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Conflicts of Interest Sample Policy Template

Set clear expectations for identifying and managing conflicts of interest. Use this customizable sample policy to address disclosure requirements, personal and financial interests, outside activities and potential conflicts in business decisions.

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Two colleagues walk through a modern office hallway, engaged in conversation. The woman is holding and gesturing at a tablet, while the man listens, holding a laptop under his arm.

Establish clear standards for conflicts of interest

Identify potential conflicts

Give employees guidance for recognizing actual, potential or perceived conflicts of interest.

Set disclosure expectations

Establish when and how employees should disclose potential conflicts.

Define mitigation measures

Create a framework for managing conflicts through measures such as recusal, reassignment, divestment or other safeguards.

Three people in an office setting work together around a laptop. One person stands smiling and pointing at the screen, while the others sit, one looking at the laptop and one holding papers.

What to include in a conflicts of interest policy

A clear policy gives employees practical guidance for recognizing situations where personal interests or relationships could affect – or appear to affect – professional judgment. This sample Conflict of Interest Policy Template gives you a starting point where you can adapt to your organization’s needs, workforce and applicable requirements. 

Use the template to address: 

  • Actual, potential and perceived conflicts of interest 
  • Financial interests involving suppliers, customers, competitors and other third parties 
  • Outside employment, consulting engagements and board service 
  • Personal relationships, nepotism and favoritism risks 
  • Gifts, entertainment and hospitality 
  • Disclosure requirements and conflict certifications 
  • Evaluation and mitigation of disclosed conflicts 
  • Training, monitoring, reporting and enforcement 

The template is intended for general guidance and should be reviewed with qualified legal or compliance professionals to account for the requirements that apply to your organization and jurisdictions.

Start building your conflict of interest policy

Give your organization a practical starting point for identifying potential conflicts, setting clear disclosure expectations and establishing a consistent process for evaluating and managing conflicts of interest.