What this is
What is a conflict of interest declaration?
What is a conflict of interest declaration?
A record of an interest, financial, family, or an outside role, that could affect the objectivity of a business decision, with an assessment of how serious it is and what management response was applied. It exists so a decision can be checked afterward for whether the interested person's influence was actually controlled.
Who has to declare?
Anyone with decision-making influence over a supplier, contract, hire or spend where they, or someone close to them, has a stake in the outcome. The obligation attaches to the influence, not the seniority, so a buyer with authority to select a supplier carries the same duty as a director.
What counts as an interest that needs declaring?
Anything a reasonable third party would think might affect the decision, whether or not it actually would: a financial stake, a family relationship, an outside directorship, other employment, or significant gifts or hospitality. The test is perception as much as fact.
Scope
When is a conflict of interest declaration required?
This declaration is one step in a larger programme, and its most common misuse is being treated as complete once signed, when the management action it triggers is what protects the decision.
Use this template when
- A person is appointed, or takes on new authority, over suppliers, contracts, hiring or spend
- Circumstances change: a new outside directorship, a family member joins a supplier, a new commercial relationship
- A decision is imminent and the person involved has, or could be seen to have, a stake in its outcome
- The periodic declaration cycle is due and existing entries need confirming or updating
- A linked record, a supplier approval or a procurement decision, needs this declaration to exist first
Do not use it for
- Code of Conduct Acknowledgement, which records that a worker has read and accepted the code, at hire and on revision
- Whistleblowing Report Record, which records a concern raised confidentially, including an undeclared conflict someone else spotted
- Modern Slavery and Labour Standards Assessment, which assesses the site's labour supply chain rather than an individual's declared interest
- Anti-Bribery Risk Assessment, which covers gifts, hospitality and bribery risk as a standing programme, not a single declared interest
- Supplier Approval Record, which is the underlying decision this declaration exists to protect, not a substitute for it
Compliance mapping
Which ISO 37301 cl.6.2 requirements does this satisfy?
Conflict of interest management sits inside compliance management system requirements rather than a dedicated statute in most jurisdictions, so ISO 37301 frames it as a risk to be identified, controlled and reviewed, not a single act of disclosure.
| Clause | Requirement | Where it lands |
|---|---|---|
| ISO 37301 cl.6.1 | Identification and evaluation of compliance risks, including risks arising from a conflict affecting decision-making | Assessment |
| ISO 37301 cl.6.2 | Compliance objectives and planning to achieve them, including how declared interests are triaged and actioned | Header |
| ISO 37301 cl.8.2 | Establishing and maintaining controls and procedures to manage identified compliance risks | Management |
| ISO 37301 cl.5.1 | Top management leadership and commitment by ensuring conflicts of interest are identified and addressed | Outcome |
| ISO 37301 cl.5.3 | Roles and authorities assigned for approving the response to a declared conflict | Outcome |
| ISO 37301 cl.7.5 | Documented information controlled and retained, supporting a register checked independently of the individual case | Outcome |
| ISO 37301 cl.9.1 | Monitoring and evaluation of the compliance management system, including periodic review of declared interests | Outcome |
What it does not cover
- Anti-Bribery Risk Assessment, which covers gifts, hospitality and bribery exposure as a standing programme, not a single declared interest.
- Whistleblowing Report Record, which is where an undeclared conflict lands when somebody else notices it first.
- Supplier Approval Record, which is the underlying commercial decision this declaration exists to protect.
- A director's statutory duty to avoid conflicts, which sits in company law and continues regardless of any form.
- Code of Conduct Acknowledgement, which records the standard was accepted, not that an interest arising under it was managed.
Global
Conflict of Interest Declaration requirements by country
The duty to manage a conflict is close to universal, but anchored differently: statutory duty for directors in some regimes, disclosure rules for public companies in others, and a management system requirement wherever ISO 37301 applies.
State corporate law duty of loyalty; SEC Regulation S-K Item 404
No single federal conflict statute for private companies; the duty of loyalty is a fiduciary standard under state law, sharpened by disclosure rules for public ones.
Absence of a specific statute is not absence of duty, and a breach of loyalty is actionable with no declaration process in place at all.
Companies Act 2006, s.175, duty to avoid conflicts of interest
A director must avoid a situation with a direct or indirect interest that conflicts with the company's interests.
The duty applies whether or not the company could have exploited the opportunity itself, a stricter test than most forms assume.
ISO 37301, compliance management systems
Conflicts of interest are an identified compliance risk requiring defined controls, ownership and periodic review.
Certification auditors examine whether declared interests are tracked to a management decision, not merely logged.
How to complete it
How to complete a conflict of interest declaration, step by step
Most declarations are completed honestly and filed correctly. What decides whether the record protects a decision is what a form cannot force.
Recording the interest as 'financial' or 'a family relationship' says what kind it is, not whether it can sway the decision. That judgement sits in influence, benefit and perception risk being genuinely worked through, not answered 'No' by default because the category sounds minor.
Disclosure only is the cheapest response and the one most often reached for regardless of severity. Where influence or benefit was assessed as present, disclosure without removal from the decision or independent approval leaves the exposure exactly where it was, just documented.
A late declaration means past decisions were taken with an undeclared interest in the room. Reviewing historic decisions is uncomfortable and is the only way to know whether anything already approved needs revisiting, rather than assuming the interest was newly formed.
A central register that is updated and periodically reviewed lets anyone check, before the next related decision, whether a person's declared interests are still accurate. A declaration correct on the day and never revisited becomes wrong silently as circumstances change.
