Managing conflicts of interest
How we manage conflicts of interest and duty
The Conflicts Management Framework (CMF) enables the Trustee of Spirit Super to appropriately manage relevant conflicts of interest and duties that may arise.
The CMF operates to protect the integrity and quality of decision-making by Responsible Persons associated with Spirit Super, by ensuring they’re not compromised by actual or potential conflicts. Responsible Persons include all Directors, the CEO, members of the Executive Team and the External Auditor.
A relevant interest or duty is one that might reasonably be considered to have the potential to have a significant impact on the capacity of the holder to act in a manner that is consistent with the best interests of Spirit Super‘s beneficiaries.
The CMF requires that all Responsible Persons disclose any potential or actual conflicts of interests or duties. All Responsible Persons have an obligation under the CMF to notify the Trustee of potential conflicts as they arise and annually. Any disclosures made are assessed by the Conflicts Officer and if necessary, appropriate conflict management measures are put in place – this will normally involve disclosure, control or avoidance of the relevant conflict. The Trustee Board must also evaluate and approve the effectiveness of the conflict management processes under the CMF. The conflicts management process is required to be monitored and is subject to review (internally and independently).
Consistent with increased transparency requirements, the Conflicts Officer is also required to record all relevant conflicts in the relevant register.