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Articles and guides on conflict of interest disclosure on how to properly handle potential conflicts.
Strategies on building frameworks for managing risks and staying up to date with regulatory developments.
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?
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.
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.
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.
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.
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.
Read our free datasheet, which provides a quick overview of ConvergePoint’s Conflict of Interest (COI) Disclosure Software, built on Microsoft SharePoint. Download now.
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.
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 SharePointoffers 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.
After investing time and resources creating these policies, make sure employees read, understand and apply them to their daily job responsibilities! How? Read the Guide on How to Ensure Employee Accountability & Compliance through Effective Policy Management.
Disclose alumni contributions, hiring practices, partnership details, and promotional endeavors.
Oversee disclosure conflicts, employee hiring practices, contributions from outside organizations, and legal ties
Manage conflicts of interest, employee investments, familial ties, and competitor links.
Supervise stakeholder ties, employee investments, corporate contributions, and political connections.
View ownership interests from employees, financial contributions, family connections, and legal involvement.
Handle employee connections with board members, corporate gifts, political connections, and environmental regulations.
Outline conflict of interest protocols for third-party providers and brokers, upper management, and mitigate driver and pilot COI breaches.
Visit our resource library for industry best practice tips and for case studies on how our software has helped clients in your industry.