Steady Guide: Conflict of Interest Policy Report (Comprehensive Update)

💡 At a Glance & Governance Overview

⏱️ Estimated Read Time: 5 minutes

Central Takeaway: Steady Guide maintains a strict Conflict of Interest framework, enforcing the Three Provider Rule, Ethical Firewall protocols, and transparent governance to safeguard participant choice, control, and decision-making autonomy under NDIS regulations.

• Executive Mandate & Scope: Universal application across all staff and operations, aligned with NDIS Code of Conduct and Practice Standards (Core Module 2.1).
• Definitional Framework: Clear boundaries defining actual, potential, and perceived conflicts, sharp practices, cross-selling, and APP 6 personal information protection.
• Prohibited Conduct & Guardrails: Absolute bans on internal/external steering, referral fees, kickbacks, and service bundling.
• The Three Provider Rule: Mandatory presentation of a minimum of three independent provider options for every referral recommendation.
• Governance & Rights: Formal Conflict of Interest Register logging, APP 13 correction rights, 30-day response limits, and annual audit reviews.

1. Executive Mandate: Purpose, Scope, and Strategic Integrity

This policy report establishes the governance architecture required to maintain absolute integrity and transparency across all Steady Guide operations. In the interconnected ecosystems of regional Queensland, where reputation is our primary capital and word-of-mouth travels rapidly, this policy serves as a strategic bulwark against the erosion of community trust. For support coordination and case management providers, ethical rigour is not merely a box-ticking exercise; it is the core differentiator that protects our brand and ensures the longevity of our service model.

The scope of this policy is universal, applying to all personnel, contractors, and leadership. It explicitly governs situations where staff members hold external business, commercial, or personal interests. Our commitment to participant choice and decision-making autonomy is absolute and non-negotiable. This framework is meticulously aligned with the NDIS Code of Conduct and the NDIS Practice Standards, specifically Core Module 2.1 and the Specialist Support Coordination Module, ensuring the participant remains the primary architect of their own support journey.

To operationalise these values, we must first establish a definitive framework for identifying the landscapes in which conflicts arise.

2. The Definitional Framework: Navigating Conflict Landscapes

Precise terminology is the first line of defence against ethical breaches. By establishing a shared, robust vocabulary, Steady Guide ensures that every team member can identify risks before they manifest as breaches of trust.

These definitions provide the clarity required to enforce the strict commercial guardrails outlined in Section 5.

3. Section 5: Prohibited Conduct and Commercial Guardrails

Section 5 serves as a defensive moat, protecting participants from undue influence and maintaining the “arm’s length” relationship required by the National Disability Insurance Agency (NDIA). Steady Guide personnel must remain independent agents of the participant, never proxies for commercial interests.

Section 5.2: Prohibitions on Internal and External Steering Personnel shall not pressure, steer, or subtly encourage participants toward secondary offerings or external commercial ventures owned by staff or their immediate family members. All personnel must refrain from any conduct that compromises the perceived or actual independence of their recommendations.

These guardrails are formalised through the “Three Provider Rule,” which operationalises choice and control.

4. Section 6: Operationalising Choice via the “Three Provider Rule”

The referral process is the primary mechanism for upholding the NDIS principle of “Choice and Control.” To move this principle from theory into practice, Steady Guide mandates the “Three Provider Rule.”

Whenever a recommendation for a service, product, or provider entity is made, personnel must present a minimum of three independent options. This rule functions as a “safe harbor” for staff; by providing three distinct alternatives, the Support Coordinator shifts the burden of “choice” back to the participant. This process legally and ethically insulates the staff member from accusations of steering, ensuring participant autonomy remains paramount.

Staff must deliver the following assurance to every participant during the referral process:

Participant Assurance Statement

“My role is to support you in finding the best options for your needs. Your choice of provider—whether you choose one of these options or someone else entirely—will never affect the quality or level of support coordination you receive from Steady Guide. You have the right to change your mind at any time.”

By providing these independent options, we mitigate the risk of perceived conflicts and ensure that participants are never funnelled into a single commercial path.

5. Section 7: Governance Protocols—Declaration, Logging, and Disclosure

Rigorous documentation is the cornerstone of governance, satisfying the requirements of the NDIA Position Statement on Conflicts of Interest through continuous, transparent monitoring.

7.1 & 7.2 Internal Declaration and Correction Rights All staff must immediately complete a Conflicts of Interest Declaration Form upon identifying a potential interest. These entries are recorded in the Conflict of Interest Register.

In accordance with APP 13 (Correction of Personal Information), staff have a right to request the correction of their declarations if the information is inaccurate, out-of-date, incomplete, irrelevant, or misleading. Steady Guide will respond to correction requests within a reasonable period, generally not exceeding 30 calendar days, at no cost to the staff member.

If a correction request is refused, Steady Guide must provide a written notice explaining the reasons for the refusal (unless unreasonable to do so) and detailing the processes available to lodge a complaint. Furthermore, if requested, Steady Guide will take reasonable steps to associate a “Statement of Correction” with the record, ensuring the individual’s belief regarding the inaccuracy is apparent to any user of the information.

7.3 Participant Disclosure Protocol All staff interests must be disclosed to participants in plain language. Communication must be tailored to the participant’s preferred style, including Easy Read formats. This disclosure must occur before any referral is discussed.

7.4 Time and Space to Decide Participants must be afforded “Time and Space to Decide.” Personnel are forbidden from pressuring participants for immediate decisions. This mandate ensures participants have the opportunity to consult with family, advocates, or independent parties.

6. Accountability: Participant Rights and Governance Review

Steady Guide utilises a self-correcting governance model where participant-led inquiry is essential to our ethical alignment.

Governance Review Cycle The Conflict of Interest Register is subject to a formal audit. All logs are reviewed against NDIS Commission returns to identify systemic risks and ensure organisational accountability. This loop ensures that individual complaints and registry entries inform our high-level compliance strategy and remediate any emerging patterns of risk.