When employees are asked to disclose conflicts of interest (COI’s) in orientation or refresher training, or receive regular email requests from HR or Compliance, the ease with which such enquiries are dismissed can be quite alarming. The assumption that since they’re doing nothing illegal or wrong, they have no COI’s is often the hardest obstacle to overcome in COI management. It is the potential for impropriety that carries the risk in terms of both compliance and damage to the company’s reputation, regardless of whether any action is ever taken on that potential. On that basis, there are five signs to look for in assessing the effectiveness of your COI management policies:
- Extensive Training
COI’s and the dangers of perceived impropriety should be addressed in detail at both new hire orientation and refresher training sessions. Ideally, that training should include industry/business specific examples to ensure that employees fully understand how quickly COI’s can develop in regular business practice.
- Evidence of Clear Understanding of the Need for Disclosure
Post-training acknowledgments and regular reminders from HR/Compliance can provide evidence of comprehension of the importance of COI disclosure, but to be truly effective, employees should be disclosing concerns of their own volition, even if those concerns do not turn out to be formal COI’s.
- A Comprehensive Review and Approval Process for all Submitted COI Disclosures
When employees are responsive to potential COI disclosure requests, an effective COI protocol should ensure that they receive a timely and detailed response, even if that response is a request for further clarification before a decision can be made. Requests for disclosure should also clarify the potential outcomes of the disclosure, including clarification that there is no COI, acknowledgment and agreed monitoring of the disclosed COI, and a formal request of recusal to avoid the COI entirely.
- Secure Storage
Any audit will request all relevant documentation pertaining to a COI. The chain of evidence has to include everything from the initial disclosure request up to the last renewal, including all supporting documentation and review and approval paperwork from assigned personnel.
- Periodic Comprehensive Risk Assessment
Over an extended period, devoting attention to potential outcomes that never materialize can get tedious, leading to the risk of automatic disclosure renewal without investigation. An explicit commitment to comprehensive risk assessment, preferably by a third party organization, can ensure that disclosed COI’s, especially for the more senior members of the leadership team (who are more likely to serve on other boards or advisory committees), are examined thoroughly before renewal.
Our Conflict of Interest Disclosure Software on SharePoint offers the functionality and security needed to maintain a fully compliant and proactive COI management policy. Integrating with Microsoft Active Directory ensures that all new employees receive COI disclosure notifications and are assigned to new hire orientation. Comprehensive automation capability allows 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 manner.
If you’re ready to implement a truly effective COI policy, request a free no obligation demo now, or download the whitepaper here.