Conflict of Interest Disclosure
A practical employee page for spotting a possible conflict of interest, preparing relevant facts, using your organization’s approved confidential route, and updating a disclosure when circumstances change.
Every employee gets a seat — priced per employee in Communications & Intranet, quoted with this template ready.
Rolled out to every employee at AutoZone (125,000), PetSmart (50,000+), A.S. Watson and Raley's (20,000) — and at larger retailers we are not permitted to name.
Built for: Manufacturing and procurement · Financial services · Healthcare · Government and public administration
Overview
The Conflict of Interest Disclosure page is an employee-facing reference for recognizing a possible conflict, preparing a factual account, finding the organization’s approved confidential route, and understanding the review handoff. It opens with the core test: a personal relationship, financial interest, or outside role may warrant attention if it could affect—or appear to affect—a work decision. Three scenario cards help employees distinguish a relative’s business in a decision, an overlapping outside role, and an activity with no apparent work connection.
A fictional supplier-selection example shows the level of detail an employee can provide: the relationship, the supplier’s role, the employee’s involvement, and decision timing. The page then lists facts to prepare, describes the sequence from checking the applicable policy through following reviewer guidance, and explains when to update an earlier disclosure. Help is assigned to Legal and Compliance and the conflict of interest policy owner, without inventing contact details or a submission link.
Use this page as an orientation and reference alongside the applicable policy, especially before an employee takes part in a decision involving a connected person, company, or outside role. It is not a disclosure form, confidential reporting channel, policy substitute, or decision tool. Do not use it to promise a particular outcome or to decide that a situation is harmless. Before publishing, confirm the organization’s policy scope, reviewer roles, and actual confidential route; employees should use that route for sensitive details and ask the designated reviewer when participation is unclear.
Standards & compliance context
- The page tells employees to follow the conflict of interest policy that applies to their location and role; it does not establish legal requirements or substitute for that policy.
- The approved confidential route and designated reviewer must be confirmed by the organization before publication; this page itself does not collect or transmit disclosures.
- The fictional Northstar Works supplier example illustrates relevant facts, not a finding, required remedy, or regulatory interpretation.
- Keep the page accessible to its intended audience, including keyboard and screen-reader users, and use clear headings and descriptive link text consistent with WCAG 2.1 AA practices.
General regulatory context for orientation only — verify current requirements with counsel or the relevant agency before relying on this template for compliance.
What's inside this template
Disclose a possible conflict of interest
Start here to understand when a personal connection or outside interest may need to be raised and where the organization’s policy and confidential route govern.
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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?
These scenarios help distinguish a work-related connection from an activity that may have no apparent link to work.
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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
See how to describe a fictional supplier relationship using concrete facts without suggesting a particular outcome.
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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
Gather the relationship, work connection, timing, and steps already taken before using the confidential route.
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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
Follow the handoff from checking the policy to receiving guidance from the designated reviewer.
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The review handoff, in order. This page does not submit a disclosure or decide its outcome. 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. 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. 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. 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
Use this guidance when relevant facts, responsibilities, or work decisions change after an earlier disclosure.
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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.
Who can help
Find the appropriate role for questions about the reporting route or how the policy applies.
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Which disclosure route applies to me? Ask about the route only, and keep details for the confidential system. Legal and Compliance Questions about what the policy covers and how it applies to your role or location Conflict of interest policy owner
How to use this template
- Confirm the applicable conflict of interest policy, the employee groups and locations it covers, the designated reviewer roles, and the organization’s approved confidential route.
- Publish the page where employees can find it before procurement, hiring, investment, or other decisions where personal interests may arise, and add a verified link to the policy and reporting route if the page supports those destinations.
- Ask the employee to identify the relationship or interest, its connection to their work, relevant timing, and any steps already taken, without collecting unrelated personal information on the page.
- Direct the employee to submit through the authorized confidential route; if the route is unknown, have them ask Legal and Compliance about the route without sending disclosure details through ordinary email or chat.
