Conflict Of Interest Policy


Peak Plan Management (PPM) recognises the need to manage any perceived or actual conflicts of interest in relation to the contracting and delivery of supports to participants of the National Disability Insurance Scheme (NDIS) and employees working for PPM.

Ensuring that any potential conflicts of interest are identified and managed in a manner that ensures participants retain choice and self-determination in relation to the use of their funding and the integrity of the organisation is protected.

The NDIS Commission Terms of Business have clarified that registered providers must not constrain, influence or direct decision making by a person with a disability and/or their family to limit that person’s access to information, opportunities and choice and control.


This policy and procedure apply PPM NDIS services and any employees of PPM .


Word Term Definition
Conflict of Interest A situation in which a person can derive personal benefit from actions or decisions made in their official capacity.
Employee Conflict of Interest Where an employee of PPM  has a relationship or association with a participant who has engaged in the services of PPM to deliver plan management. Or is an employee of PPM  and has directly engaged the services of PPM  as their plan manager.
Employee All full-time, part-time, temporary, and casual and contracted staff, including Directors.
Plan Management Independent Plan Managers that assist participants with the administration and management of their NDIS funds.
NDIA The National Disability Insurance Agency (NDIA) is an independent statutory agency. Our role is to implement the National Disability Insurance Scheme (NDIS).
NDIS The National Disability Insurance Scheme (NDIS) is a scheme of the Australian Government that funds cost associated with disability. The scheme was legislated in 2013 and went into full operation in 2020.



The NDIS Commission Terms of Business have clarified that a registered provider must not constrain, influence or direct decision making by a person with a disability and/or their family to limit that person’s access to information, opportunities, choice and control.


Employees providing Plan Management will not have any role in the coordination or delivery of direct services for the participants they are supporting.

All employees are expected to:

  • make claims for payments that are correct and truthful.
  • only provide and charge for supports that are in line with a participant’s plan.
  • identify, declare and manage any conflict of interest including disclosing this information to the participant where required.
  • behave fairly and ethically in all your financial dealings.
  • do not purposely mislead anyone to gain a financial or other advantage.
  • do not try to convince a public officer to act unethically.

All PPM employees will not:

  • accept any offer of money, gifts, services or benefits that would cause them to act in a manner contrary to the interests of the participant.
  • will have no financial or other personal interest that could directly or indirectly influence or compromise the choice of provider or provision of supports to a participant. This includes the obtaining or offering of any form of commission.

Employees and Participants

Where an employee has engaged the services of PPM for plan management,  the employee will not be involved in making any decisions relating to the payment of invoices outside of the normal Plan Manager/participant relationship.

Peak Plan Management

Where PPM operates as a financial intermediary, systems will be in place to ensure funds that are allocated to participants will remain independent of funds used for other organisational purposes. The funds will only be used for the purposes intended. Clear guidelines regarding the allocation of NDIS funds, the independence of funds and the process of managing a participant’s funds are stipulated in the participant’s plan.