Of the 8 million stories in the Big City, here are the ones about conflicts of interest
An area of recurring challenge for many C&E regimes is setting the right level of discipline for a given violation (COI-related or otherwise), a task often complicated by the lack of available precedent for any given case. For companies, precedent generally means prior internal case decisions that can meaningfully be used for guidance on a given matter. But small or medium-sized organizations will often lack critical mass of this sort. Occasionally, one learns of publicly available precedent from other entities in the private sector, although such instances are rare – and are typically limited to instances involving worst-case conduct.
In the public sector, however, more precedent is available. And, in the absence of anything else, public sector cases might be useful to a private sector entity looking for some guidance on meting out justice for COI transgressions.
For instance, the New York City Conflicts of Interest Board publishes a compendium of disciplinary actions concerning:
and many other types of COI-based wrongdoing.
Of course, disciplinary considerations in the public sector can differ from private sector ones in various ways. But for some companies – particularly those with little else to go on – this information may be useful.
Moreover, for organizations doing business with public sector entities, the data base can be helpful for other purposes, including:
– risk assessment, specifically, identifying situations at the intersection of public and private sectors likely to give rise to COIs; and
– developing “real-life” communications to employees on the causes and consequences of COIs.
When it comes to COIs, a good story can do a C&E program a world of good.
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