Conflict of interest review process decision tree
Conflict of interest review process decision tree: actual or perceived, interest type, live decision, recusal or reassignment, escalation and review dates.
How it works
Open the template as a chart
Open the conflict of interest review template and use it as a new chart. Nothing is fixed: every lane, question, branch label and outcome can be renamed, moved or deleted.
Rename the lanes to your decision rights
Replace Declaring individual, Line manager, Compliance officer and Ethics committee with whoever actually holds each answer. If you have no standing committee, name the person or board that plays that part rather than deleting the lane, because the escalation route is the point of it.
Write your committee threshold into the note
Put the real test behind "Above committee threshold?" into the step's note: the value of the interest, the value of the decision it touches, and the seniority of the declarer. Decide in advance which roles always go to the committee, such as board members, executives and anyone approving above the delegated authority limit.
Define what recusal means here
Recusal is only sufficient if the person can be kept out of the whole decision, including papers, discussion, scoring and the vote. Record who checks that, and list the situations that force reassignment instead: line managing the decision maker, holding the budget, or having written the specification or job description.
Set the register entry and the review date
Decide what each register entry must hold — the interest, the classification, the management action agreed and who agreed it — and what triggers an early review rather than waiting for the date, such as a change of role, a new tender or a renewed outside appointment.
Circulate it and put it under version control
Share the chart with the people named in each lane and collect their comments, then use the approval workflow and version history so the policy diagram itself has a recorded approver and a trail of what changed and when.
Frequently asked questions
What is the difference between an actual, a potential and a perceived conflict of interest?
An actual conflict is one where the interest bears on a decision the person is taking now. A potential conflict would do so if the circumstances arose, for example a relative working for a supplier who is not currently bidding. A perceived conflict is one where a reasonable outsider could think judgement was affected, even where it was not. The distinction matters for how much management is needed, not for whether the interest is declared, and perceived conflicts are managed rather than dismissed, because the damage from one comes from how it looks after the decision rather than from how it was actually taken.
When is recusal enough, and when should the responsibility be reassigned?
Recusal works when the person can genuinely be removed from the whole decision: not receiving the papers, leaving the discussion, not scoring, not voting and not being consulted informally afterwards. It stops working when they still shape the decision through another route, and the common ones are line managing the decision maker, holding the budget, chairing the meeting, or having written the specification or the scoring criteria. In those cases the responsibility itself should move to somebody independent, and the reassignment should be recorded against the register entry rather than agreed verbally.
Who should decide, the line manager or an ethics committee?
Most declarations are settled by the line manager with the compliance officer, and reserving everything for a committee just means declarations stop being made. Send a case upward on a written threshold rather than on instinct: the value of the interest, the value of the decision it touches, and the seniority of the person declaring. Anything involving a board member or an executive, or any decision above the delegated authority limit, is normally the committee's, since the alternative is somebody assessing a conflict held by the person who appraises them.
Does every declaration need a register entry, even when there is no conflict?
Yes. The nil return is what makes the register evidence rather than a collection of the awkward cases. Recording that an interest was declared, assessed and found not to conflict shows the test was applied, and it gives a starting point when the same interest matters later because circumstances changed. It is also the only way to answer an auditor who asks how many declarations were received against how many were escalated.
How often should entries in the interests register be reviewed?
Set a date on each entry rather than relying on an annual sweep, and make the interval reflect the risk: entries attached to a live procurement or an ongoing outside appointment are usually reviewed at least annually and often at each decision point, while a closed one-off can be closed at its review date. Add event triggers as well, because most changes do not wait for the date: a change of role, a new tender or grant round, a promotion into a decision-making post, or a change in the outside interest itself should all pull the entry back through this tree.