| Conflict of Interest Policy | Version: | 01 |
| Approval Date: | 24 February 2026 | |
| Approved by: | Council | |
| Review Date: | 24 February 2030 | |
| Responsible Officer | Executive Director Corporate Services | |
| Authorising Officer | Chief Executive Officer | |
Purpose
These Guidelines set out the requirements that apply when a Councillor of the City of Greater Geelong stands as a candidate in a State or Federal election. The Guidelines promote high standards of integrity, transparency, and public confidence. They provide clear guidance to Councillors who are candidates on how to avoid any actual or perceived misuse of their position, influence, or Council resources.
The Guidelines complement and expand upon the obligations contained in the Model Councillor Code of Conduct, which replaced the Councillor Code of Conduct in October 2024. They form an important part of the City of Greater Geelong’s governance framework. The Guidelines reinforce the separation between Council responsibilities and electoral activities and supporting ethical conduct, accountability, and good governance.
Scope
These Guidelines are designed to support a Councillor from the time they become a nominated candidate, or are taken to be a prospective Candidate, in a State or Federal election in accordance with the relevant electoral legislation administered by the Victorian Electoral Commission (VEC) or Australian Electoral Commission (AEC), until the time they cease to be a candidate under that legislation.
These Guidelines operate alongside, and do not replace, the Model Councillor Code of Conduct, the Local Government Act 2020 (Vic) (the Act), and the Local Government (Governance and Integrity) Regulations 2020.
Councillors who are candidates in a State or Federal election remain bound by these legislative and integrity frameworks at all times, including during any period of approved leave of absence from Council duties.
These Guidelines do not apply to local government elections, which are governed by the Council’s Election Period Policy.
Definitions
| In these Terms, unless the context suggests otherwise the following words and phrases mean: | |
| City The City of Greater Geelong organisation, led by the CEO. | |
| City Officers includes employees, volunteers, and contractors. | |
| Council The City of Greater Geelong Council comprised of elected councillors and led by the Mayor. | |
| Councillor means a person who holds the office of member of a Council. | |
| ELT The Executive Leadership Team of the City, as constituted from time to time. | |
| Election State or Federal Election - this includes a by-election. | |
| Prospective candidate means a person who becomes an endorsed candidate of a registered political party or publicly expresses an intention to run as an independent candidate for a State or Federal Election. | |
| Nominated candidate means a person who nominates as a candidate for a State or Federal election through the relevant Electoral Commission. | |
Guidelines
1. Councillor to Candidate - Expectations
| 1.1 | To support public confidence, ethical decision-making, and the clear separation of Council responsibilities from electoral activities, the following best-practice governance guidance applies to Councillors of the City of Greater Geelong who are prospective or nominated candidates in a State or Federal election. | |
| 1.2 | Consistent with contemporary governance standards, a Councillor who is a candidate is strongly encouraged to: | |
| 1.2.1 | Seek a leave of absence from Council in accordance with these guidelines, to minimise the risk of real or perceived conflicts between Council duties and campaign activities; | |
| 1.2.2 | Maintain a clear and appropriate separation between their role as a Councillor and their role as a candidate, ensuring Council decision-making, communications and authority are not associated with electoral campaigning; | |
| 1.2.3 | Proactively identify, avoid, and manage both actual and potential conflicts of interest arising from their candidacy; | |
| 1.2.4 | Declare any conflicts of interest or relevant interests that may arise in connection with their role as a candidate and their position as a Councillor, in accordance with legislative and governance requirements; | |
| 1.2.5 | Refrain from any misuse of their position as a Councillor, including the use of influence, access to information, or status associated with the office for electoral advantage; | |
| 1.2.6 | Ensure that Council resources are not used, or perceived to be used, to support their candidacy, including staff time, facilities, information, branding, or systems; and | |
| 1.2.7 | Continue to comply with all obligations under the Model Councillor Code of Conduct for the duration of their candidacy. | |
2. Councillor Endorsement
| 2.1 | To uphold the political neutrality and maintain public confidence in the integrity of Council, Council is encouraged not to endorse, support, or oppose the candidature of any Councillor in a State or Federal election. | |
| 2.2 | All Councillors are strictly required to: | |
| 2.2.1 | Refrain from using Council resources, facilities, communications, branding, or forums in any way that could be interpreted as promoting or opposing a candidate; | |
| 2.2.2 | Avoid any public statements or actions that may create the perception of Council endorsement or opposition; and | |
| 2.2.3 | Respect the impartiality of Council at all times, ensuring that Council business remains separate from individual electoral activities. | |
| 2.3 | Non-compliance with these expectations may constitute a breach of the Model Councillor Code of Conduct and the Act. | |
3. Notification of Candidacy
| 3.1 | As soon as practicable after a Councillor becomes a prospective or nominated candidate for a State or Federal election, the Councillor must notify the Mayor in writing. |
| 3.2 | Upon receipt of the notice, the Mayor will advise the other Councillors to ensure transparency across the Council, while respecting the Councillor’s privacy regarding campaign matters. |
