AI Conflict of Interest Policy Generator

A conflict of interest policy establishes procedures for identifying, disclosing, and managing situations where personal interests could influence professional judgment or organizational decisions. It defines what constitutes a conflict, who must comply, how conflicts are disclosed and reviewed, and what actions are taken to manage or eliminate conflicts. The policy protects organizational integrity and ensures transparent decision-making.

At a minimum, the policy should cover board members, officers, and key employees with decision-making authority. Many organizations also include committee members, consultants, volunteers in leadership roles, and family members of covered persons. The scope should be broad enough to capture all individuals whose personal interests could materially influence organizational decisions, including procurement, hiring, and strategic direction.

For nonprofits, the IRS strongly encourages COI policies and asks about them on Form 990. Publicly traded companies must comply with SEC and stock exchange rules requiring COI procedures. Government agencies and healthcare organizations often have statutory requirements. Even when not legally mandated, a COI policy is considered a governance best practice that protects the organization from liability and reputational harm.

Common conflict types include financial interests in vendors, contractors, or competitors; outside employment or consulting arrangements; family relationships with individuals doing business with the organization; gifts, entertainment, and hospitality from business contacts; board memberships at potentially conflicting organizations; intellectual property or licensing conflicts; and real estate or investment transactions involving the organization.

Disclosed conflicts should be reviewed by a designated body (typically a committee or the board). The review process should determine whether a conflict exists, assess its severity, and decide on appropriate remedial action. Options include recusal from related decisions, divestiture of conflicting interests, modification of duties, enhanced monitoring, or in severe cases, termination of the relationship. All decisions should be documented in meeting records.