Skills Assure Supplier Conflict of Interest Policy

Purpose of the policy

Allara Learning is committed to ensuring all enrolments subsidised under the Department of Trade, Employment and Training (the department) is conducted in a fair and unbiased way, and that any decisions made are not affected by self-interest, private affiliations, or the likelihood of personal gain or loss.

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)

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.

Conflict of interest means having an interest, affiliation, or relationship, or owing an obligation (whether personal, financial, professional or otherwise) which conflict, may reasonably have the potential conflict, or may reasonably be perceived as conflicting, with the ability of the Supplier or its Personnel to perform its obligations under the Skills Assure Supplier Agreement/s fairly or objectively.

Service level agreement an agreement between the RTO and a service provider that outlines the specific terms and conditions of the service being provided.

Skill Assure Supplier (SAS) means a pre-approved registered training organisations (RTOs) able to deliver training and assessment services subsidised by the Department of Employment, Small Business and Training (DESBT).

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

Scope

The policy applies to all training programs provided by Allara Learning (Allara) inclusive of those provided by Tactical Training Group Pty Ltd, RTO provider No: 91054 (TTG) and W G Learning Pty Ltd, RTO Provider No: 91178 (WGL) under their respective Skills Assure Supplier Agreements.

Policy

Allara Learning recognises that there could be a perceived conflict of interest where a student enrols in a course of study (Training Product) with Allara learning. This perceived conflict may arise because both TTG and WGL hold a Skills Assure Supplier agreement and have a similar scope of registration.

Allara Learning has put in place the following procedures in accordance with the Skills Assure Supplier Guide to Conflict-of-Interest Management Plans (Guide) that provides an overview of the ways in which a Conflict-of-Interest can be effectively identified, managed and monitored – whether actual, perceived or potential.

Non-Disclosure

Clause 14 of the 2021-22 Skills Assure Supplier (SAS) Agreement requires the disclosure of any conflict of interest (COI) or risk of a conflict of interest to the Department immediately.

Non-Disclosure of Conflicts of Interest may be considered a breach of the Skills Assurance Supplier (SAS) Agreement and may give rise to an Event of Default.

Types of conflict

Allara recognises the following types of conflict may lead to an actual or perceived conflict

Types of conflict	Role	Position	Interest
Actual	Director, Shareholder or Key Personnel of a Skills Assure Supplier	Is in a position to be influenced	By their private interests when doing their job
Perceived	Director, Shareholder or Key Personnel of a Skills Assure Supplier	Is in a position to appear to be influenced	By their, their spouse or family members private interests when doing their job
Potential	Director, Shareholder or Key Personnel of a Skills Assure Supplier	Is in a position where they may be influenced in the future	By their, their spouse or family members private interests when doing their job

Identifying a conflict of interest

A conflict of interest is identified by completing the Assessment of Potential Conflict of Interest Checklist

Managing a conflict of interest

A combination of strategies will be used to mitigate any perceived, potential, or actual conflict of interest as detailed below.

Register

All conflicts of interest whether perceived, potential, or actual will be recorded in the Conflict-of-Interest register.

Likely affected persons are informed of the nature of the perceived, potential, or actual conflict, and the strategies to apply to effectively manage the conflict.

Restrict

Restrictions will be placed on the common shareholders of Allara Learning to ensure the conflict can be separated from the activity, and includes:

Refraining from taking part in or influencing any decisions relating to students enrolling in a course of study with either TTG or WGL.
Refraining from taking part in or influencing any decision-making in relation to the location of work placement for an individual or group of students.

Service level agreements

A service level agreement will be documented and agreed to with any individual and/or organisation identified as having a perceived, potential, or actual conflict of interest.

This service level agreement will stipulate at minimum:

Duration of the agreement (start and termination dates)
Services to be provided
Obligations of the parties to the agreement
Charges and applicable fees for services provided (if applicable)

Monitoring a conflict of interest

The General Manager is responsible for monitoring any identified conflict by:

Developing and implementing of a conflict-of-interest policy
Developing and implementing the Skills Assure Supplier Conflict of Interest Management Plan.
Conducting annual reviews of applied conflict of interest management strategies to ensure that strategies remain relevant to the conflict
Amending Skills Assure Supplier Conflict of Interest Management Plans as required
Notifying the Department and keeping formal records of all reviews and any decisions made with respect to managing the conflict identified.