In the three previous posts of this series, we’ve walked through ways to manage conflicts of interest from how to observe the environment for potential risks and assessing each risk using a severity scale to the importance of consistently performing regular control and monitoring COI processes and policies. In this post, we will verify your COI management’s capability from looking at different data sources and analyzing audit results to evaluate all of the possibilities and growth areas you have in front of you – and at the end of the day, mitigate risk in your organization.
Now, it’s time to see if your COI management can stand up in court and in the board room. Will it meet the satisfaction of your board and be defensible in times of scrutiny or when a high-risk COI appears? Let’s take a look.
Assess conflict management capabilities to see what gaps exist and ways to mitigate risk
Can your COI system:
- Adjust and improve controls based on an analysis of COI results?
- Provide assurance to leadership that risk is low or that in the instance of high-risk areas, the compliance team is taking appropriate measures to mitigate such?
- Does it meet legal and external reporting requirements?
Evaluate your COI system in a holistic way. If you answered no to any of the above questions, there is room to improve. Here are some capabilities that your COI system should be integrating into your compliance program and able to do on demand to ensure risk is effectively being managed and addressed (from an internal perspective and in the eyes of the law):
If there are areas that leave your company at high levels of risk, get to it – a COI can arise at any time and you wouldn’t want to be caught in the crossfire of one that could potentially damage the company, its reputation, and trust in the compliance program. The stronger you ensure your COI management system is, the stronger your corporate shield is to stand up to varying levels misconduct and/or illegal activities. Defending your company is your job and what you are great at – and a solid COI management approach is a line of a defense you want to remain effective at what you do so well (and areas you may not be doing so well at.)
A better way to manage COIs – technology is not only the future but the answer you’re looking for.
Have you read through this entire series and asked yourself: What solution could be right for me? We hear more often than not from compliance officers they understand the level of risk their company is facing, but they may not have the budget to invest in something new or the time or resources or support from the powers that be. We get it, but perhaps think of it this way: while you may not see a risk as a high price tag now, consider the fines from regulatory penalties, legal fees, consulting hours and the overall aftermath of a high-risk COI in terms of cost and impact that could occur. Which seems like the high ground? Likely, finding a solution sooner rather than later.
Technology doesn’t only need to benefit the company or compliance program, but it can positively impact your career trajectory and simplify the manual COI processes that exist, help automate functional areas and help you get ahead of risk before it happens in the first place rather than trying to put out a fire with no water in sight. Choose a solution that benefits all involved, makes your life easier and allows compliance to be more effective.
COI software in action.
See what an integrated solution looks like. Take a self-guided tour of our COI Manager. Customizing disclosures, escalating high-risk COIs and collaborating across the company all within one place is only a few clicks away.
GRC of Conflict of Interest Management – Webinar
April 28 at 2-3 p.m. EDT
In this interactive session, led by OCEG and speakers from Convercent, you will learn:
- How to observe your environment to identify potential conflicts
- How to assess COI risks and design risk-based controls
- How to implement COI controls and monitoring
- How to verify that COI management capabilities are working as intended
Register to join this conversation with industry experts and tackle the huge management challenges that COI presents.