In business it pays to be prepared for just about anything, right? So if, right now, someone asked you for documentation on how your organization manages conflicts of interest, what would you do? Do you have a clearly defined, up-to-date mitigation plan ready to go? Or, would you be scrambling to assemble a policy from old emails and HR documents? Conflicts of interest aren’t just theoretical risks, they’re potential operational vulnerabilities. If your company doesn’t have one already, putting a strong organizational conflict of interest mitigation plan into place should be a priority.
Mitigation plans for COI ensure that if an issue does arise, a business can be ready, before a conflict escalates into a crisis. Without a plan, businesses risk legal consequences, regulatory complications, damaged reputations, and eroded trust from employees and other stakeholders.
If you don’t have a plan, or a plan for a plan, we’ve got you covered. In this article, we’ll break down the risks posed by conflicts of interest, as well as how to develop a comprehensive conflict of interest mitigation plan, from brainstorming through execution.
What is an Organizational Conflict of Interest?
It may be a mouthful, but at its core, an organizational conflict of interest is a pretty simple concept. Organizational COIs occur when the way a company is structured, the partnerships it undertakes, or its decision-making processes give rise to competing interests that could compromise its objectivity, and its ethical integrity.
Unlike personal conflicts of interest, which occur when an individual’s personal interests conflict with their ability to act impartially, organizational conflicts of interest are embedded in a company’s operations. Examples of this type of conflict may include sharing vendors, a company taking on dual contracts that compromise its impartiality, or utilizing biased procurement processes. Failure to address such conflicts could lead to compliance violations, lost business opportunities, and a breakdown of internal accountability.
Identifying Potential Conflicts Within the Organization
When seeking to reduce organizational COI, start by conducting a thorough risk assessment across all departments within the company. This assessment should aim to uncover potential sources for bias or influence. Areas of investigation may include relationships with vendors, arrangements with contractors or subcontractors, and strategic partnerships. Analyze and evaluate these factors for overlapping interests, or opportunities for insider advantages.
Don’t limit this risk assessment to current potential risk sources, either. Reviewing past incidents where conflicts of interest could or did arise can help reveal systemic issues and inform future strategies for your organizational conflict of interest mitigation plan.
Developing a Written Organizational Conflict of Interest Mitigation Plan
After gathering necessary data and identifying potential pain points, your organizational conflict of interest mitigation plan begins with a well-crafted, thoroughly drafted written policy. Make the process of brainstorming for and drafting this policy a collaborative one, sourcing input from relevant company stakeholders. This helps ensure that the resulting document will serve as a thorough, comprehensive resource.
A formal written plan for managing organizational COI should include clear definitions around potential sources of and different forms of conflict, all necessary disclosure requirements, and guidance for resolving conflicts when they do appear. Along with outlining procedures for addressing sources of COI, be sure to assign responsibility for oversight, reporting and decision-making to specific roles within the organization.
Again, make this process as collaborative as possible—and as accessible as possible. It’s much easier for employees to comply with rules when they understand them, so write directives using concise, actionable language. Once completed, give your employees the ability to access this policy whenever they need to reference it. If necessary, schedule regular periods of review for organizational conflict of interest policies, to make any needed changes and keep regulatory language as current as possible.
Necessary Tools For a Policy to Be Successful
Your organization could create the most beautifully worded, meticulously crafted COI policy in the world – and you should definitely try – but no organizational conflict of interest mitigation plan is truly complete without a couple more things:
A Training Program
Educate your employees on why your business has rules governing organizational conflicts of interest, and what those conflicts look like. Regular training helps them understand what constitutes a conflict of interest, and how to appropriately report instances if they see them. Training programs should include examples tailored to different roles and departments, to make them as relevant and engaging for participants as possible.
A Monitoring and Reporting Framework
Your organizational conflict of interest mitigation plan won’t mean much if your business isn’t capable of upholding and enforcing it. You’ll need a monitoring system in place to track disclosures, identify potential red flags in reporting, and document conflict of interest efforts when instances do occur. Conduct regular internal audits and COI reviews to assess the effectiveness of mitigation efforts, and to gauge and maintain compliance.
Make ComplianceBridge Part of Your Organizational Conflict of Interest Mitigation Plan
Your business needs a smart, secure, way to execute an effective organizational conflict of interest mitigation plan. Luckily, you won’t have to look far! ComplianceBridge’s team of policy experts and our automated conflict of interest software make conflict of interest audits faster and more efficient than ever.
Our COI management software simplifies the disclosure process while offering the flexibility to match your organization’s structure and needs. Build custom questionnaires with conditional follow-up questions and weighted responses. Use targeted distribution to send forms company-wide or to specific teams and departments, ensuring disclosures reach the right people.
After forms are distributed, automated notifications remind employees to complete their assignments—helping ensure nothing slips through the cracks. Meanwhile, our system tracks employee responses and participation in real time. The manager dashboard makes it easy to analyze trends, generate visual reports, and flag potentially problematic behavior. All data is securely stored in a centralized, cloud-based database with top-tier cybersecurity, creating a complete audit trail and supporting long-term compliance.
Protect your business from the harms of organizational conflicts of interest, and let us help! To find out more about how, contact ComplianceBridge for a demo today.
