Conflict of interest (COI) disclosure operates on a trust system. New hire orientation training and occasional refresher training sessions bring up the issue and request the submission of disclosure forms with no real sense of how many of the potential COI’s in the company are really being disclosed. The importance of the issue and the inherent risks to compliance and to the company’s reputation can be reinforced in regular communication, but if employees aren’t engaged, it is too easy for them to ‘zone out’ and to ignore the issue completely.
For those companies following a more strict C&E (compliance and enforcement) approach to COI’s, a comprehensive risk assessment is the best approach to quantifying how well you are managing the issue of COI disclosure. However, if you are seeking to avoid an embarrassing report, how can you gauge your readiness for a risk assessment?
- A Clear Sense of Purpose
Preparing for a risk assessment because you are committed to full compliance is a very different objective than preparing for it because you think there are gaps in your current COI disclosure process.
- Full Executive Engagement
The senior executives of any large organization are powerful people, and approaching the issue of potential improprieties in their involvement with multiple corporate boards and other business interests has to be undertaken with considerable tact. However, without full executive engagement in the process, those senior personnel could turn out to be your biggest compliance risks.
- Established COI Disclosure Protocols
If your current COI disclosure process has been developed in an ad hoc manner over multiple fire-fighting episodes, you will not survive even the most rudimentary risk assessment. Evidence of established rules and procedures, along with active supervision by authorized personnel is critical to the establishment of a solid foundation.
- Comprehensive Software Solution
An excel spreadsheet and an email list do not constitute a comprehensive software solution. Unless all supporting documentation and activity logs have been securely stored in a central portal, you are unlikely to be able to pull together the necessary data to answer case-specific questions from an auditor.
- Solid Resource Commitments
Risk assessments that result in gold stars and a pat on the back are as rare as unicorns. Most result in (hopefully short) lists of items to be addressed, with the assumption that the resources are going to be available to address them. Failure to follow-through can have a longer-term impact on employee morale and ongoing engagement in the COI disclosure process.
A comprehensive risk assessment represents a far more substantive commitment to COI disclosure than simply logging submitted forms on an Excel spreadsheet. Our Conflict of Interest Disclosure Software on SharePoint offers the comprehensive functionality and data security needed to maintain a fully compliant and proactive COI management policy and to keep your system ready for a full risk assessment. Comprehensive 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 manner. Any requests for supporting documentation from a risk auditor can be handled quickly and easily.
If you’re planning a comprehensive risk assessment, request a free no obligation demo now, or download the whitepaper here.