Eight Best Practices of Conflict of Interest Program Management

Few types of corporate misconduct can be as pernicious as conflicts of interest (COI). They can erode corporate culture, lead to regulatory enforcement actions, damage the corporate reputation, or invite litigation. Even inadvertent conflicts with no nefarious intent — say, a purchasing executive whose sibling starts working for a major supplier — still bring risk, which corporations ignore at their peril. 

Addressing conflicts of interest at scale, as part of the corporate compliance program, is no easy task. “COIs” are hugely diverse, and compliance officers need a thoughtful approach to wrestle them into a disciplined program.

Companies need a rigorous, structured process to find potential COIs among employees, and then to resolve those COIs — complete with systems that track mitigation steps to assure the mitigation happens. So what best practices can help a compliance officer to manage conflicts of interest efficiently and effectively?  Consider these 8 steps.