Creating a COI Program

Conflicts of Interest THE THREE PILLARS

OF COI MANAGEMENT
are the Root of Many
Regulatory Compliance
and Business Ethics Issues 1.

C o n f l i c t s o f i n t e re s t c re a t e a l l m a n n e r o f e t h i c a l ,
CLEAR POLICY:
TO DEFINE (1) A POTENTIAL CONFLICT,
re p u t a t i o n a l a n d re g u l a t o r y p ro b l e m s . C o m p a n i e s
(2) WHO MUST COMPLETE COI DISCLOSURE FORMS AND
m u s t b e a b l e t o f i n d a n d m a n a g e co n f l i c t s t o a n a p -
(3) WHO WILL REVIEW THOSE COI DISCLOSURES.
p ro p r i a t e re s o l u t i o n . C O I p ro g r a m s s h o u l d a i m fo r
1 0 0 % co m p l i a n ce a n d fo s t e r a s e n s e o f fa i r n e s s i n
t h e w o r k p l a ce , re d u ce t h e r i s k o f c i v i l l i t i g a t i o n a n d
h e l p t h e co m p a n y t o i d e n t i f y o t h e r i s s u e s .

S t r u c t u re d a n d m a n a g e d w e l l , y o u r C O I p ro g r a m 2.
c a n h e l p t h e co m p a n y b e m o re re s p o n s i v e t o p o t e n -
t i a l t ro u b l e o v e r a l l — a s t r a t e g i c c a p a b i l i t y e v e r y STRUCTURE AND PROCESS:
business should strive to achieve. COI FORMS FOR EMPLOYEES TO USE AND A SYSTEM
TO COLLECT DISCLOSURES, TRACK RESOLUTION
AND SUPPORT DATA ANALYTICS.

3.
LEADERSHIP:
BOTH FOR RESOLVING CONFLICTS OF INTEREST THAT MAY
ARISE AND TO FACILITATE A STRESS-FREE PROCESS AND
ENVIRONMENT FOR EMPLOYEES TO DISCLOSE COIS.

Creating a COI Program

A COI Management Solution to Fit Your Needs
Modern conflict-of-interest programs need technology to succeed. Without it, a business is overwhelmed with too many conflicts
to review, and COIs linger without remediation. But if you’re looking for a technological solution, you need to ensure you’re investing
in the right one for your needs—both for today and as your compliance program evolves. Two key things you should be looking for:

1. Technology should be fast, cost-effective 2. The technology should offer strong, precise
and scalable for users, allowing for: oversight and include:
• Targeted campaigns for flexible and precise • Pre-packaged templates and workflows
interaction within your organization. that can be modified for your business.

• Auto-provisioning of users supported through • Test environment to vet communications and

direct integration of HR System. processes prior to changes or full development.

• Automated review process for disclosures • Self-administration capability to allow modification

detected to have no potential conflicts. on your own time and cost schedule.

Designing the Ideal COI Management Process

An effective COI process should include capabilities to identify conflicts, remediate them and create complete audit trails of how
the company resolved them. Reviewing your current system’s COI process from disclosure through review and overall management
will give you an idea of some of the vital capabilities and features that, if added, would enhance and create more efficiencies in your
current process. A solution should support each stage of the COI process, as shown below.

Disclosure Submission Disclosure Review Case Management

D i s c l o s u re s u b m i s s i o n Q u i c k ly i d e n t i f y co n f l i c t s M a n a g e c a s e c re a t i o n a n d re v i e w
m u s t b e s i m p l e a n d fa s t . a n d e n s u re 1 0 0 % co m p l i a n ce . t o e f f i c i e n t ly re s o lv e co n f l i c t s .

Smart Forms with branching Ability to set organizational Management plan

logic to adapt in real-time thresholds, identifying conflicts development and tracking
to specific responses. in real-time. with 360° signoffs.

Applicable data can be Automatic reminders One audit-ready repository collects

pre-filled and carried over with escalations and stores all documents
from previous submission. to supervisors. and communication.

Single Sign-On (SSO) support CMS Open Payments integration Mitigation process that routes tasks
that provides easy access. to validate disclosures. according to conflict type.

ABOUT STEELE COMPLIANCE SOLUTIONS, INC.

Steele, a Diligent brand, is the global leader in Ethics & Compliance Management. We partner with
the world’s largest, most respected, companies to deliver compliance products and services that help
organizations embrace a culture of compliance while protecting their brand.
Learn more at STEELEGLOBAL.COM