2024 Conflict of Interest Disclosure Planning

Fourth quarter is just around the corner, which means many are switching from vacation mode to back-to-school shopping. And compliance officers are turning their attention to planning next year’s conflict of interest disclosure activities.

In the workplace, Conflict of Interest (COI) refers to a scenario that could benefit an employee, their friend or family member, but is not necessarily in the employer’s best interest. For example, if a hiring manager selects a family member for a job position or a board member also serves on one of your competitor’s boards.

Conflict of interest issues often result in excessive spending and can also impact company morale and an organization’s overall reputation. And in many scenarios, it is against the law. To protect their organizations and bottom lines, many companies have a COI policy in place and processes to solicit and manage COI disclosures from employees. While this sounds simple enough, compliance officers that don’t optimize technology frequently lament that the COI implementation process is a thorn in their sides.

Here are just a few of the frustrations with COI that we commonly hear from compliance officers who have taken a manual or spreadsheet-based approach to COI:

• Time-consuming – “Chasing up paperwork and updating spreadsheets feels like a waste of time.”
• Nebulous – “It’s not always clear who needs to participate and how frequently.”
• Low priority – “The COI process feels like a check-the-box exercise, therefore not taken seriously.”
• Awkward – “While there are legitimate reasons to request disclosures, it can feel intrusive.”

Given these concerns, it is easy to see why some compliance officers dread the COI process. However, scrutiny of COI has never been higher, and ignoring the responsibility can be extremely costly.

Fortunately, there are steps compliance officers can take to ease the burden of collecting COI disclosures:

1. Ensure your Conflicts of Interest policy is clearly stated. If it takes a law degree for employees to understand precisely what is and isn’t permissible, go back to the drawing board.
2. Educate your employees on why COI disclosure is important. And make sure it is relatable. Employees need to understand how the policy relates to them personally and the steps to take to make a disclosure. The best way to communicate with today’s workforce is to show them. Whether presented as a short video or interactive microlearning, SAI360’s COI trainings feature relatable stories using real-world examples that employees can personally connect with in ways a single email never will. An effective COI training program helps employees grasp why their participation is critical, which helps make the entire process less uncomfortable.
3. Leverage technology to reduce manual processes and save time. SAI360’s automated, end-to-end COI disclosure solution can initiate, manage (including reminders and escalations), track, and report on an organization’s COI disclosure status. Policies and processes, as well as records, can be made easily accessible in a centralized platform for internal and external auditing, and an analytics dashboard provides quick visibility into real-time status.

A fresh approach to COI that focuses on education and leverages technology will not only protect your organization from risk, but it can also increase efficiencies, promote a positive workplace culture, and improve decision-making. Click here to learn more about SAI360’s Conflict of Interest Disclosure Software, including industry-specific solutions such as healthcare.

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