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5 Conflict of Interest Myths Debunked eBook

Think you know where conflict of interest risk comes from? The data may surprise you. Download this eBook to see what nearly 200,000 employee disclosures reveal about who reports conflicts, which risks appear most often and how leading organizations can build smarter disclosure programs.

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See what conflict of interest data really reveals

Challenge common assumptions

See how real employee disclosure data challenges conventional thinking about who creates COI risk and which conflicts matter most.

Benchmark your program

Compare your approach against insights from 198,549 conflict of interest disclosures submitted through NAVEX One Disclosure Management.

Target the right risks

Learn how employee role, geography and changing risk patterns can inform more targeted questionnaires, workflows and oversight.

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Your biggest conflict of interest risks may not be where you think

Conflict of interest disclosures help compliance teams spot risks early, but many programs are still built on assumptions about where those risks come from and who reports them. 

NAVEX analyzed 198,549 conflict of interest disclosures and found those assumptions don’t always hold. Individual contributors account for far more disclosures than executives, gifts and entertainment make up a small share, and patterns vary by role and region. 

Understanding these differences helps you focus resources where the real risk is.

Download the eBook to learn more

What nearly 200,000 disclosures tell us

Conflict of interest risk extends across the workforce – and the most common disclosures aren’t always the ones organizations expect.

  • 58.5%

    Individual contributors

    Nearly six in 10 disclosures were submitted by individual contributors, compared with just 3.6% from executives.

  • 29.2%

    Relationships

    Personal relationships were the most common disclosure category, ahead of outside employment and outside investments.

  • 3.80

    Disclosures per 100 employees

    Global disclosure rates increased from 3.42 per 100 employees in 2024 to 3.80 in 2025 – one sign that conflict of interest patterns continue to evolve.

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Inside the eBook

This eBook separates conflict of interest myth from reality using data from nearly 200,000 employee disclosures. 

Discover what the data reveals about: 

  • Who actually discloses conflicts – and the risks they report most often  
  • How disclosure patterns differ by employee role and geography  
  • Why a more targeted, adaptable approach can strengthen conflict of interest management 

See what the findings mean for your organization – and where your disclosure strategy may need to evolve.

Get your copy
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Is this eBook for you?

Download this eBook if you’re looking to: 

  • Understand where conflict of interest risk appears across your workforce and which categories are disclosed most often  
  • Benchmark your disclosure program against real-world employee data  
  • Tailor disclosure questions and workflows to different employee populations  
  • Use disclosure trends to improve policies, training and compliance oversight  
  • Turn disclosure data into meaningful compliance intelligence 

Whether you work in Ethics & Compliance, Legal, HR, Internal Audit or Risk Management, you’ll find data-driven insights to help you evaluate your current approach and build a more targeted conflict of interest program.

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Turn disclosure data into compliance intelligence

Every disclosure represents more than an individual event. Taken together, disclosures can reveal patterns in workforce behavior, emerging risks and areas where your compliance program may need to adapt. 

NAVEX helps organizations move beyond simply collecting conflict of interest forms with connected solutions for: 

  • Disclosure Management to centralize annual and ad hoc disclosures with configurable workflows, automated routing, AI-powered review and approval processes, audit-ready documentation and reporting. 
  • Ethics & Compliance Training to help employees recognize potential conflicts, understand when disclosure is appropriate and make decisions that support organizational integrity. 
  • Code of Conduct to establish clear expectations for ethical decision-making, transparency and employee disclosure responsibilities. 
  • NAVEX One to connect disclosure data with the broader ethics and compliance program, helping organizations identify trends, strengthen governance and make more informed, risk-based decisions.

With a more connected view of disclosure activity, compliance teams can turn individual disclosures into actionable intelligence – and continuously adapt their programs as risks evolve.

Frequently asked questions about conflict of interest management

  • What is a conflict of interest disclosure?

    A conflict of interest disclosure gives employees a way to identify personal, professional or financial circumstances that could conflict – or appear to conflict – with their responsibilities to the organization. Collecting disclosures helps organizations identify potential risks early and determine the appropriate response.

