Conflicts of interest are more common than you think. Make disclosures about potential conflicts, including gifts, travel, entertainment and more, simple to manage and monitor over time with NAVEX One Disclosure Management.
No-paperwork, automated system
Real-time tracking and check-ins
Customizable to your structure
Managing disclosures shouldn’t feel like detective work. Bring everything into the open, from initial disclosure to final resolution.
With NAVEX One Disclosure Management, you can:
Set an ethical tone by incorporating annual and on-demand disclosure workflows, elevating your risk awareness.
Our disclosures solution molds to your world, not the other way around.
Buried under disclosure data? Let’s dig you out. Our tool gives you the insights to use your data to help, not hold back.
Save time, reduce errors and make disclosure management easier – all while safeguarding your organization.
Weave compliance into the fabric of your team’s day-to-day. With NAVEX professional services, compliance becomes more than a requirement – it’s a natural, empowering part of your workplace culture.
Embarking on your employee compliance journey? We’re right beside you. Together, we’ll dive into your specific needs and chart a path that’s just right for your team – and that doesn’t end with software setup. We’re committed to ensuring you’re comfortable and confident navigating NAVEX One.
At the heart of every success story is a supportive team – and that’s exactly what you get with NAVEX. Whether it’s a quick query or in-depth support, we’re here for you.
Whether you need to integrate multiple systems or kick off an organization-wide process improvement project, we’re here to help. Together, we’ll map out these complexities, ask the right questions, rally key stakeholders and prepare for challenges ahead of time. Whatever your starting point, we can help you make the most of your investment.
A practical guide for strengthening COI programs through clearer expectations, consistent oversight and modern technology.
A conflict of interest (COI) arises when personal relationships, financial interests or outside activities influence, or appear to influence, an employee’s judgment. A COI program helps organizations identify, assess and resolve these risks early.
During our recent webinar, speaker Michael Volkov emphasized that undisclosed conflicts, especially at senior levels, can erode trust quickly and undermine culture. Employees notice when leaders are held to different standards, which makes COI governance an important indicator of accountability and integrity.
A good rule of thumb is simple: everyone.
While senior leaders, people managers and procurement roles carry heightened exposure, all employees can encounter potential conflicts. Asking every employee to complete a disclosure reinforces fairness and encourages a speak-up culture.
New hires should complete a disclosure during onboarding, and all employees should reconfirm annually. Volkov noted that treating all roles consistently helps create a culture where transparency is expected.
Best practice includes:
Technology can streamline this workflow by repopulating past answers and prompting employees to confirm whether details remain accurate. This reduces administrative burden while improving completeness.
Most organizations use a tiered approach:
A formal escalation policy helps avoid real or perceived bias and ensures that reviews are handled consistently. This structure is essential for fairness and credibility.
Boards should receive regular compliance reporting, including COI metrics and trends. DOJ expectations reinforce that boards must have visibility into the health of an organization’s culture.
However, individual COI cases are usually reviewed by internal ethics committees unless the disclosure involves:
Boards mostly need oversight, not immersion in operational decisions.
Documentation is one of the strongest indicators of accountability.
Regulators expect organizations to:
As Michael Volkov noted, “If you cannot produce documentation, regulators will not believe you.”
Clear COI policies typically address:
Simple and consistent language helps remove ambiguity and reinforces fairness.
Provide employees with examples across a spectrum. For instance:
The key is perception. Even if a situation is not an actual conflict, the appearance of one can damage trust. Clear definitions and relatable examples help employees understand when to disclose.
Gifts, meals, entertainment and travel (GMET) are among the most common sources of conflicts. Expectations should include:
Because this is a seasonal pain point, especially during the holidays, employees benefit from quick access to guidance such as micro-learnings or automated policy lookup tools.
Fairness requires:
Organizations should periodically review trends to confirm that decisions are being applied evenly.
Employees value transparency, but confidentiality must be preserved. Many organizations share de-identified examples in:
Volkov noted that anonymized summaries help strengthen culture by showing that concerns are taken seriously.
Manual processes such as email, spreadsheets and inbox archives create inconsistency and risk. Modern COI technology reduces workload through:
Large organizations especially benefit from automation because they may manage thousands of disclosures each year.
Anonymous reporting is usually handled through the hotline. For disclosures:
This helps employees who may need assistance while still maintaining process integrity.
Yes. Integrations support:
When COI data is paired with HR or vendor data, teams can also identify relationships or activities that require closer review.
Analytics can uncover insights such as:
During the webinar, one example highlighted how more than a dozen employees in the same department had outside employment with the same company. This pattern only became clear through analytics.
COIs often appear alongside other risks, including fraud, bribery and third-party misconduct. Volkov noted that many bribery or trade violations begin with an overlooked or undisclosed conflict.
This makes COI data valuable for:
While DOJ does not issue COI-specific regulations, its expectations remain clear. Organizations should demonstrate:
COI handling is often viewed as a reflection of broader compliance maturity.
Explore additional resources, including:
Webinars
Effectively managing risk through today’s global macro-economic conditions, geopolitical turmoil, evolving regulations, and empowered employees requires proactive governance and organization-wide visibility - from front-line workers to back-office applications.
View on demand
Datasheets
Our conflict of interest management software solution, Disclosures, helps you identify, prioritize, mitigate and communicate disclosure-based risk.
Get the datasheet
White Papers
Learn the key elements of a robust risk and compliance program to effectively manage conflicts of interest within an organization.
Get the white paper
Your approach to disclosures shapes not just compliance, but also the trust and respect you gain from your people. Set a new standard in transparency with NAVEX One Disclosure Management.