The Importance of a Robust Conflict of Interest Program 

Conflict of interest (COI) is a serious issue that can have a significant impact on organizations of all sizes and industries. A COI occurs when an individual or organization has a personal or financial interest that could influence their judgment or decision-making. This can lead to biased decisions, decreased productivity, and even legal liability. 

COIs—which involve situations where an individual or company has a common conflicting interest with decisions or actions that could impact the organization—are often overlooked and misunderstood, difficult to manage, and both subtle and complex at the same time. 

The Benefits of a Robust COI Program 

Most organizations are now taking steps to raise awareness of COI issues and remind employees of their obligations under the organization’s COI policies, with 80 percent conducting an annual COI campaign, according to a survey from the Association of Corporate Counsel. 

There are many benefits of having a robust COI program.  

3 Key Benefits of an Annual COI Program 

1. Organizations can help reduce their risk of legal liability in the event of a COI violation
2.  Organizations can help protect their reputation and avoid the negative consequences of a COI violation
3. Employees who feel confident their organization is taking COI seriously are more likely to be satisfied with their work and to be more productive

How to Develop a Robust COI Program 

Today’s COI software makes developing a COI program easier than ever, saving organizations time and costs while also ensuring compliance with the latest regulations.  

The first step in developing a robust COI program is to create a clear definition of what constitutes a COI. This definition should be tailored to the specific needs of the organization. Once a definition has been created, the organization can begin to identify and assess potential COIs. This can be done by conducting risk assessments, reviewing employee financial disclosures, and monitoring social media activity. 

Once potential COIs have been identified, the organization can develop mitigation strategies. These strategies may include: 

• Requiring employees to disclose potential COIs helps ensure the organization is aware of all potential COIs and can take steps to mitigate them 
• Providing training on COI prevention helps employees understand what constitutes COIs and how to avoid them 
• Establishing conflict management plans helps ensure a process in place to manage COIs that do arise 
• Implementing disciplinary measures for employees who violate COI policies helps deter employees from violating COI policies 

Ultimately, an effective COI program should include several key elements, including: 

• A clear definition of what constitutes a COI 
• A process for identifying and assessing potential COIs 
• Mitigation strategies for managing COIs 
• Training for employees on COI prevention 
• A system for reporting and investigating COIs 

The Importance of Annual COI Campaigns 

In addition to having a robust COI program in place, it is also important to conduct annual COI campaigns. These campaigns can raise awareness of COI issues and remind employees of their obligations under the organization’s COI policies. COI campaigns can also be used to update employees on the latest COI regulations and to provide them with training on new COI mitigation strategies. 

Here are some specific examples of how annual COI campaigns could be used to raise awareness of COI issues and remind employees of their obligations: 

• Email or intranet messages: Highlight recent COI cases, provide updates on COI regulations, and remind employees of the organization’s COI policies 
• Webinars or training sessions: Provide employees with more in-depth information about COI compliance 

• Posters or flyers: Placed in common areas around the organization to remind employees of COI policy 
• Lunch-and-learn sessions: Provide employees with an opportunity to ask questions about COI compliance 

By conducting annual COI campaigns, organizations can ensure employees are aware of their COI policies, which is the first step to compliance. This can protect the organization from COI risks and maintain public trust. 

The Benefits of Investing in COI Software 

Many organizations rely on the automated capabilities of a software solution to help manage COI programs such as: 

• Identifying potential COIs 
• Delivering training on COI prevention 
• Reporting and investigating COIs 

SAI360’s COI Solution 

SAI360’s Disclosure Management solution can help you streamline your COI program by automating many time-consuming tasks involved. Or if you are starting from scratch, it can auto-create a conflict management plan.  

Disclosure Management includes features that help you identify, assess, and mitigate COIs, including: 

• Compliance risk assessments 
• Reporting systems 
• Training modules 
• Investigation tools 

• Disciplinary action tools 

Final Thoughts 

A robust COI program is an essential part of any organization’s compliance program. By taking the time to develop and implement a COI program in the right way, organizations can protect themselves from legal liability, protect their reputation, and ensure employees are making decisions in the best interests of the organization. 

If you are ready to add automation and reduce administrative tasks, we have purpose-built software to solve your pain points. For more information: 

• Visit our Conflict of Interest Disclosure Software page on SAI360’s website.  

• Read our quick COI 101 Recap: https://www.sai360.com/resources/grc/compliance-grc/conflict-of-interest-what-you-need-to-know-blog  
• Grab a virtual coffee with us to learn about our demo and help us learn about your business needs by clicking here.