Episode Transcript
[00:00:00] Speaker A: Hi, everyone. You've got questions and we've got answers. Welcome to another Bella Asks episode of the Ethicast.
The Business Ethics Leadership alliance, or bella, is a global ethics and compliance community that provides exclusive access to helpful data, benchmarking events and other resources to advance your ethics and compliance program.
One of those resources is bela's Concierge Service, in which members can submit any question regarding ethics and compliance and our internal experts will provide an answer, plus helpful resources with more information.
Now, while we invite everyone watching and listening to join bella, we know that there's no competition in compliance, so we're using this program to thematically respond to high level questions from the Bela community for the benefit of E and C teams everywhere.
Joining us as always, is Bella chair Erica Salmon Byrne. Erica, we're so glad to have you on the show.
[00:01:01] Speaker B: Oh, Bill, thank you so much for having me back. It means that our BELLA members still have questions.
[00:01:06] Speaker A: They do. And our next question is a conflicts of interest question which reads, how do companies collect COI disclosures on an annual basis as well as during job changes?
[00:01:17] Speaker B: Yeah, and I'm really glad, Bill, that this particular Bella member highlighted the during job changes piece, because I think probably the biggest thing that we are seeing the Bella community do right now around conflicts of interest is think about those particular points in time where a conflict situation might have changed. So let's say, hypothetically speaking, I am, I'm getting promoted at work and I'm now in a position where I'm managing people. Well, previously speaking, I may not have been that concerned about talking about the fact that my cousin works in a different part of the business. But, but now that I'm managing people, I probably do need to think about the fact that my cousin works in a different part of the business and I need to think about what those relationships might look like. So it's really important for companies to think about the way in which they talk to employees during job changes, about the things that might have changed from the, from a conflicts of interest perspective. So very often when somebody's going through that process, they're transferring units, they're transferring jobs, they're taking on new responsibilities.
There's a whole script that goes into that that HR is often in charge of, right? Your people team, your whatever the word is for the people who manage people, Right?
So think through working with your HR team to say, okay, here's the. The job transfer piece of a conflicts of interest disclosure that I need to think about. Is there a system you can use to send a Prompt to that employee to say, hey, congratulations on your new role. We need you to redisclose any conflicts. Here's what you disclosed before.
Let's talk about what updates might look like. So that's, that's absolutely something that we're seeing companies spend a lot of time thinking about is, you know, kind of what are those systems that can be used similarly annualized basis conflicts disclosures have been standard for a very long time. Asking people to say on an annual basis, I certify that I'm going to comply with a code of conduct and I don't have any undisclosed conflicts of interest.
Thinking again about that systems based piece. So let's say you've got a team that is going to work on an acquisition transaction as part of getting access to the data room. Can you require them to also certify that they don't have any new conflicts?
So what are those kind of technological touch points that you can use to make conflicts disclosures as seamless as possible?
[00:03:31] Speaker A: As someone who is very fond of filing conflicts of interest disclosures myself, because I do things outside of at the sphere, the easier your organization makes it to disclose, the more you want to disclose. It's such a virtuous cycle.
[00:03:43] Speaker B: It absolutely is, Bill. And I'm really, I'm really glad you offered that personal antidote because I do think it's a really important piece of the puzzle, which is ask your Is there something in your process that is making it harder for employees than it should be to tell you about some conflicts? The easier you make it, the more seamless the process.
Is there a chatbot element you can use? Right. There's all kinds of ways that you can think about making your conflicts disclosures process as easy for your employee base as possible. The easier you make it, the more likely they are to use it and you're going to be able to get out in front of issues as quickly as possible.
[00:04:19] Speaker A: I couldn't agree more. Well, Erica, thank you so much for weighing in on this question from the Bella community. It really helps ENC teams everywhere.
[00:04:26] Speaker B: Oh, absolutely, Bill. My pleasure. And to all those Bella members out there listening, please keep the questions coming, okay? Because that gives me a chance to come back.
[00:04:34] Speaker A: To learn more about Bella, visit ethisphere.com bella to request guest access to the member resource hub and to speak with the Bella Engagement director. If you have a question that you would like answered on this program, contact the Bella Concierge service and we'll get to work on it for you. Thanks for joining us. We hope you've enjoyed the show. If you haven't already, please like and subscribe on YouTube, Apple Podcasts and Spotify. And be sure to tell a colleague about us. It really helps the program.
That's all for now, but until next time, remember, strong ethics is good business.
