Decide who in the organization to charge with the task of drafting the formal conflict policy. Ideally, the entity in charge of formulating this policy and overseeing its application and continued maintenance should be the human resources committee of the board of directors, which usually includes one or two members of the board, the human resources director and the organization's CEO or the duly designated representative thereof.
2
List everyone in the organization to whom the policy applies. A simple blanket statement that the policy applies to "everyone in the organization" is inherently vague and leads to questions. Be specific from the start by listing each category of person the policy applies to, including board members, officers, management, employees, contractors and share holders if relevant. Include also other organizations that function as a single entity in its relationship to the organization in question, such as corporations as shareholders.
3
Consider what constitutes a conflict of interest and make a list of these situations, with definitions when relevant. Include preventing or eliminating situations, such as the following: any applicable member of the organization who owns or has a financial interest in a competing company where that individual might be influenced to make a business decision not in the best interest of the organization if he gains financially by favoring the competing interest; any applicable member of the organization using her position to influence a hiring or promotion decision in favor of a personal and/or family relationship, including nepotism; any organization member running for public office where the public position may be used to further the organization's political, financial and/or public relations interests; and close relationships between individuals of varying levels of authority within the organization where such relationship may be perceived as favoritism, thus leading to allegations of alienation. Always include a statement that the organization intends to follow the spirit of the policy as well as its letter to prevent any attempt exempt a conflict by strict construction of policy language.
4
Include at least two separate chains of reporting to ensure anonymity and freedom from repercussion to encourage employees to come forward with information concerning conflicts.
5
Set out a step-by-step procedure by which alleged conflicts are examined and designate who conducts this investigation.
6
Consider and then clearly state all potential resulting actions the organization may take in response to a disclosed conflict, or a situation found to constitute a conflict after formal investigation.
7
Maintain the policy actively by continuing to add to or alter it in response to the organization's needs. In this way the policy becomes a "living document" that grows and changes with every new situation encountered by the organization.
8
Apply the policy consistently, and charge the policy committee with continued oversight of the application process so employees, applicants and the public understand that the organization is vigilant in its efforts to identify conflicts of interest, and committed to preventing them in the first place.
