Conflict of interest in training and assessment policy and procedure

Purpose of the policy

Allara Learning is committed to the delivery of high-quality courses and to the maintenance of an effective learning environment. Quality and consistency as well as transparent and ethical conduct in all aspects of Allara Learning’s operations are a major component of Allara Learning’s policies. This policy describes the practices and procedures by which Allara will ensure all training and assessment is conducted ethically and without a perceived conflict of interest.

A perception of a conflict of interest may arise where it can be identified that a relationship exists or has existed between a trainer and/or assessor and a participant that could lead to a view that training and assessment have not been conducted in accordance with the ‘Principles of Assessment’ and ‘Rules of Evidence’.

The purpose of this policy is to ensure that the quality and integrity of assessment have not been compromised where a perception of a conflict of interest may be apparent. Trainers and/or assessors need to ensure that the processes applied are free of bias and are transparent.

This will particularly be the case where Allara Learning staff members are seeking training, assessment, and certification from Allara Learning, and where the training and assessment is likely to be conducted by a trainer and/or assessor who is a colleague of the participant/staff member. There are other examples of relationships where a perceived conflict of interest might occur, and these are listed as a guide in Appendix A.

Definitions

Allara – Allara Investments Pty Ltd, trading as Allara learning and is inclusive of; Tactical Training Group Pty Ltd, RTO provider No: 91054 (TTG) and W G learning Pty Ltd, RTO Provider No: 91178 (WGL)

TTG - Tactical Training Group Pty Ltd, RTO provider No: 91054 (TTG)

WGL– W G learning Pty Ltd, RTO Provider No: 91178 (WGL)

Scope - means, Scope of registration and consists of; the list of training package qualifications, units of competency or state accredited courses which a training organisation is registered to provide the services offered: either training and assessment, or assessment only.

Training and assessment strategies and training and assessment practices - means the approach of, and method adopted by, an RTO with respect to training and assessment designed to enable students to meet the requirements of the training package or accredited course.

Training package - means the components of a training package endorsed by the Australian Industry Skills Council (AISC) or its delegate in accordance with the Standards for Training Packages. The endorsed components of a Training Package are:

Units of Competency; and
Assessment Requirements (associated with each Unit of Competency); and
Qualifications; and
Credit Arrangements.

The endorsed components form part of the requirements that an RTO must meet these Standards. A training package also consists of a non‑endorsed, quality assured companion volume/s which contains industry advice to RTOs on different aspects of implementation.

Accredited Course - means a course that has been accredited by a regulatory body as nationally recognised training and meets the requirements of the Standards for VET Accredited Courses 2012.

Educational and support services may include, but are not limited to:

Pre-enrolment materials.
Study support and study skills programs.
Language, literacy, and numeracy (LLN) programs or referrals to these programs.
Equipment, resources and/or programs to increase access for participants with disabilities and other learners in accordance with access and equity.
Learning resource centres.
Mediation services or referrals to these services.
Flexible scheduling and delivery of training and assessment.
Counselling services or referrals to these services.
Information and communications technology (ICT) support.
Learning materials in alternative formats, for example, in large print.
Learning and assessment programs contextualised to the workplace.
Any other services that the RTO considers necessary to support participants to achieve competency.

Training product - means AQF qualification, skill set, unit of competency, accredited short course, and module.

Conflict of interest - means an actual or perceived conflict of interest is a situation arising from an actual or perceived potential conflict between the performance of the role of trainer and/or assessor and their relationship with a participant that may cause others to question the quality and integrity of the assessment process that leads to awarding and certification. The conflict of interest may be actual or perceived to exist or potentially exist currently or at some time in the future, and which could be seen to improperly influence the assessment judgement made and the awarding of credentials and certification.

Scope

The policy applies to all nationally recognised training programs of Allara Learning (Allara) inclusive of those seeking to enrol with Tactical Training Group Pty Ltd, RTO provider No: 91054 (TTG) and W G learning Pty Ltd, RTO Provider No: 91178 (WGL).

This policy also applies to actual and potentially perceived conflicts of interest that occur in the delivery of training and assessment at Allara Learning. It does not include conflicts of interest that might arise in other areas of Allara’s business (such as purchasing or receiving gifts). This policy applies to all enrolments at Allara.

