be a Related Body Corporate (as defined under section 9 of the Corporations Act 2001 (Cth)) of a Registered Provider of Supports; or
have another entity or person in a position to exercise influence over the Applicant who is related to a Registered Provider of Supports, including where:
a director of the Applicant is also the director of a Registered Provider of Supports;
a shareholder or member of the Applicant is a Registered Provider of Supports; or
a shareholder or member of the Applicant is also the shareholder or member of a Registered Provider of Supports.
(emphasis added)
In addition, paragraph 5.5 of the Program Guidelines provides:
Applicants must undertake reasonable enquiries to identify all actual, potential or perceived conflicts of interest they consider will or may arise through the submission of an Application, including any conflicts of interest in relation to a Registered Provider of Supports. Applicants must identify all of these actual, potential or perceived conflicts of interest in their Application, including a description of the conflict and its proposed mitigation and how the conflict will be monitored to ensure it does not compromise the outcomes sought under the Program.
…
A conflict of interest arises where:
a person makes a decision or exercises a power in a way that may be, or may be perceived to be, influenced by either material personal interests (financial or non-financial) or material personal associations; or
due to a direct or indirect relationship or interest, the Applicant or its related entities, personnel or subcontractors is, or may reasonably be perceived to be, unable to discharge their obligations or duties to the NDIA in an objective and independent manner to the best of their ability…