  • What are the most common types of conflict of interest disclosures?

    NAVEX’s analysis of 198,549 disclosures found that relationships were the most common category, accounting for 29.2% of disclosures. Outside employment accounted for 18.7%, followed by outside investments at 12.3% and board positions at 11.7%. Gifts and entertainment represented a much smaller share.

  • Are conflict of interest disclosures mainly an executive concern?

    No. The data shows conflict of interest disclosures occur throughout the workforce. Individual contributors submitted 58.5% of disclosures analyzed by NAVEX, managers accounted for 34.2% and executives just 3.6%. Effective programs therefore need to make disclosure accessible and relevant to employees at every level.

  • Should every employee receive the same conflict of interest questionnaire?

    Not necessarily. Different employee populations encounter different types of risk. In the NAVEX data, executives most frequently disclosed board positions, while relationships were the leading category among individual contributors and managers. Tailoring questions and workflows by role can improve both the employee experience and the quality of disclosure data.

  • Do conflict of interest risks differ by region?

    Yes. While relationships were the leading disclosure category in both the United States and EMEA/APAC, other patterns varied considerably. For example, family member employment represented 27.4% of EMEA/APAC disclosures analyzed, while outside employment represented 19.0% in the United States. Global programs should combine consistent governance with enough flexibility to account for regional regulations, cultures and workforce characteristics.

  • How often should organizations review their conflict of interest programs?

    Disclosure programs shouldn’t be treated as “set it and forget it.” NAVEX data shows meaningful year-over-year changes in both disclosure rates and categories. Regularly reviewing trends can help organizations update questionnaires, policies, training and workflows as workforce expectations and business risks evolve.

Explore more resources on conflict of interest management

  • Webinar Upcoming

    5 Conflict of Interest Myths Debunked

    How well do you really know conflicts of interest? Put five common myths to the test and learn what stronger conflict of interest programs do differently.

    Save your seat!

  • Webinar On-Demand

    Beyond Policy: Are You Capturing and Controlling Disclosure Risk?

    Most UK organisations have policies covering conflicts of interest, gifts and outside activities but lack visibility into how those risks are disclosed, reviewed and managed in practice. Join us to learn how to close the gap between policy and real-world risk through effective disclosure management.

    View on demand

  • 20 Jan 2026 NAVEX Editorial Team

    The Growing Importance of COI Management

    Building a compliance program with limited resources starts with consistency, not perfection. Learn how SMB leaders turn practical steps into lasting culture change.

    Read more

  • 30 Sep 2025 Press release

    CDL Nuclear Technologies Builds Centralized, Scalable Compliance Program with NAVEX as Trusted Advisor

    CDL Nuclear Technologies, a fast-growing leader in cardiac diagnostic solutions, has built a centralized compliance program to protect its culture, streamline processes, and scale with its rapid expansion. Under the leadership of Chief Compliance Officer Heather Hurst, CDL has transformed how its distributed workforce manages regulatory requirements while continuing to deliver trusted service to healthcare providers nationwide.

    Read the news

  • Course

    Code of Conduct Experience Training

    An all-video training course designed to resonate with today’s learners. Through realistic scenarios and interactive questions, it helps your employees reflect on ethical challenges they may face at work.

    Learn more about this course

  • Course

    Conflicts of Interest Training

    NAVEX’s Conflicts of Interest course helps you ethically navigate the workplace by identifying and managing potential conflicts. Learn strategies to recognize, avoid and respond to these situations – protecting both yourself and your organization.

    Learn more about this course

  • Datasheet

    NAVEX One GRC Insights Datasheet

    By leveraging NAVEX GRC Insights, your organization can seamlessly access comprehensive data through both standard and personalized reports that are designed for day-to-day use and board presentations.

    Get the datasheet

Are your conflict of interest assumptions backed by data?

Download 5 Conflict of Interest Myths Debunked to discover what nearly 200,000 employee disclosures reveal about today’s conflict of interest risks – and how those insights can help you build a smarter, more responsive disclosure program.

Download the eBook

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