Conflict of Interest Certifications – Part Two: Content

In a recent post we discussed the “why” and “who” of COI certifications.  Below, we examine what is typically covered by a COI certification.

First, the basics tend to be questions around the following issues:

– Employment (of oneself or family members) with or consulting for an entity doing or seeking to do business with or competing against the company.

– Holding a financial interest (again, involving oneself or family members) in the above-described types of organizations.

– Employment of relatives at the company.

– Gifts, entertainment and travel involving any person or entity doing or seeking to do business with the company (including loans involving such persons or entities).

Sometimes these questions are asked broadly, other times in terms of the employee’s area of responsibility (e.g., do you have any procurement- or management-related duties concerning any entity in which you or a family member have an ownership interest?)

Second, less frequently one also sees questions concerning:

– Any other outside employment or consulting (i.e., regardless of whether it involves a competitor, supplier, etc.)

– Service on a board (of directors or advisors).

– Anti-corruption requirements –  questions involving employees of governmental entities and, less commonly, union officials.

– Corporate opportunities.

– Purchases, sales or leases of property involving the company.

– Holding government office (presumably on a part-time basis) – which is generally relevant only to organizations that have significant dealings with a large number of local governmental bodies, like energy utilities; and

– Relationships with the company’s external auditors.

Finally, one should ask, in substance:  Do you have any other relationships, etc., that might reasonably be regarded as creating an actual or apparent conflict of interest with your responsibilities to the company?

I hope that readers of the Blog will use the comment feature to share any other issues or relationships that organizations might wish to consider for their COI certifications.

One Comment
  1. Jason Lunday 6 years ago

    Our Code of Conduct has a specific section on “Significant Personal Relationships” which includes both relationships with family members where a business connection could exist (when they serve as a vendor, contractor, customer, etc.) or relationships among employees that is intimate, romantic or sexual.

Leave a comment
*
**

*



* Required , ** will not be published.

*
= 4 + 0