| 3.3 | To reinforce transparency and good governance, a Councillor should declare their intention to contest a State or Federal election at the next scheduled Council Meeting following notification. This declaration helps other Councillors manage potential conflicts of interest and supports the integrity of Council decision-making. |
4. Leave of Absence
| 4.1 | Councillors are strongly encouraged to apply for a leave of absence commencing no later than the date of nomination with the relevant electoral commission and concluding no earlier than the close of voting for the election: | |
| 4.1.1 | For State elections, the Victorian Electoral Commission (VEC) allows candidates to formally nominate until 15 days prior to election day. | |
| 4.1.2 | For Federal elections, the Australian Electoral Commission (AEC) allows candidates to formally nominate no less than ten days no more than 27 after writs are issued. This is generally between 23 to 31 days prior to election day. | |
| 4.2 | Leave of absence ensures a clear separation between Council duties and campaign activities, reduces the risk of actual or perceived conflicts of interest, and reinforces public confidence in the impartiality and integrity of Council decision-making. | |
| 4.3 | The application should be made: | |
| 4.3.1 | Immediately upon the date for the close of nominations being published, if at that date the Councillor has decided to nominate; or | |
| 4.3.2 | On the date the Councillor formally nominates, whichever occurs sooner. | |
| 4.4 | Leave of absence must be requested at a Council Meeting in accordance with Council’s Governance Rules. Council is expected to grant any reasonable request for leave. | |
| 4.5 | While on an approved leave of absence, a Councillor must not attend Council Meetings, Delegated Committee Meetings, or Councillor Briefing Meetings in their capacity as a Councillor and must not otherwise act in the role of Councillor. | |
| 4.6 | If a Councillor withdraws their nomination after leave has been granted, they may resume ordinary Council duties, provided they submit written notification to Mayor confirming their return. The Mayor is to advise all other Council members and the Chief Executive Officer in the event this occurs. | |
5. Legal Advice
| 5.1 | Councillors are required to obtain their own legal advice, at their own expense, regarding the various issues associated with running as a candidate at a State or Federal election such as: | |
| 5.1.1 | A Councillors eligibility to be a Candidate; | |
| 5.1.2 | Conflicts of Interest, whether actual, perceived, potential or otherwise. | |
6. Comments on Council Issues
| 6.1 | Councillors who are prospective or nominated candidates must clearly separate their role as a Councillor from their role as a candidate when commenting on Council matters. | |
| 6.2 | Comments must not imply Council endorsement or use Council resources, branding, or staff to support a campaign. | |
| 6.3 | Councillors are strongly encouraged to maintain separate social media accounts for their Council and candidate roles. | |
| 6.4 | Failure to maintain this separation may breach the Act, including obligations to act with integrity, avoid misuse of position or information, and comply with the Model Councillor Code of Conduct. | |
7. Use of Council Resources and Activities
| 7.1 | Councillors who are prospective or nominated candidates must not use Council resources for election purposes. This includes but is not limited to; office accommodation, Council facilities, vehicles, hospitality services, mobile phones and numbers, laptops, Council email addresses, photographs, computers, printers, and other Council-owned materials. | |
| 7.2 | During Leave of Absence, all Council equipment and materials must either be returned to Council or retained but not used for the duration of the approved leave. | |
| 7.3 | During any period of leave of absence, Councillors should activate out-of-office messages on Council email and voicemail that clearly advise of their leave and provide alternative contact points for Council matters. | |
| 7.4 | Managing perceived conflicts, even where no direct expense occurs, Councillors should ensure campaign activity does not intersect with Council resources. Examples include: | |
| 7.4.1 | Responding to campaign-related emails received on a Council account only via a private email and directing future correspondence to the private account. | |
| 7.4.2 | Providing a non-Council contact number for campaign-related calls received on Council devices. | |
| 7.5 | Councillors must not use Council meetings, events, networking opportunities, or other Council-related activities to advance their candidature. | |
| 7.6 | Councillors must not leverage their official position, Council staff, or Council resources in any way to assist or support the election campaign of another Councillor. | |
8. Media and Publicity
| 8.1 | The City will not provide media advice or assistance in relation to election issues or publicity concerning a Councillor who is a prospective or nominated candidate. | |
| 8.2 | Council media releases will not refer to specific Councillors in their capacity as prospective or nominated candidates. | |
9. Successful Election
| 9.1 | A Councillor must resign from Council immediately upon being successfully elected to State or Federal Parliament. This requirement arises because under section 34(2)(a) of the Local Government Act 2020, a person is not qualified to be a Councillor if they are a member of Parliament. |
Implementation
Monitoring and reporting
A Councillor is responsible for notifying the CEO of their candidacy in accordance with these guidelines.
The Chief Governance and Risk Officer are responsible for the monitoring of these guidelines.
Advice and assistance
The Responsible Officer is responsible for providing guidance on the application of these guidelines.
Records
The City must retain records associated with these guidelines and its implementation in accordance with its Records Information Management Policy.
Review
These guidelines will be reviewed by the Manager Council and Corporate Governance prior to a State or Federal election or State or Federal by-election.
Documents
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