For the past several months, I have been knee deep in learning about conflicts of interest.
I’ve read countless articles and scoured through numerous research reports, white papers, and even college textbooks. I got on the phone with professionals with experience practicing compliance from finance to telecom and consulting.
One major takeaway from all of this learning: There is no formulaic approach to any conflict. And if you don’t have a solid process in place, you’re starting out at a tremendous disadvantage (not to mention the heap of risk that goes along with it).
It’s plain as day why there is a universally-felt frustration with this aspect of building compliance and ethics programs.
Whether you are a nonprofit organization or a large financial institution, a systematic approach to COI management makes disclosure management and action feasible. After all, we know that having a documented process and a detailed paper trail is one of the very first things regulators look for should a potential conflict of interest arise.
Understanding the patterns behind conflicts of interest is similar to trying to calculate the exact pattern and location of lightning strikes; you just know they are going to happen during a thunderstorm and it’s to be expected.
Try looking at your conflicts of interest process through that same lens and be ok with not being a mind reader. Focus on being an effective compliance officer.
You do that by starting with establishing a conflict of interest policy and program, which starts right here with this disclosure template. The sample disclosure form covers everything from outside financial interests, business interests, personal interests, family members, gifts and much more. Download the form and get started today.
It is in the best interests of all organization members to have a clear understanding of what constitutes a potential conflict, and this conflict of interest disclosure form will help your decision making. It can also become the basis of important policy decisions and help set conflict of interest standards.
It’s designed for you to download it, make it your own by adding your brand language, adjusting the phrasing of the questions and then distribute to your board of directors and employees either electronically as a PDF or via hardcopy using the print option.
While the industry is moving toward a more automated and technologically aided approach to COI, this form can help ease the transition from a solely paper-based program into a more digital program with a stronger audit trail.
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