Secondary Employment Policy

Secondary employment is any paid employment with an organisation other than your primary employer. It can also be known as ‘outside employment’.

The NSW Independent Commission Against Corruption (ICAC) says ‘Outside employment [or Secondary Employment] creates significant conflict of interest risks, especially if the outside employment has not been declared.’ However, secondary employment can also create benefits for the primary employer as it can provide additional skills and knowledge for the employee. It also provides employees with additional income which may benefit the primary employer through improved retention.

Secondary employment is increasing in Australia with the rise of the gig economy and the ability to establish online businesses. Given this, it is important for organisations to have a policy to address secondary employment. This should include a requirement for all secondary employment to be declared and approved.

There are 3 key elements to include in a Secondary Employment Policy:

Conflict of Interest management

A conflict of interest occurs when a reasonable person might perceive that a personal interest could be favoured over the individual’s professional duties.

There are many ways that secondary employment may give rise to a conflict of interest, including:

  • working for a direct competitor of the primary employer
  • working in a field that is regulated by the primary employer
  • working for a goods or service provider of your primary employer
  • performing work that may use the same time, resources, and contacts of the primary employer.


To help mitigate these conflicts, all secondary employment should be declared and the conflict resolved to the satisfaction of the primary employer.


Provided any conflict has been resolved, two further matters of accountability should be addressed and documented:

  • how the employee will ensure that the time and resources of the primary employer are protected and not used for the secondary employment
  • how the employee will ensure that their health and wellbeing are not impacted by the additional employment to ensure fitness for work for the primary employer.


The steps taken to address the above should be agreed by the primary employer and monitored throughout the term of the secondary employment.


Employment situations change. As such, any declaration should be updated either annually or when the circumstances of the employment changes, whichever comes first. This is an opportunity to verify that both the conflict of interest and accountability elements are being managed appropriately.

On the management side, it is also a good idea to check in with the employee to see how their secondary employment is going. This adds an element of accountability while also showing the employer’s interest in the wellbeing and personal success of the employee.

Further Information

Many agencies and businesses include guidance on secondary employment in their Code of Conduct, others have a stand-alone Secondary Employment Policy. Further information on developing a Secondary Employment Policy can be found on the ICAC website.

You can also contact Procure Group for assistance in developing or reviewing your Secondary Employment Policy.