Disclose a possible conflict of interest
Northstar Works is a fictional organization used in this example. If a personal relationship, financial interest or outside role could affect a work decision, or look as if it does, raise it with the designated reviewer through the approved confidential route. Your applicable policy and that route govern real disclosures. This page helps you recognize the situation and prepare, and it does not submit or decide anything.
Is this a possible conflict?
Three common situations. If you are unsure which one is yours, ask the designated reviewer rather than deciding alone.
A relative's business is in play
A close relative owns or works for a company that is being considered for a contract, hire or purchase you can influence.
- Ask whether you help evaluate, recommend or approve it.
- Raise it before the decision, not after.
An outside role overlaps with your work
A board seat, side business, consulting engagement or investment touches the same customers, suppliers or decisions as your job.
- Note which work decisions it could touch.
- Disclose the role even if you have not yet acted on it.
A personal activity with no work link
A hobby, a community volunteer role or an investment in an unrelated field often has no connection to your work decisions.
- Check the applicable policy for any category it requires you to disclose.
- If the link is unclear, ask the designated reviewer.
Worked example: comparing suppliers
A fictional illustration of the facts to describe, not a ruling on any outcome
A procurement analyst at Northstar Works is asked to help compare three packaging suppliers for next year's contract. The analyst's sibling owns one of the three, Harbor Lane Packaging. Nothing has gone wrong. The analyst wants to raise it early and is not sure how much detail to give.
The facts that matter here
- Relationship: sibling, who owns the company.
- The supplier's role: one of three bidders for the packaging contract.
- Your involvement: building the comparison sheet and presenting it to the sourcing group.
- Upcoming decision: supplier selection, due at the end of next month.
A sample description
"My sibling owns Harbor Lane Packaging, which is bidding on next year's packaging contract. I am preparing the supplier comparison for the sourcing group, and selection is due at the end of next month. I have not discussed the bid with my sibling."
The designated reviewer decides what follows, such as whether to adjust your role in this decision. You do not need to propose a remedy or defend yourself.
Facts to prepare
Have these ready before you use the approved route. Share only what is relevant to the situation, and keep sensitive details out of ordinary email and chat.
The relationship or interest
- Who is involved and how they are connected to you
- The kind of interest: ownership, employment, investment, board seat, gift or other
- When it started or when you learned about it
The connection to your work
- Which work decisions or relationships it could touch
- When those decisions are due or likely to come up
- Any steps you have already taken, such as not taking part in a discussion
What happens after you raise it
The review handoff, in order. This page does not submit a disclosure or decide its outcome.
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1
Check the applicable policy
Read the conflict of interest policy that applies to your location and role. Your policy hub is the source of the rules.
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2
Use the approved confidential route
Submit through the system your organization authorizes for disclosures. If you do not know which one applies, ask Legal and Compliance first, without sending details.
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3
Describe the relevant facts
Use the facts you prepared above: relationship, connection to your work and timing. Answer what is asked and avoid adding unrelated personal information.
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4
Follow the reviewer's guidance
The designated reviewer looks at the facts and tells you what, if anything, to do next. Until you hear back, do not take part in the decision in question, and ask the reviewer if you are unsure how that applies.
Update a disclosure
A disclosure describes a moment in time, so keep it current
Tell the designated reviewer when something that mattered to your earlier disclosure changes. Typical triggers:
- Material facts change: your relative sells the business, or you take on a larger investment or a new outside role.
- Your responsibilities change: you move teams or take on approval authority that touches the same relationship.
- A new decision becomes relevant: the supplier you disclosed is now invited to bid on a different contract you will help evaluate.
Use the same authorized route, or ask the designated reviewer how they prefer to receive updates. Say what has changed and the date it changed.