Conflict of Interest Register

A director's sibling owns a company bidding for a supply contract, so the director discloses the relationship before the procurement decision, and the business records it, assesses the risk and decides who may see documents, discuss bids and vote. The purpose is not to label everyone with an outside interest as dishonest but to make possible bias visible before a decision becomes hard to undo.

Define the population, because directors, managers, procurement staff and others with decision power may need to disclose relevant interests, and requirements depend on the entity and country. Invite early declarations, since an interest reported after a contract is awarded gives fewer choices for managing the process.

Record the relationship by describing the organisation, person, financial holding or outside role involved, with enough detail for a reviewer to understand the overlap, and distinguish kinds of interest, because financial stakes, paid work, family ties, gifts and close relationships may matter in different decisions under the relevant policy. Assess relevance, as a harmless investment may not affect a particular decision while a direct stake in a bidder may require stricter handling.

Recognise perceived conflicts, because a reasonable outsider may question impartiality even if the person believes they can decide fairly. Name the affected work, since a register entry should identify the type of decision or project involved rather than leaving the risk vague.

Choose a management action, which can include disclosure at a meeting, independent review, restricted access or stepping away from the decision, subject to the applicable rules. Do not assume one action fits all, because recusal may be necessary in some cases while in others a narrower control may be enough, so seek advice on legal duties.

Assign a reviewer, and where feasible someone other than the person with the interest should assess how it will be managed. Keep the decision trail by recording who assessed the interest, the conclusion, any conditions and when they were applied.

Refresh entries, because a minor outside role can become important when a new supplier contract appears, and a general annual declaration does not remove the need to check each meeting for agenda-specific conflicts. Protect personal information, since the register can hold sensitive family and financial details, so limit access and publish only what relevant rules require, and avoid blanket publication because transparency rules for public bodies differ from private firms and the audience and legal basis should be explicit.

Coordinate with minutes, so that if a director leaves a discussion or does not vote the meeting record agrees with the register and governing procedure, and check quorum effects, because removing a conflicted voter may affect whether the remaining body can decide under its actual decision rules. Watch related-party deals, as a conflict register helps identify them but accounting disclosure and approval may involve separate requirements.

Provide a route for uncertainty so staff can ask whether a relationship needs declaring without fear of punishment, review open cases because a recorded mitigation is only useful if someone checks that it happened (a register is not a substitute for supervision), and consider changes in role, since a person promoted into procurement may now influence suppliers they previously had no authority over. UK Cabinet Office guidance for non-executive board members illustrates interest descriptions, relevance assessments, conflict categories and management measures, and the UK Pensions Regulator also describes managing board conflicts, but these are named UK frameworks, not a universal template; for an owner, the register makes a sensitive decision defensible by showing the interest and the response, and it should change the process where needed, not merely fill an administrative box.