Having a conflict of interest policy is table stakes. Implementation and culture are what determine whether it actually protects your organization.
Moving Beyond Compliance Theater
- Annual disclosure is just the start: Create mechanisms for real-time disclosure
- Define “conflict” broadly: Include indirect interests and appearances of conflict
- Establish clear procedures: What happens when a conflict is disclosed?
- Document, document, document: Keep records of disclosures and recusals
Building a Culture of Transparency
The goal isn’t to eliminate all conflicts, which is often impossible, but to manage them openly and appropriately.