- Have the employee follow the designated reviewer’s guidance and ask the reviewer before participating if it is unclear whether a pending decision is affected.
- Tell employees to update the disclosure through the authorized route when material facts, responsibilities, or relevant work decisions change.
Best practices
- Keep the policy and confidential route easy to locate, and verify every linked destination before publishing.
- Preserve the distinction between a possible conflict and a reviewer’s determination; do not present the examples as automatic rulings.
- Encourage employees to raise relevant facts before a decision rather than waiting until after they have participated.
- Ask employees to state the relationship, work connection, timing, and actions already taken in plain, factual language.
- Keep sensitive disclosure details out of ordinary email, chat, and public page comments.
- Make the reviewer handoff explicit and tell employees to ask before participating when interim guidance is unclear.
- Review the page whenever the applicable policy, reporting route, reviewer roles, or employee scope changes.
- Label fictional examples clearly and replace them only with approved, appropriately anonymized examples.
What this template typically catches
Issues teams running this template most often surface in practice:
Common use cases
Frequently asked questions
What situations should an employee raise as a possible conflict?
Raise a situation when a personal relationship, financial interest, outside role, gift, or other connection could affect—or appear to affect—a work decision. Examples include a relative’s company bidding on a contract you help evaluate, or an outside role that overlaps with your work. An unrelated hobby or investment may have no work connection, but check the policy if it is unclear.
Who should make and review a disclosure?
The employee with the relevant interest or relationship should use the organization’s approved confidential route. A designated reviewer assesses the facts and explains any next steps. The page directs employees to ask Legal and Compliance which route applies if they are unsure, without sending sensitive details through ordinary email or chat.
When should an employee disclose a possible conflict?
Raise it as soon as a relevant situation is known, preferably before participating in the decision it may affect. The worked example shows an employee raising a sibling’s connection before supplier selection. Follow the applicable policy for any required timing or process.
How often should an existing disclosure be updated?
Update it when material facts change, responsibilities shift, or a new work decision makes the relationship relevant. Examples include a relative selling a business, gaining approval authority, or a disclosed supplier entering another selection process. Use the authorized route or ask the reviewer how updates should be submitted.
Does this page determine whether a conflict exists or what remedy is required?
No. It helps an employee recognize and describe a possible conflict, but it does not submit a disclosure or decide its outcome. The applicable policy and designated reviewer govern the assessment. Do not propose a remedy as a substitute for giving the reviewer the relevant facts.
What should employees include in a disclosure?
Describe who is involved and their connection to you, the kind of interest, when it began or became known, and which work decisions it could touch. Include relevant timing and any steps already taken, such as not joining a discussion. Share only information relevant to the situation and answer the approved route’s questions.
Can this template be used as a disclosure form or integrated reporting workflow?
No. It is an informational employee page, not a submission form, case-management system, or approval workflow. The organization must identify and link its actual authorized confidential route. Do not imply that reading the page submits a disclosure or alerts a reviewer.
How should an organization customize and roll out this page?
Confirm the applicable policy, audience, designated reviewer roles, and approved confidential route before publishing. Replace the fictional Northstar Works example with clearly identified sample content or an approved local example, and provide a working link only when the destination is verified. Check the page with Legal and Compliance and make it easy to find before employees face procurement, hiring, or other relevant decisions.
What is the risk of handling a possible conflict informally?
An informal conversation may leave out relevant facts, fail to reach the designated reviewer, or place sensitive details in ordinary email or chat. This page instead prompts employees to prepare a concise account and use the authorized route. If an employee is unsure whether to participate while waiting for guidance, they should ask the reviewer.
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Ready to use this template?
Every employee gets a seat. Request pricing for Communications & Intranet and we quote into a workspace with Conflict of Interest Disclosure ready.
Rolled out to every employee at AutoZone (125,000), PetSmart (50,000+), A.S. Watson and Raley's (20,000) — and at larger retailers we are not permitted to name.
