This policy sets the criteria and standards that will be met and complied with by all Hireup Representatives at all times with respect to actual, perceived or potential conflicts of interest.
The purpose of this policy is to provide guidance to Hireup Representatives on how to manage conflicts of interest and will help to ensure all dealings are conducted in an ethical manner.
Hireup promotes and upholds each Client’s right to exercise choice and control. This includes each Client’s right to be involved in and to make their own decisions in pursuit of their goals, their support and the planning and delivery of that support.
Hireup is committed to continuing to uphold each Client’s right to exercise choice and control by both managing conflicts of interests as they arise and by being proactive in their prevention. By mandating transparency and disclosure, we are able to minimise influence, bias and impropriety by always ensuring conflicts of interests are at the forefront of our minds and that of Hireup Representatives in all dealings.
We always aim to, and pride ourselves on, acting in accordance with our values and complying with our general and specific obligations as a registered provider under the National Disability Insurance Scheme (“NDIS”).
Hireup, as a registered provider of supports under the NDIS has responsibilities in relation to:
- managing conflicts of interest generally;
- managing conflicts of interest in plan management, support coordination and the exploration of support options; and
- offering or receiving gifts, benefits and commissions.
Any advice provided by a Hireup Representative to a Client, is to be solely in the Client’s best interests and transparent to enable the Client to exercise their rights to choice and control.
What is a conflict of interest?
A conflict of interest is a situation that arises in which a person or entity is in a position to obtain a benefit from the actions or decisions made in their own interest or official capacity and that such actions and decisions are based on that benefit.
In the context of services provided by Hireup, examples of potential conflicts of interest may arise where a Hireup Representative only recommends Hireup to be a Client’s Support Provider because that Hireup Representative is employed or engaged by Hireup.
Managing conflicts of interest
As an NDIS Registered Provider, we are required to have policies to manage actual and potential conflicts of interest in the delivery of our services.
Hireup and our Hireup Representatives will ensure that when providing services to our Clients, that any conflict of interest is declared and any risks to Clients are mitigated.
When providing services, Hireup and Hireup Representatives will always act in the best interests of the Clients and will ensure that each Client can exercise their rights of choice and control by being honest and transparent in all dealings. Clients will at all times be informed and thereby empowered to maximise their choice and control.
Neither Hireup nor our Hireup Representatives will withhold, constrain or unduly influence a Client or their family’s decision making by limiting their access to information, opportunities and thereby their choice and control.
We will proactively manage perceived and actual conflicts of interest by:
- disclosing any perceived or actual conflicts of interest;
- managing, documenting and reporting on conflicts of interest as they arise;
- ensuring Clients are always fully informed of all options; and
- ensuring that any advice provided to a Client is honest, transparent and promotes choice and control.
Each Client will be treated equally and no preferential treatment will be extended to any Client.
Mitigating conflicts of interest
When Support Providers or other support services are recommended to Clients by a Hireup Representative, the following steps are to be followed to both prevent and manage conflicts of interest, and to protect Clients’ rights to choice and control.
Step 1: Declaration
- The Hireup Representative will declare to each Client at the beginning of their relationship or engagement:
- the capacity in which they are employed or engaged by Hireup; and
- that Hireup is also a NDIS registered Support Provider.
- Hireup Representatives will also confirm that they will at all times act in the Client’s best interests and as directed by the Client.
Step 2: Recommending Support Providers
- Clients will be presented with a range of options of Support Providers. Hireup will only be provided as one of the recommended Support Provider options if Hireup’s services are in the best interests of the Client in the reasonable opinion of the Hireup Representative.
- Clients will not be unduly influenced in any way as to which Support Provider to select and will not be unduly influenced to select Hireup when Hireup is presented as a Support Provider option.
- A file note will be made by the relevant Hireup Representative confirming the Support Provider options that they have presented to each Client.
Step 3: Reporting
- If Hireup is recommended as a Support Provider, the Hireup Representative will record this on Hireup’s Conflict of Interest Register along with the other Support Provider options recommended to the Client.
Availability of Support Providers
If the Client’s selected Support Provider does not have the capacity to accept the Client and the Client does not want to proceed with a different Support Provider, Hireup Representatives will:
- present options regarding support delivery in the future; and
- ask the Client if they want to be placed on the waitlist with other SupportProviders.
If multiple Support Provider options are not available, for example, where there may be limited Support Provider options available in the Clients’ area, Hireup Representatives will:
- advise the Client of the limited options available;
- record the feedback from the Client;
- advise the Client of any complaint mechanisms; and
- advise the Client of their right to support from an advocate should the Client have any concerns about supports provided.
Gifts, Benefits & Commissions & the NDIS
Neither Hireup nor any Hireup Representative will accept any offer of money, gifts, services or benefits that would cause them to act contrary to the best interests of the Client.
If a Hireup Representative breaches or is alleged to have breached this policy, where appropriate:
- Hireup will implement it’s disciplinary processes (including potentially suspending the work being performed by the Hireup Representative);
- a formal investigation will be conducted by Hireup; and
- if any investigation finds a breach of this policy, disciplinary action (including termination) may be taken against the offending Hireup Representative.
National Disability Insurance Scheme (Registered Providers of Supports) Rules 2013.
“Client” means an individual with a disability who has registered with, and has been approved by Hireup to obtain services through the Platform.
“Hireup Representative” means a person engaged by Hireup as an employee (under an employment agreement) or independent contractor (under a contractor agreement) to provide services to Clients.
“Platform” means the Hireup website (currently, www.hireup.com.au), the Hireup web app, the Hireup iPhone App, iPad App and Android App and all parts and pages of the same.
“Support Provider” means a person, business or organisation who delivers disability services to Clients.