Conflict of Interest Disclosure management requires a robust control system

Conflicts of interest can arise from the receipt of gifts or hospitality, personal relationships and personal or business financial interests.

The process of collecting, reviewing, responding to and monitoring actual and potential conflicts of interest is one that often falls down due to the lack of a robust control system. Establishing a gift and conflict of interest policy is the easy part. Ensuring compliance with the policy requires certain controls to be in place.

We have recently extended the signature feature within SC Spheres to make it easy to implement a robust gift and conflict of interest policy.

1. Disclosures at every meeting

Key Requirement: It is important to declare actual and potential conflicts of interest at every meeting where decisions are taken. Implementing a robust process for ensuring that this occurs has become more difficult with the now widespread practice of conducting virtual and hybrid meetings.

How SC Spheres Delivers: The signature feature withing SC Spheres has been extended to allow for the creation of one master disclosure form that can be added to a meeting agenda pack. The form can be completed and signed by each person who attends the meeting. They do this by finding the form in their agenda pack when preparing for the meeting or at the start of the meeting.

The person who creates the master disclosure form can see all of the responses in one central folder and is able to follow up with any meeting attendee who has not responded. All responses are timestamped and signed with a system that is tamper proof.

The disclosure form solution can also be used as an attendance register for meetings.

2. Central Register

Key Requirement: Maintaining a central register for Gift and Conflict of Interest declarations greatly simplifies the declaration process that would otherwise require the full details to be repeated at every meeting.

How SC Spheres Delivers: The disclosure form now built into the extended signature feature on SC Spheres allows for multiple forms to be completed by one individual and recognises that for many individuals no form will be required as no conflict of interest arises. By setting up the disclosure form in a central folder on the SC Spheres platform, it can fulfil the function of a central register for Gifts and Conflicts of Interests.

The signature feature works with any disclosure forms and the terminology and layout of the form can be customised to comply with your own governance requirements.

3. Compliance oversight

Key Requirement: Organisational leaders must be allowed to gain awareness of potential conflicts of interest and be able to engage with the conflicted individuals where necessary. Such engagement should be properly documented for compliance purposes.

How SC Spheres Delivers: The discussion feature within SC Spheres allows for the initiation of a multi-way conversation where documents can be shared and the discussion threat stored for record keeping purposes.

4. Confidentiality protection

Key Requirement: Some Conflicts of interest disclosures may contain sensitive personal information and will require a high level of protection. At a minimum, the disclosures should be maintained in a secure, password-protected system with restricted user access.

How SC Spheres Delivers: The extended signature feature allows for the individual disclosures to be hidden from users without administration rights or for all users to see all disclosures. This feature can be toggled on or off depending on the governance process that is being followed.

Conclusion

The extended signature feature within SC Spheres provides a robust control system for managing Conflict of interest declarations that is flexible enough to be implemented for most governance processes. For existing users of SC Spheres, the forms can be added to the existing agenda packs with minimal disruption to the meeting process and for no additional cost.

For Boards who are not using SC Spheres, a bespoke central conflict of interest register, and meeting declaration system can be implemented for below $40 per month for unlimited users and meetings.