Conflict of interest certification best practices

As noted in an earlier post, the Ethics & Compliance Initiative has recently published a COI best practices report written by a research working group which I co-chaired (along with Mark Snyderman of Laureate Education). Here are some of the report’s findings and recommendations on the important topic of COI certifications (“COIC”):

– Using a written COIC instead of simply requiring disclosure

– Including a section about the COIC requirement in the organization’s code [of conduct]

– Providing guidance and training to assist employees in completing the COIC

– Dedicating resources to respond to COI questions and address issues related to reported potential conflicts, including coordination within the organization’s control groups such as HR, E&C, and legal, and protecting the confidentiality of COIC responses

– Requiring new hires to sign or complete a COIC

– Evaluating the need for additional customized COICs (i.e., COIC specific to risk area or employee group)

– Distributing a COIC annual report or summary to senior executives and governance committee(s)

– Retaining and storing completed COICs in accordance with the organization’s record retention policy

– Establishing expectations and a schedule for periodic recertification (semi-annual, annual, ad hoc self-reporting).

Of course, to most C&E professionals some of these will be fairly obvious (e.g., periodic recertification) but others of may not be (such as the recommendations concerning the COI annual report or customized COICs). And hopefully, having a list of this sort itself will be useful to those launching or revisiting COI certifications for their respective companies.

Finally, some earlier posts on certifications can be found here  and here.

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