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How to run a conflict of interest declaration process

By the EMPOBase team · · 4 min read

Short answer

Run conflict of interest declarations on a yearly cycle. Everyone who can influence a decision, including board members, managers and procurement staff, completes the same short form. A named person reviews every answer, decides how each conflict is managed, and records that decision. Add a duty to declare new conflicts as they arise during the year.

Key points

  • A conflict of interest is a situation, not an accusation; declaring it is the correct step.
  • Ask everyone who influences money, hiring or partners, not only senior staff.
  • Declare once a year and again whenever something changes.
  • Record how each conflict is managed, not only that it exists.

What counts as a conflict of interest?

A conflict of interest exists when a person’s own interests, or those of someone close to them, could affect their judgment in their role. Common examples in NGOs:

  • A manager’s relative owns a supplier that bids for a contract.
  • A board member sits on the board of another organization that applies for the same grant.
  • A staff member has a second job with a partner or a donor.
  • A program officer is asked to select beneficiaries and a family member could qualify.

Money is not the only kind. Friendships, favors owed, and family ties count too.

Who should declare?

Cover everyone who can influence a decision about money, people or partners:

  1. Board or trustee members.
  2. Senior management.
  3. Finance, procurement and logistics staff.
  4. Program staff who select partners, sites or participants.
  5. HR staff involved in hiring and discipline.
  6. Long-term consultants with decision power.

A short list is easy to defend. A rule that says “everyone, once a year” is simpler still and avoids arguments about who is in scope.

What should the form ask?

Keep it to one page. Ask:

  • Do you have any interest, role or relationship that could affect, or appear to affect, your decisions at this organization?
  • If yes: who is involved, what is the interest, and which decisions could it touch?
  • Do you promise to tell us if this changes?

Add a plain statement above the signature: “I have read the conflict of interest policy.” Provide a clear “none to declare” option so people do not feel they must invent something.

How to run the yearly process

  1. Set the date. Choose the same month every year, such as the start of the financial year, and tell people two weeks ahead.
  2. Send the form and the policy together. People should read the policy before they answer.
  3. Track who has replied. Follow up on gaps. A missing response is itself a finding.
  4. Review each answer. A named reviewer reads every declaration. Where something is declared, discuss it with the person.
  5. Decide how to manage it. Options include stepping out of a specific decision, handing a task to someone else, extra approval, or in rare cases ending the relationship.
  6. Record the decision. Write what was decided, by whom and when.
  7. Report to the board. Give a short summary: how many declared, how many conflicts exist and how they are managed. Avoid personal detail in the summary.

What about conflicts that appear during the year?

A yearly form is a snapshot. Real conflicts often appear mid-year, when a supplier bid lands or a relative applies for a job. Build two habits:

  • Declare at the start of a meeting. Add “any conflicts to declare?” to the agenda for board meetings, hiring panels and procurement committees. Minute the answer.
  • Declare before the decision. A person who spots a conflict tells their manager or the reviewer straight away and steps back from that decision.

Our article on conflict of interest in procurement goes deeper on supplier selection, where the risk is highest.

How do you keep records that stand up?

Keep the signed declarations, the reviewer’s notes and the management decision together, by year. When an auditor or donor asks how you handle conflicts, you can show the cycle: policy, declarations, review and decisions. Check local rules and donor agreements for how long to keep these records. Our guide to how long an NGO should keep its documents covers this.

A short example

A procurement officer declares that her brother runs a small transport firm. The reviewer does not punish her. They agree that she will not take part in any decision on transport suppliers, that a second officer will run those tenders, and that the declaration is noted in the file. A year later the brother’s firm bids. The record shows the rule was set in advance, and the officer stepped out as agreed.

That is the aim of the process. It is not to catch people out. It is to bring hidden ties into the open, early, so they can be managed calmly and fairly. If staff fear punishment for declaring, they will stay silent, and the process will fail. Say plainly, from the top, that declaring is expected and safe.

Also train reviewers. Give them a short guide on common cases and the usual ways of managing each, so decisions are consistent from one person to the next.

Where EMPOBase fits

EMPOBase has a Conflict of Interest area in Governance & Compliance where you can record disclosures and track annual certification submissions. You review outstanding submissions yourself, since a record does not renew by itself. See the platform overview or ask us for a demonstration. The software holds the record; deciding whether a situation is a real conflict still needs human judgment and your own policy.

Questions people ask

Is having a conflict of interest wrong?

No. Conflicts happen in every organization, especially small communities. The problem is hiding one or taking part in a decision while affected by it.

Who reviews the board chair's declaration?

Someone other than the person declaring. Often another board member, such as the chair of an audit or governance committee, reviews it.

What if someone refuses to sign?

Treat it as a governance issue. Explain why the process exists, and involve the board or senior leadership if the refusal continues. Nobody should keep a decision-making role without declaring.