Case Management services, and we take conflicts of interest seriously because

they can affect a participant’s choice, control, and trust in the support they receive. You can read the Easy Read Version here.

This policy explains how we:

  • identify conflicts of interest

  • disclose them clearly and early

  • manage them in a way that puts participants first.

This policy applies to everyone working for, with, or representing Steady Guide, including:

  • the business owner/principal

  • employees

  • contractors and consultants

  • students/placements (if applicable)

  • key personnel

  • any person acting on behalf of Steady Guide.

It applies to all interactions with NDIS participants, their families, carers, nominees, and other providers.

2. Definitions

To keep this policy clear and practical, these words mean:

  • Conflict of interest: a situation where personal interests, relationships, or business interests could influence (or look like they could influence) the advice, recommendations, or decisions we make

    for a participant.

    • Actual conflict of interest: a conflict that is happening now (for example, a decision could directly benefit Steady Guide or a staff member).

    • Potential conflict of interest: a conflict that could happen in the future (for example, a relationship or interest that may later affect a decision).

    • Perceived conflict of interest: a situation that could reasonably look like a conflict to someone else, even if it does not influence what we do.

  • Sharp practice: unethical, unfair, or unscrupulous conduct that is not in a participant’s best interests. It can include misleading conduct, taking advantage of vulnerability, or using pressure or confusing information to gain a business benefit.

  • Cross-selling: pressuring, encouraging, or steering a participant to purchase another service or product from Steady Guide (for example books, guides, training, or other paid offerings) as part of, or because of, support coordination or case management.

  • Bundling services: requiring a participant to accept multiple services or products together, or making one service conditional on buying another (for example “you can only get support coordination if you also buy our resources”).

  • Over-servicing: delivering or recommending more supports, appointments, hours, or activities than a participant needs, to maximise plan spend or provider revenue (rather than what is reasonable, necessary, and aligned to goals).

  • Backroom deals: secret or undisclosed arrangements with other providers (or organisations) where referrals, pricing, services, or decisions are influenced for mutual benefit (especially financial benefit) instead of the participant’s best interests.

  • Business Partner — Any individual or entity that holds an ownership interest in, or is a director, key personnel, or decision-maker of, Steady Guide. This includes any future partners who join the business.

  • Inducements and gifts: anything offered or received that could influence (or look like it could influence) decisions or referrals. This includes gifts, cash, discounts, commissions, referral fees, kickbacks, hospitality, or other benefits.

Referral pathways: the process and relationships involved in connecting participants with other supports and services (for example allied health, support workers, plan managers, or community programs). Referral pathways must support choice and control and must not be influenced by personal gain.

3. Legal framework

Steady Guide aims to meet all relevant NDIS and legal obligations, including:

  • NDIS Code of Conduct
    Especially the requirement to act with integrity, honesty and transparency (including in how we manage conflicts of interest and referrals).

  • NDIS Practice Standards
    Including the Core Module — Governance and Operational Management (effective governance, ethical conduct, and risk management) and the Specialist Support Coordination Module — Conflict of Interest outcome (identifying, disclosing, and managing conflicts so participant choice and control is protected).

  • NDIA Position Statement on Conflicts of Interest in the NDIS Provider Market
    Including expectations that providers avoid “sharp practice”, disclose conflicts, and support participants to make free and informed decisions.

  • Corporations Act 2001 (Cth) — director duties
    Where relevant, including duties to act in good faith, for a proper purpose, and to avoid improper use of position or information.

4. Our commitment

Steady Guide is here to support participants to live their best lives, with real choice and control. We commit to:

  • Putting participants first, always
    Our advice and actions are guided by what is best for the participant, not what is easiest or most profitable.

  • Keeping a low-caseload model
    We cap our caseload at 20 participants so we can give each person dedicated attention, thoughtful planning, and reliable follow-up.

  • Providing a neuroaffirming, sensory-friendly environment
    We aim to be calm, respectful, accessible and trauma-informed, including in how we communicate and how we run our office.

  • Offering options (not just one recommendation)
    Wherever possible, we will provide at least 3 suitable support/service options, based on participant preferences, location, availability, cultural safety, and goals.

  • No pressure, no rushing
    We do not pressure participants into decisions. We give time, space, and clear information so choices are made freely.

  • Building capacity and self-advocacy
    We support participants to understand their plan, build skills, and speak up for their needs—so they can make informed decisions now and in the future.

5. Prohibited conduct

Steady Guide does not tolerate conduct that undermines participant choice and control or damages trust in the NDIS. The following are explicitly prohibited:

5.1 Sharp practice

We will not engage in unethical, misleading, deceptive, unfair, or unscrupulous conduct, including taking advantage of a participant’s vulnerability, disability, stress, or lack of information.

5.2 Cross-selling

We will not pressure (or repeatedly encourage) participants to buy other services or products from Steady Guide as part of, or because of, support coordination or case management.

5.3 Bundling services

We will not require a participant to accept multiple services/products as a condition of receiving support coordination or case management. Support coordination/case management is not conditional on buying anything else.

5.4 Over-servicing

We will not deliver, recommend, or claim for supports just to use up funding or increase revenue. Supports should be reasonable and necessary, aligned to the plan, and match the participant’s goals and preferences.

