Conflict of Interest: The Integrity Risk You Can’t Overlook
Conflict of interest (COI) might not spark the same level of alarm as bribery or fraud—but its impact can be just as serious. Unmanaged conflicts can shape decisions, strain credibility, and create openings for serious and damaging misconduct.
In recent years, expectations around COI have shifted. The 2025 update to ISO 37001, the global standard for anti-bribery systems, reinforces the idea that managing conflicts of interest is no longer optional—it’s essential to safeguarding integrity.
Actual, Potential, and Perceived: What’s the Difference?
One of the most common challenges in managing COI is confusion around terminology. Without clear language, it’s hard to know when something truly poses a risk—or when it’s simply misunderstood.
Here are three key types to recognize:
Actual conflict: The interest has already compromised someone’s objectivity
Potential conflict: A situation exists where a conflict could arise in the future
Perceived conflict: There may not be a real conflict, but it appears questionable to others
Each type carries a different level of risk, and each requires a different response. Not all conflicts lead to misconduct—but ignoring them creates space for doubt and potential abuse.
What’s Changing?
Global standards like ISO 37001:2025 are calling for more structured, transparent COI oversight. The shift is away from informal disclosure toward systems that are clear, documented, and consistently applied.
Organizations are now expected to move beyond surface-level definitions. They’re being asked to design processes that help surface conflicts early—and manage them with clarity and consistency.
This includes:
Clearer policies on what must be disclosed
Decision-making checks for high-risk roles
Training to normalize and de-stigmatize disclosure
Systems to log and review declarations
Regular updates, not just one-time forms or verbal conversations
This isn’t just about preventing misconduct—it’s about reinforcing fairness, transparency, and accountability across the organization.
Managing COI in Practice
Managing conflict doesn’t mean halting every decision or removing people at the first sign of overlap. It’s about creating space for safe, early disclosure—so issues can be addressed before they escalate.
That means:
Making disclosure a routine part of organizational life
Offering practical examples of what counts as a conflict
Considering the role and influence of everyone involved
Responding to disclosures consistently and fairly
It’s also important to remember: not all conflicts are disallowed. When disclosed properly, many conflicts can be approved with appropriate mitigation steps. Transparency opens the door for informed decisions, not just restrictions.
By framing disclosure as a responsibility, not a red flag, we encourage a healthier integrity culture. And when people know they’ll be treated fairly, they’re far more likely to speak up.
Final Thoughts
COI doesn’t always look like a serious risk at first glance. It might show up as a familiar connection, a personal favor, or simply being in the wrong place at the wrong time.
But if left unacknowledged, even small overlaps can compromise trust in decision-making. That’s why conflict of interest is no longer just a side note in ethics guidance—it’s a priority.
Recent international standards, including ISO 37001:2025, reflect this shift. Organizations are being called to treat COI with the same seriousness they apply to financial fraud or procurement abuse.
If you work in compliance, ethics, investigations, or oversight, ask yourself:
Do staff in your organization know what they’re expected to disclose?
Do they understand the difference between potential and actual conflict?
And most importantly, do they feel safe raising the flag when something doesn’t feel right?
Managing COI is more than a policy—it’s a commitment to integrity in action.
Support for your COI Strategy
At STB Integrity, we support organizations in strengthening their conflict of interest systems—from drafting clear, practical COI policies to designing disclosure processes that work in real-world settings. Whether you’re starting from scratch or refining an existing approach, we can help you align with evolving standards and foster a culture of transparency.
Ready to take your COI framework to the next level? Get in touch with us to explore how we can support your team.
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Hi, I'm Sârra-Tilila!
I help international organizations and NGOs strengthen their integrity frameworks through internal policy development, tailored trainings, misconduct investigations, and dispute resolution. With over a decade of legal and investigative experience, I’ve worked extensively in Africa and collaborated with global giants like the World Bank and the World Food Programme.
My work is driven by a deep passion for tackling fraud and corruption while promoting transparency and accountability in international development. If you’re looking for expert support to achieve your organization’s integrity goals, let’s connect!
© 2022 par Sârra-Tilila Bounfour