The likelihood that your employees face significant conflicts of interest in the performance of their assigned roles is usually assumed to vary dramatically from industry to industry. In practice, it is the type of COI that most often varies. Senior executives in every industry can face COI’s when serving on boards of other companies or civic and community organizations. For the ‘worker bees’ on the front line, COI’s may be more mundane in nature, such as putting your nephew’s resume forward for an open position in your company. How your company differentiates these scenarios will determine your risk of non-compliance and potential damage to your company’s hard-earned reputation.
If COI disclosure in your organization is a simple process of sending out forms, logging the responses, and tracking renewals, then it is likely that a state of routine tedium has replaced the proactivity that is needed to manage the very real risk of COI’s. If, on the other hand, these three critical elements are in place, your COI disclosures are more likely to be in full compliance. They are:
COI’s are most often addressed as a ‘gateway’ issue, with much of the attention focused on catching any potential problems during new hire orientation. If your employees continue to bring potential COI concerns to you long after those initial training sessions, that’s evidence that they have embraced the message and understand the potential risks to the organization. In addition, requests for further documentation to support disclosed COI’s are met with prompt responses.
Once approved, employees share the responsibility for ongoing monitoring by providing regular updates as to the status of any disclosed COI. This may be nothing more than “no change,” or “nothing to report,” but it represents greater engagement than simply waiting for annual disclosure renewals, and represents a far more substantive process from a compliance perspective.
Disclosure forms are provided to all employees, irrespective of rank, with consistent escalation for any employees struggling with procrastination in responding to the request. HR/Compliance can endorse this process by proving percentage of completion updates to reinforce the message that everyone shares the responsibility for full COI disclosure.
Conflict of interest software offers comprehensive functionality and security needed to maintain a fully compliant and proactive COI management policy. Extensive automation capabilities allow detailed task assignment and notification with escalation capability for the procrastinators on your team. Role-based access restricts document-viewing privileges to assigned personnel only, and the real-time dashboard makes sure that all assigned tasks are managed in a timely and responsive manner. If your COI disclosure management policy includes periodic risk assessment audits, it is important that all summary data, including related supporting documentation, is able to be accessed quickly and easily.
If you’re ready to implement a truly effective COI policy, request a demo of ConvergePoint’s Conflict of Interest Software now, or download the data sheet here.