5.5 Backroom deals

We will not enter into secret arrangements with other providers that influence referrals, service decisions, pricing, or access, especially where there is a mutual financial benefit.

5.6 Inducements, kickbacks, commissions, and gifts linked to referrals

We will not offer or accept inducements that could influence (or appear to influence) referrals or recommendations, including:

  • kickbacks or referral fees

  • commissions or “spotter’s fees”

  • gifts or hospitality that create an expectation of referrals

  • discounts or benefits provided in exchange for steering participants.

5.7 Provider steering due to personal relationships

We will not recommend or require participants to use specific providers because of personal relationships, friendships, family ties, or business interests. If a relationship exists, it must be disclosed, and the participant must be supported to consider alternatives.

5.8 Acting as a plan nominee while also providing support coordination

We will not act as a participant’s plan nominee while also providing support coordination/case management unless we have been legally appointed (for example by the NDIA or a court/tribunal where applicable). If this situation arises, we will disclose it and ensure safeguards are in place to protect the participant’s choice and control.

6. Referral Pathways

Like many support coordination providers, Steady Guide uses referral pathways with other NDIS providers — including disability support organisations, allied health professionals, and plan managers — to help participants find us. These referral pathways are an essential part of how participants in and around Toowoomba learn about Steady Guide, as general advertising (such as market stalls) has proven less effective in reaching people who need personalised support coordination.

To ensure full transparency, Steady Guide publishes a list of its active referral pathway partners on our website at steadyguide.com.au. Participants can view these relationships at any time.

When Steady Guide establishes a referral pathway with another provider, we do so with the clear expectation that:

  • The referring provider will offer the participant at least two other support coordination options alongside Steady Guide, ensuring genuine choice and control.

  • The referral is made in the participant's best interests, based on their needs and goals — not because of any benefit Steady Guide or the referring provider may receive.

  • No kickbacks, commissions, referral fees, or reciprocal referral arrangements are involved, consistent with our prohibition on inducements.

From a participant's perspective, being referred through one of these pathways means:

  • You will be told about the relationship between Steady Guide and the referring provider.

  • You will be offered other support coordination options to consider alongside Steady Guide.

  • You are free to choose whichever provider best meets your needs, with no pressure or influence.

These referral pathways do not reduce your rights under this policy. All other sections — including our commitments to disclosure, choice and control, and prohibitions on sharp practice — apply fully.

7. Disclosure and declaration (how conflicts are managed)

We manage conflicts of interest by being upfront, documenting them, and putting safeguards in place.

7.1 Immediate disclosure

All real, potential, or perceived conflicts of interest must be disclosed as soon as they are identified.

This includes conflicts held by Steady Guide, staff, contractors, and anyone acting on our behalf.

7.2 Documenting conflicts

All disclosures are recorded using our Conflicts of Interest Declaration form, stored securely and recorded in the Conflicts of Interest Register. We also document the steps taken to manage the conflict (for example, providing extra options, seeking independent input, or removing the person from the decision).

7.3 Clear information for participants (plain language)

If a conflict relates to a participant, we will tell the participant:

  • what the conflict is

  • why it matters

  • what options they have

  • what we will do to manage it.

We will explain this in plain language, and in the mode of communication that works best for the participant (for example in writing, verbally, with visuals, or with support people present where consent is given).

7.4 Time and space to decide

Participants will be given time and space to consider options free from influence. This includes the option to:

  • choose a different provider

  • seek independent advice

  • have a support person present

  • pause and come back to the decision later.

8. Participant rights

Participants have the right to:

  • Ask about conflicts of interest
    You can ask us at any time if we have any relationship, benefit, or interest connected to a recommendation.

  • Get a list of other options
    You can request a list of alternative provider options, and we will provide options wherever possible.

  • Choose any provider they want
    You can choose any provider, even if Steady Guide has worked with them before, has a relationship with them, or does not know them.

  • Make a complaint without fear
    You can raise a concern or complaint without it affecting your supports or the way we treat you. We take feedback seriously.

  • Contact the NDIS Quality and Safeguards Commission
    If you are unhappy with how a conflict of interest has been handled, you can contact the NDIS Quality and Safeguards Commission.

9. Governance and review

This policy is reviewed at least annually, and sooner if needed, to reflect changes in NDIS requirements, guidance, and best practice. We also update this policy if we identify improvements through feedback, audits, complaints, or incidents.

10. Future Business Partners and Ownership Changes

Steady Guide may take on a business partner in the future. Any prospective or incoming partner will be required to:

  • Disclose any existing relationships with NDIS providers, participants, or support networks that could create a real, potential, or perceived conflict of interest.

  • Sign a declaration acknowledging their obligations under this policy and the NDIS Code of Conduct.

  • Participate in conflict of interest training as part of their onboarding.

If a business partner has a personal, financial, or professional relationship with a provider that Steady Guide refers participants to, this relationship must be disclosed to participants and documented in the Conflicts of Interest Register. The same transparency and disclosure requirements that apply to all Steady Guide personnel apply fully to business partners.

Participants will be informed of any change in ownership or partnership structure through an update to this policy and a notice on our website.

Contact Information
For questions about this policy, to declare a conflict, or to raise a concern, please contact:
Steady Guide
Website: steadyguide.com.au
Email: jenny@steadyguide.com.au
Location: Toowoomba, QLD