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Considerations when creating or updating a conflicts of interest policy

Patty Houser (PLHouser@landolakes.com) is Compliance Counsel at Land O’Lakes, Inc. in Arden Hills, MN.

Conflicts of interest—these tricky shape shifters of the compliance world are never far from the headlines. Springing up in a multitude of contexts, they corrode ethical cultures, ruin reputations, and destroy trust.

But even with the amount of damage they can inflict, they can be difficult to anticipate and identify. Not surprisingly, the best defense includes a strong compliance program centered on a well-thought-out conflicts of interest (COI) policy. This article will explore how to either create your first stand-alone policy and disclosure process or how to update your current one, no matter your budget.

A conflict of interest arises when an employee’s personal interests conflict, or appear to conflict, with the company’s best interests. In other words, someone is, or is perceived to be, acting in way that benefits themself, or someone close to them, at the expense of the company.

Employees up and down the ladder can face conflicts of interests in a wide range of business settings. From accepting a bribe to ordering pizzas from your brother’s company, from improper use of insider information to personal use of office supplies, conflicts of interest wear many masks. Often, conflicts are personal in nature, which can make it difficult for employees to recognize them and for companies to address them.[1] And, while a conflict of interest increases the risk of poor judgment, the existence of a conflict doesn’t necessarily mean that anyone did anything wrong.

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