Goodo Conflict of Interest Statement

Draft for legal review — not yet legal advice

This statement has two parts. Part A applies to plan managers and support coordinators on Goodo, and to anyone else on the provider side whose role could influence a participant's choices. Part B is Goodo's own commitments as the operator of the platform.

The aim is simple: a participant should be able to trust that what they see on Goodo is not shaped by who is paying whom.

Why this matters

Participants choose their own supports. Some providers, especially plan managers and support coordinators, are well placed to influence those choices: they see budgets, recommend services, and are often trusted. NDIS rules and Commission guidance on conflicts of interest, inducements and independence apply to NDIS providers and workers. [Counsel to insert current citations, including the relevant NDIS rules, Practice Standards and Commission guidance on conflicts of interest in plan management and support coordination.] Goodo must not become a channel for steering, kickbacks or hidden influence.

Part A: Plan managers, support coordinators and other provider-side members

What counts as a conflict of interest

A conflict of interest exists when you have a financial, personal, business or other interest that could (or could appear to) influence your advice, your recommendations or what you post. Examples:

• you or a relative own or work for a provider you are recommending
• your organisation also provides the services you are suggesting, or a related organisation does
• you are paid, rewarded or otherwise benefited when a participant chooses a certain provider
• you are paid to promote a service, product or event
• you receive gifts, hospitality or discounts from a provider you mention

What you must do on Goodo

1. Disclose. If you recommend, mention, promote or link to a service, you must say if you or a related party have an interest in it. Put the disclosure in the video, the caption or the description, clearly and early. Your profile must also state any ownership of, or relationship with, other providers (for example, "My organisation also provides support coordination and in-home support").
2. Plan managers and support coordinators: you must not steer participants toward your own or an affiliated service without clear disclosure and the participant's free choice. Give balanced options where you can. Remind participants they can choose anyone.
3. No referral fees, kickbacks or inducements. You must not give or receive any payment, commission, gift, discount or other benefit for referring a participant, for a recommendation, or for a participant choosing or staying with a provider. This applies to you, your organisation and people connected to you.
4. Label paid content. Paid promotion must be marked as paid placement. Goodo applies the label automatically when a video is marked as paid, and you must not hide or remove it.
5. Do not vouch for reward. If you hold a verified plan manager or support coordinator badge you may vouch for people you genuinely know as participants. You must not vouch in return for anything.
6. Keep the participant in charge. Do not pressure a participant to start, change or stop a service. Do not make support depend on them using your other services.
7. Update your disclosures. If your interests change, update your profile within 5 business days.
8. Answer questions. If a participant, moderator or the NDIS Commission asks about your interests, answer honestly.

How we handle breaches

• A report with the reason "undisclosed conflict of interest" goes to the reports queue.
• Failing to disclose: we require you to add the disclosure, and issue a warning.
• Repeated or deliberate non-disclosure, or steering for gain: we may revoke your badge, strike, suspend or ban you, and refer to the NDIS Quality and Safeguards Commission.
• Giving or taking referral fees or inducements: we remove content and revoke the badge, and may ban and refer.

See the Moderation Policy for the ladder.

Part B: Goodo's own commitments

1. No referral fees. Ever. Goodo does not charge or accept any referral fee, commission, finder's fee or per-lead charge from any provider, and nothing a provider pays us is for introductions, enquiries, leads or bookings.
2. Participants are never charged. Participants, nominees and carers use Goodo free of charge.
3. Paid placement is always labelled. Anything promoted for payment is labelled in the app, every time. We do not sell unlabelled placement, and we do not sell placement in participant-only spaces or in groups.
4. Money does not buy a badge. A badge is granted only when the requirements in the Verification Policy are met. Paying a fee does not change a verification, moderation, ranking or enforcement decision, and reviewers do not know whether an applicant is a paying customer. [Confirm how this is reflected in staff processes and in any provider fee structure. If verification tiers are charged for, the fee must cover administration only and be refundable if the application is declined.]
5. Providers cannot buy access to participants. Providers cannot start conversations with participants, cannot search for participants by location, and cannot buy a list. We do not sell or share user data.
6. No ownership by providers [to be confirmed]. Goodo is not owned or controlled by an NDIS provider. We will disclose any investor, director or staff member who has a material interest in a provider, plan management or support coordination business, and they will not take part in verification or moderation decisions about that business.
7. Staff declare interests. Every staff member and contractor declares conflicts when they start and when they change. A reviewer must step aside from any case involving someone they know or an organisation they have a link to. The register of declared interests is held by the director.
8. Independent decisions. Verification and moderation decisions are made by trained staff using written rules. No commercial, sales or partnership team may influence a decision.
9. Co-design and advisers. People on our co-design group or advisory panel who are paid or unpaid are asked to disclose their interests, and disclosures are published in summary.
10. Gifts. Staff may not accept gifts, hospitality or benefits from providers or applicants (other than trivial ones, such as a cup of tea at a meeting).
11. Advertising. We show no third-party advertising, and we do not use participants' information to target advertising.
12. Public record. We publish this statement in the app and on our website, and report in our transparency reports how many conflict of interest reports we received and acted on.
13. Review. We review this statement every year and when our business model changes, such as before any paid provider plan starts.

If you think there is a conflict

Tap Report on any video, profile, group or event and choose Undisclosed conflict of interest. You can also email [conflicts email TBC]. You can also complain to the NDIS Quality and Safeguards Commission on 1800 035 544.