Club Conflicts of Interest - Policy Template

Why This Matters

In July 2026, the NSW Independent Liquor and Gaming Authority (ILGA) determined that the president of Erina Rugby League Football Club was not a fit and proper person to hold office. The finding arose from invoices totalling over $80,000 paid to two businesses owned by the president - without tenders, competitive quotes, or board approval - and a construction project that blew out from a $90,000 quote to more than $450,000.

ILGA found the president failed to properly record conflicts of interest and should have disclosed that his own companies were performing works at the club. The penalties included a 12-month ban, a $1,100 fine, and $31,147 in investigation costs.

Liquor & Gaming NSW was direct in its response: "Saying there was a lack of governance knowledge among directors is not a defence."

Conflicts of interest are one of the most common - and most avoidable - governance failures in the club sector. A clear, well-understood policy is the foundation. The template below is a starting point clubs can adapt to their own circumstances.

What a Conflicts of Interest Policy Should Cover

At a minimum, a conflicts of interest policy for a registered club should address the following:

• Definition of a conflict of interest - including actual, potential, and perceived conflicts, and conflicts involving associates, family members, and related entities.
• Who is covered - directors, officers, the secretary, committee members, and senior employees at a minimum.
• Disclosure obligations - when to disclose, how to disclose, and to whom.
• The conflicts register - what is recorded, who maintains it, and how it is reviewed.
• Managing declared conflicts - the process for determining whether a person should be excluded from deliberations or decisions, and how that determination is recorded.
• Procurement and related-party transactions - specific rules for situations where a director or officer has an interest in a supplier, contractor, or counterparty.
• Consequences of non-disclosure - what happens if a conflict is not declared.
• Annual declarations - a standing requirement for covered persons to confirm their interests at least annually.

The Registered Clubs Accountability Code

NSW registered clubs are subject to the Registered Clubs Accountability Code, which sets out specific requirements for conflicts of interest management. The Code requires clubs to have a conflicts of interest policy and to maintain a conflicts register. Compliance with the Code is not optional - it is a condition of registration.

Clubs should ensure their policy is consistent with the Code and reviewed whenever the Code is updated. The Erina determination is a reminder that regulators will look at whether policies exist and whether they are actually followed.

Template Policy

The template below is provided as a starting point. It covers the core elements described above and is structured for a typical registered club. Clubs should review it against their constitution, the Registered Clubs Accountability Code, and any applicable legislation before adopting it.

Key Lessons from the Erina Determination

The Erina case illustrates several practical points that clubs should take from the determination:

• A conflict does not have to be intentional to be a problem. The obligation to disclose arises when the conflict exists - not when the director decides it is significant enough to mention.
• Related-party procurement is high risk. Where a director or officer has an interest in a supplier or contractor, the club needs a clear process: disclosure, board consideration, competitive quotes, and documented approval. Skipping any of these steps creates exposure.
• Cost blowouts attract scrutiny. A project that starts at $90,000 and ends at $450,000 will be examined. If the contractor is connected to a director, the absence of a paper trail is a serious problem.
• The conflicts register is evidence. A well-maintained register demonstrates that the club takes its obligations seriously. An absent or incomplete register is evidence that it does not.
• Ignorance is not a defence. Directors and officers of registered clubs are expected to know their obligations. The regulator's position is clear on this point.