Jeffrey M. Kaplan (jkaplan@kaplanwalker.com) is a Partner with Kaplan & Walker LLP in Princeton, New Jersey, USA.

Whether drafting a code of conduct or other compliance and ethics policy documents, developing training, designing audit protocols, conducting a risk or program assessment, or creating compliance and ethics metrics, it can be useful to bear in mind the relationships between conflicts of interest (COI), corruption, and fraud—particularly given the extent of overlap among these areas. The following is an overview of these connections, but note that it is offered only for general principles.