Writing a Conflict of Interest Policy

by Chris MacDonald, Ph.D.

All kinds of organizations need a Conflict of Interest policy. Experience suggests that many people have only a vague idea of what Conflict of Interest is, or how to deal with it. And yet dealing properly with COI is crucial to maintaining organizational integrity and reputation. A well-written policy is a great place to start. What should that policy look like? There are really three key considerations to keep in mind:

A) The first consideration is content. Your policy should include certain ingredients, including the following:1

  1. Approval / revision date. As with any policy, the inclusion of an approval or revision date signals that the document is current, and that it is important enough to be part of an updating process.
  2. Definition of Conflict of Interest. You don’t have to use my definition of conflict of interest. But you do need a definition. It should be clear and non-technical. It should be broad enough to include the full range of factors that can be expected to bias decision-making. So, for example, it should generally not be limited to “pecuniary interests” (i.e., financial interests).
  3. Examples of Conflict of Interest. Examples are a natural way to supplement a definition. Examples can be a great way of illustrating how COI pops up in your organization. COI at a bank, for example, is likely to take very different forms than COI on a municipal council.
  4. Procedures to follow. Your COI policy should outline the procedures that should be followed inorder to avoid COI, where possible, and to deal with COI when it occurs. Who should be notified? Are there forms to be filled out? Should I remove myself from decision-making? Are there exceptions? Who has the authority to grant exceptions?
  5. Pointers to additional sources of information. No policy can ever be exhaustive, or provide enough examples, or give enough detail about how COI should be handled. It is wise to give members of your organization pointers regarding where they should turn if they need more information. That might mean a pointer to other documents, or to key personnel within your organization.

B) The second consideration in devising a COI policy is readability. There’s little point in having a policy if members of your organization won’t read it and understand it. That means it cannot be written entirely in ‘legalese.’ In this regard, it can be handy to run your policy through a standardized readability test. Word-processors like MS Word are equipped to generate readability stats. You can also find services online (like this one, for example) that will assess (for free) any document you upload.

C) The final ingredient is not really an ingredient of the policy itself, but has to do with awareness and training. There’s absolutely no point in having a policy if no one knows about it. Members of your organization need to know the policy exists, and they need to have the opportunity to have their questions answered.

Finally, if you need help creating or revising your conflict of interest policy, let me know.

1Many of the ideas here are drawn from: Bryn Williams-Jones and Chris MacDoanld, “Conflict of Interest Policies at Canadian Universities: Clarity and Content,” Journal of Academic Ethics, (2008) 6:79–90 [PDF here]. Chris MacDonald is solely responsible for the form those ideas take on this website.