Why conflicts of interest deserve renewed attention
Conflicts of interest have long existed in organizations, but expectations surrounding their management have evolved. During our recent webinar, “Conflicts of Interest in 2025 – Navigating Disclosure, Risk, and Accountability,” leaders noted an increase in COI questions, more complex scenarios, and heightened scrutiny from employees and regulators. These patterns align with NAVEX benchmark findings that show rising concern about relationship-based conflicts and other COI risks.
This trend reflects a broader reality: COI management has become a key measure of culture, trust, and ethical leadership.
To help teams strengthen their approach, NAVEX created a Conflicts of Interest FAQ, a resource that gathers attendee questions, examples and guidance discussed during the session.
Conflicts of Interest in 2025: Navigating Disclosure, Risk, and Accountability
Explore DOJ and global compliance expectations for conflicts of interest and see how to strengthen disclosure, oversight, and accountability.
COI management expectations continue to rise
Employees notice how organizations handle conflicts, especially at leadership levels. Michael Volkov of The Volkov Group emphasized that a single undisclosed conflict at the senior level can quickly undermine trust and damage culture. NAVEX research shows a similar pattern. Relationship-based conflicts are among the top COI issues reported, anonymous COI reports are increasing and substantiation rates for COI concerns have grown.
These signals show a workforce that is more aware of conflicts and more willing to speak up when expectations are unclear.
Annual declarations are no longer enough
Annual declarations remain a best practice, but strong COI programs go further. Organizations that want more consistency and defensibility often:
- Include disclosures during onboarding
- Require interim updates when circumstances change
- Use clear escalation paths for sensitive or senior-level conflicts
- Provide examples to help employees understand what should be disclosed
- Apply consistent review criteria
- Document decisions thoroughly
These practices help organizations move from moment-in-time disclosure to continuous awareness.
COI technology improves consistency and reduces manual work
Manual COI tracking creates unnecessary risk. Emails, spreadsheets and saved documents can be lost or handled inconsistently. Modern COI technology helps compliance teams:
- Route disclosures to the correct reviewer
- Reduce manual effort and follow up
- Identify trends or repeated concerns
- Maintain a defensible audit trail
- Provide a simple, accessible process for employees
Automation helps ensure a more consistent and fair approach, making it easier to demonstrate how COI concerns are handled.
Strengthening COI management in 2025
Clear processes and strong visibility help organizations manage conflicts with consistency and care.
Make disclosures accessible and expected
Include disclosures in onboarding and require annual reaffirmation. Encourage interim updates when circumstances change.
Establish clear review and escalation paths
Create workflows that guide routine reviews and ensure complex or executive-level disclosures receive independent oversight.
Use automation to reduce administrative burden
Automated routing, reminders and analytics help teams focus on decisions rather than manual tasks.
Document decisions thoroughly
Records of reviews, communications and resolutions help demonstrate fairness and meet regulatory expectations.
Share anonymized insights to build trust
De-identified examples reinforce expectations without revealing sensitive details.
COI Disclosure Management
Make disclosures about potential conflicts simple to manage and monitor over time with NAVEX One Disclosure Management.
COI trends worth watching
Recent NAVEX data and webinar insights highlight how COI risks continue to evolve.
- 50% of organizations faced a significant compliance issue in the past three years. Many involved conflicts or relationship-based concerns.
- 32 days represents the median closure time for COI concerns in the NAVEX benchmark dataset that Michael Volkov discussed. Faster resolution reflects well-defined processes and clearer escalation paths.
- 28% of COI reports relate to personal or romantic relationships. These conflicts often remain undisclosed until raised through internal reporting channels.
If COI reviews are not documented, regulators will not believe the organization handled them properly.
The Volkov Law Group PC
Michael Volkov
CEO
Conflicts of interest: quick answers to common questions
What should a COI policy include?
Definitions, examples, disclosure expectations, review criteria and escalation pathways.
Who should complete a COI disclosure?
All employees should complete disclosures annually and during onboarding. Interim updates should occur as circumstances change.
How does COI technology help manage risk?
Technology automates routing, tracks decisions, maintains audit trails and helps identify patterns.
How transparent should we be when communicating outcomes?
Share de-identified examples to maintain confidentiality while reinforcing expectations.
Looking ahead: strengthening culture through COI clarity
Strengthening COI programs is not only about meeting regulatory expectations. It is also a meaningful opportunity to reinforce your culture, support employee trust and ensure decisions across the organization remain fair and transparent. By pairing clear processes with modern tools and thoughtful communication, compliance teams can help their organizations navigate COI challenges with confidence and consistency.
