Ensure that employees understand:
- their conflict of interest obligations
- the public duty reasons for them
- the policy and processes to follow.
Communications strategy
Develop and implement a communication strategy to make your organisation’s conflict of interest policy, processes and culture known and understood by:
- employees
- external stakeholders, such as suppliers and prospective suppliers.
The strategy will usually include:
- raising awareness about the policy, how it works and where to get information
- targeted communication in high risk areas or at high risk times.
Information for employees
We recommend that all employees be made aware of, and provided with ready access to, the documents listed below.
For example, provide links to these documents on a dedicated Conflict of Interest page on your organisation’s intranet.
Your organisation’s documents
- conflict of interest policy (employees)
- high risk areas for conflict of interest. If this is not yet determined for your organisation, refer instead to our list of typical areas of high risk areas.
- guidance on conflict of interest
- conflict of interest declaration and management plan form
- declaration of private interests (DOPI) form.
Commission guidance
The guidance we offer for employees and organisations on conflict of interest. For example:
- Conflict of interest key things to know and do
- Consensual personal relationships
- Declarable associations
- Duty or loyalty to another organisation or group
- Guide for manager’s on developing conflict of interest management plan.
Advice and support
Ensure your employees:
- are aware of who they can contact for advice about conflict of interests, and
- feel encouraged and supported to do so.
Usually, the employee’s direct manager will be the first point of advice. But ensure that alternative contacts exist. For example, your organisation’s human resources manager, integrity manager or conflict of interest officer.
Induction
Embed training about conflicts of interest and how to comply with your organisation’s policy into the induction process.
We recommend that conflict of interest training be a compulsory part of the induction/onboarding process.
Regular awareness raising and learning opportunities
Provide regular awareness raising and learning opportunities about conflict of interest. For example:
- make conflict of interest a regular agenda item in team meetings – this is an opportunity to foster awareness, a culture of integrity and discussion that can surface potential issues and opportunities
- publish ‘awareness raisers’ – such as news items or case studies
- link employees to other learning resources that are consistent with your organisation’s policy – such as the key things to know and do.
If resources permit, other strategies could include:
- short videos – such as senior leaders or a group of employees discussing conflict of interest issues or cases studies
- short digital modules that employees work through at their own pace
- interactive refresher training programs.
Targeted information and awareness
Provide targeted information and awareness for employees where there is added risk, obligations or processes. For example:
- employees involved in high risk areas or activities
- managers with direct reports
- employees, such as certain financial delegates and executives, who complete an annual Declaration of Private Interests (DOPI).
Declaration of Private Interests (DOPI) information and support
For employees who submit an annual DOPI:
- encourage a culture of seeking advice from their manager if they’re unsure what private interests to declare and when
- consider making it part of their annual performance review to ensure their DOPI is current
- if recruiting to fill a position where the successful candidate will be required to complete a DOPI, specify this in the position description.
Also provide an alternative source of advice, for example, if your organisation has an integrity officer.