---
title: "Conflict of interest policy for a registered charity (adapted from the ACNC template)"
url: "https://ailawframework.com/precedents/not-for-profit-charities-and-associations/conflict-of-interest-policy"
type: "precedent"
site: "AI Law Framework"
id: "a35-conflict-of-interest-policy"
area_id: "A35"
kind: "policy"
ai_level: "yellow"
version: 1
law_stated_as_at: "2026-10-17"
---

# Conflict of interest policy for a registered charity (adapted from the ACNC template)

> The ACNC's openly licensed conflict of interest policy, adapted with numbered clauses, a standing-notice clause and a register of interests table, so a charity board can identify, disclose and manage conflicts under…

Canonical page: https://ailawframework.com/precedents/not-for-profit-charities-and-associations/conflict-of-interest-policy  
Law stated as at: 2026-10-17

Site index for agents: https://ailawframework.com/llms.txt

The ACNC's openly licensed conflict of interest policy, adapted with numbered clauses, a standing-notice clause and a register of interests table, so a charity board can identify, disclose and manage conflicts under Governance Standard 5.

## Key facts

- Kind: Policy. A policy or procedure for a firm or client.
- Practice area: [Not-for-Profit, Charities & Associations](https://ailawframework.com/precedents/not-for-profit-charities-and-associations.md)
- Jurisdictions: Australia
- AI level: Yellow. AI can help in set ways. A lawyer checks specific points before use.
- Law stated as at: 2026-10-17
- Status: Maintained. Checked on 2026-10-17 against the official source at acnc.gov.au and the 4 authorities it cites, for Australia.

## When to use it

Use for a registered charity that needs a board conflicts policy, or to update an old one. Adapt it for larger charities with staff delegations, and check the governing document first: a constitution's conflict rules may be stricter and will prevail.

## How AI may be used

AI may tailor the template to the charity's structure and build a draft register of interests from board papers, under the lawyer's direction. Whether a conflict is material and how it is managed is for the board on the lawyer's advice.

**AI may:**

- Replace placeholders with the charity's name, roles and governance structure
- Draft register entries from directors' declarations, related-party contracts and minutes, citing the source document for each
- Compare the policy with the charity's constitution and list inconsistencies

**AI must not:**

- Must not decide whether a conflict is material or what action the board should take
- Must not change the statement of duties so that it departs from Governance Standard 5
- Must not process directors' personal and financial details in a tool the charity has not approved

**The lawyer checks:**

- The policy is consistent with the constitution and any funding agreement conditions
- Disclosure routes match Governance Standard 5(3) for the charity's legal form
- For a company, the s 111L position is explained to the board
- The attribution and change note are kept with the adopted policy

## Authorities

- [Australian Charities and Not-for-profits Commission Regulations 2022 (Cth) s 45.25 (Governance Standard 5)](https://www.legislation.gov.au/F2022L01301/latest/text)
- [Australian Charities and Not-for-profits Commission Act 2012 (Cth)](https://www.legislation.gov.au/C2012A00168/latest/text)
- [Corporations Act 2001 (Cth) s 111L (ss 180 to 183 and 191 to 194 do not apply to companies registered with the ACNC)](https://www.legislation.gov.au/C2004A00818/latest/text)
- [ACNC, Template conflict of interest policy (CC BY 4.0)](https://www.acnc.gov.au/tools/templates/conflict-interest-policy)

## Official form

[Official form](https://www.acnc.gov.au/tools/templates/conflict-interest-policy)

## Where this comes from

Reproduced from acnc.gov.au under CC BY 4.0. Based on the ACNC template conflict of interest policy, © Commonwealth of Australia 2018 (Australian Charities and Not-for-profits Commission), https://creativecommons.org/licenses/by/4.0/. Changes made.. Last checked on 2026-10-17.

## Full text and drafting notes

The full text and the drafting notes are not part of this public page. Signed-in firm accounts can read them at https://ailawframework.com/precedents/not-for-profit-charities-and-associations/conflict-of-interest-policy and through the signed-in MCP connector https://ailawframework.com/mcp/firm.

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*