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:


misuse of official position,

misuse of time and resources,  

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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