Self-assessing your COI program
Compliance and ethics program assessments sometimes have a general scope and are sometimes focused on a single substantive risk area—such as corruption or competition law. For some companies, it makes sense to do such a targeted/deep dive assessment for conflicts of interest (COIs). This is particularly so for those responding to a significant COI violation or “near miss,” but it is also the case where the likelihood of COI risks is heightened due to geographic, organizational, or industry cultural considerations. The scope and approach of such assessments for any given company at any given time should vary based on various circumstances. Though, as a general matter, what does one look for in a COI program assessment? Risk assessment : Has the company assessed COI risk? If so, has it been done in a documented way? Has it used the assessment(s) results in designing and implementing other aspects of the COI program? Governance : Have the respective COI oversight roles of the board of di...