Policy

Allara will, in addition to its standard training and assessment policies and procedures, recognise that there is a potential for a conflict of interest where a participant is a close friend, close neighbour, relative or business associate of the trainer and/or assessor. There is also potential for a conflict of interest where a participant is a past, current or future staff member of Allara or where the participant has been a previous work colleague of the Allara trainer and/or assessor.

This policy does not deem that a conflict of interest necessarily occurs where a trainer and/or assessor and participant are acquaintances with occasional personal or social contact, since this occurs frequently in small communities and specialist, niche industry areas.

Allara has put in place the following procedures to minimise the risk associated with potential or actual conflict of interest in the delivery of training and assessment. All trainers and assessors are required to follow these procedures to ensure internal and external confidence in the impartiality of the training and assessment process.

Consequences for Non-Disclosure

Non-disclosure of conflicts of interest may be a breach of Allara’s Code of Conduct and may give rise for disciplinary action. Non-disclosure may also be grounds for cancellation of the certification issued by Allara.

Process

Determining a risk of conflict of interest

During the enrolment process, any potential conflict of interest must be disclosed using the Conflict of Interest in Training and Assessment Form.

Allara recognises that in small communities and specialist, niche industry areas, there is a significant potential for low to medium risk levels of conflict of interest in training and assessment. Examples are represented in the table below.

Risk Level	Example Relationship
Low	Distant relative Colleague (another Institute or RTO) Acquaintance Former business associate (no contact for 2 years)
Medium	Relative (extended family) Colleague in another jurisdiction Casual friend Close neighbour Former business associate (contact within the past 2 years)
High	Relative (immediate family member) Colleague – same office Line Manager Employer Close friend

The list above is not intended to be exhaustive but provides some general guidance about the types of relationships that may lead to an actual or perceived conflict of interest. For example, there may be situations where a member of the extended family is also a close friend and therefore represents a high-risk conflict of interest.

Trainers, assessors, and employees responsible for enrolment are to utilise the Assessment of potential conflict of interest checklist to establish the potential for a perceived or apparent conflict of interest.

Idenifed potential conflict of interest

Where a potential conflict of interest is identified in the “high risk” category, this must be recorded in the ‘Conflict of Interest in Training and Assessment Form’. The form must be used to identify any high-risk conflict of interest and to develop a plan for managing the training and assessment under those circumstances. The plan is forwarded to the Quality Assurance Consultant for inclusion on the Register for Conflict of Interest.

Delivery of training with perceived conflict of interest

Training and assessment will be implemented in accordance with standard practice.

A mid-course meeting will be held between the trainer and/or assessor and the Quality Assurance Consultant or delegate to review the implementation of the conflict-of-interest plan and to identify any potential issues regarding the management of the conflict of interest that need to be addressed.

For courses of short duration, this mid-course meeting will take place via a verbal check-in that is to be documented during scheduled course breaks.

Entering training outcomes

Prior to entering any results, all evidence of assessment and recommended results must be blind moderated by a panel that includes at least one Lead Trainer and/or Assessor and an external party. Where industry specific knowledge and skills are required to confirm the outcomes of assessment, particularly in relation to licensing or external accreditation outcomes, an additional panel member should be included who has this experience. An alternative structure for the panel might include an experienced and qualified trainer and assessor that meets the requirements of Clause 1.14 of the Standards for Registered Training Organisations (RTOs) 2015, and external party who demonstrates a minimum of two (2) industry experience. Clause 1.14 states: ‘if delivered on or after 1 July 2019, is delivered only by persons who have the training and assessment credential specified in Item 2 or Item 3 of Schedule 1'.

Where the moderation of assessment supports the recommended result, the RTO Administrator can enter the result into the Student Management System.

Where moderation of assessment does not support the recommended result, gap training and/or assessment must be identified by the moderating panel to achieve the recommended result.

Gap training and assessment

Where gap training and/or assessment has been identified by the moderating panel to achieve the recommended result, the final assessment must go back to the original moderating panel to confirm that the assessment requirements have now been met.

Finalising training and certification

When the assessment outcome is complete, the Conflict of Interest in Training and Assessment Form must be finalised and forwarded to the Quality Assurance Consultant for recording on the Register for Conflict of Interest.

All documentation related to the conflict of interest, the conduct of assessment, and moderation of assessment must be retained in the participant’s file.