When a conflict of interest disclosure reveals a potential, perceived or actual conflict of interest, a management strategy needs to be in place to document and proactively address questions that may arise regarding an individual’s objectivity, integrity or professional commitment as a result of the disclosed activity, relationship or financial interest.
A Conflict of Interest Management Strategy outlines the scope and nature of actions, conditions or restrictions put in place to manage, mitigate or eliminate any actual, potential or perceived conflict of interest.
What does such a Strategy include?
In some circumstances, simply the act of declaring he perceived, potential or actual conflict may be sufficient to adequately mitigate or manage the conflict.
Other strategies may include consideration of activities of the following nature:
- Removal from situation or conflict.
- Restricted involvement in the situation or conflict.
- Recruitment of an independent third party to oversee part or all of the process.
More significant conflicts may also involve consideration of:
- Relinquishing an interest which is ongoing, unacceptable and/or likely to cause damage
- as a last resort, Resigning from any held role.
More specifically, the options included in the strategy could be the following:
- taking no further action because the potential for conflict is minimal or can be eliminated by disclosure and effective supervision
- informing impacted persons of the disclosure and the decision that there is no conflict, or that the potential for conflict is minimal;
- appointing an independent third party to oversee the integrity of a decision process and assess potential conflict of interests;
- appointing extra persons to a panel or committee to minimise the influence of the individual about whom the perception of conflict is held;
- seeking the views of persons likely to be affected about the person continuing in a decision making process;
- restricting the access of the person to relevant information that is sensitive or confidential;
- requesting the person to relinquish or divest the personal interest which creates the conflict or to make other arrangements;
- removing the person from the responsibilities or duties to which the conflict relates;
- making arrangements for members of boards and committees to absent themselves from debate or decision on specific matters;
Conflict of interests need to be declared, evaluated and adequately managed. Ignoring them, as if they do not exist, will lead to potential tragic results for internal or external stakeholders.