What auditors find
Most common conflict of interest declaration findings
The document nearly always exists once asked for. The findings concern whether it arrived in time and whether the management response matched what was assessed.
| Finding | Clause | What fixes it |
|---|---|---|
| Declaration made only after the interest was noticed by a colleague or auditor, not when it arose or on appointment. | ISO 37301 cl.6.2 | Set and communicate the trigger points, appointment and change of circumstances, so declaration precedes the decision. |
| Interest type recorded but influence, financial benefit and perception risk left unassessed or answered 'No' without reasoning. | ISO 37301 cl.6.1 | Require a stated basis for each assessment answer, and reject declarations submitted without one. |
| Management approach recorded as disclosure only for a conflict also rated with decision-making influence present. | ISO 37301 cl.8.2 | Set a minimum management approach by conflict level, so disclosure only cannot be selected where influence is present. |
| Historic decisions not reviewed where the declaration was made significantly after the interest arose. | ISO 37301 cl.5.1 | Trigger a historic decision review automatically whenever the declaration date lags the interest's actual start. |
| Central register not updated, or the declaration not carried into the next periodic review cycle. | ISO 37301 cl.7.5 | Treat register update as a closing condition of the record, not an optional step. |
| Interest relates to a supplier or contractor but procurement was not informed of the declaration or its approach. | ISO 37301 cl.9.1 | Route supplier-linked declarations to procurement automatically so approvals account for the interest. |
Case in point
Case in point: the declaration that arrived after the contract was signed
A procurement lead's brother-in-law started a consultancy that later bid for, and won, a services contract the lead had authority to award. The lead declared the relationship the week after signature, calling it a formality because, in their account, the bid had won fairly on price.
The declaration was assessed as a genuine conflict with decision-making influence and financial benefit both present, but because it arrived after the contract existed, the only management approaches left were disclosure and an after-the-fact review, neither of which could have prevented what had already happened. The fix was not a better declaration; it was requiring declaration before any decision the person had authority over, with that authority suspended until the assessment was complete.
The template
The template, field by field
The form exactly as it installs. Every field, option, score and conditional rule is editable, and the links to other templates come with it.
5 sections
- Reference
- CMP-041
- Archetype
- Record
- Record ID
- COI-2026-000
- Scoring
- Declarations current
- Direction
- High is good
- Singleton
- Yes
- Basis
- ISO 37301 cl.6.2
- Links
- Links Supplier approval, Procurement
- Tags
- Ethics, Conflict
- Sections
- 5
- Fields
- 40
- Follow up fields
- 3
- Repeating sections
- 0
- Links out
- 3
Header
13 fieldsDeclaration ID*
Auto sequence. Format COI-2026-000.
The record's own ID. Other templates point at this value.
Status*
Drives who this goes to next.
- Planned2 pts
- In progress2 pts
- Complete3 pts
- Deferred0 pts
- Open0 pts
- Closed3 pts
- Overdue0 pts
Date and Time*
Completed By*
Site*
Site ID*
Format SITE-000.
Links to FDN-001 Site ID
Declaring Person*
Declaration Trigger*
Interest Declared*
Interest Type*
Relates To A Supplier Or Contractor*
- No3 pts
- Yes0 pts
Declared Promptly*
- Yes3 pts
- Late1 pt
- Only when asked0 pts
Supplier Relationships Are Where They Surface
The undeclared interest that causes a problem is almost always a family connection to a supplier or a contractor.
Assessment
6 fieldsDecision Making Influence Assessed*
- Yes3 pts
- Partly1 pt
- No0 pts
Financial Benefit Assessed*
- Yes3 pts
- Partly1 pt
- No0 pts
Perception Risk Assessed*
- Yes3 pts
- Partly1 pt
- No0 pts
Value Or Materiality Considered*
- Yes3 pts
- Partly1 pt
- No0 pts
Family Or Close Relationship Involved*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Historic Decisions Reviewed*
- Yes3 pts
- Partly1 pt
- No0 pts
Management
6 fieldsPerson Removed From Related Decisions*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Independent Approval Required*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Interest Disclosed To Affected Parties*
- Yes3 pts
- Partly1 pt
- No0 pts
Recorded In A Central Register*
- Yes3 pts
- Partly1 pt
- No0 pts
Reviewed Periodically*
- Yes3 pts
- Partly1 pt
- No0 pts
Line Manager Informed*
- Yes3 pts
- Partly1 pt
- No0 pts
Related records
1 fieldCode Acknowledgement ID
The code the declarer has signed.
Links to CMP-039 Record ID
Outcome
14 fieldsConflict Level*
- None3 pts
- Perceived2 pts
- Potential1 pt
- Actual0 pts
Management Approach*
- No action needed3 pts
- Disclosure only2 pts
- Removed from decisions3 pts
- Role change2 pts
Acceptable To Continue*
- Yes3 pts
- With controls2 pts
- No0 pts
Register Updated*
- Yes3 pts
- No0 pts
Procurement Informed*
- Yes3 pts
- Not applicable3 pts
- No0 pts
Review Date*
Action Required*
Raise the action record, then enter its reference here.
- No2 pts
- Yes0 pts
Priority
- High0 pts
- Medium1 pt
- Low3 pts
CAPA ID
Format CAPA-2026-00000.
Links to FDN-014 CAPA ID
Action Owner
Compliance Lead*
Signature*
Site Manager*
Second Signature*
CMP-041 · record IDs look like COI-2026-000 · Links Supplier approval, Procurement
Open in KnowellaRun it with agents
From a document you fill in to a programme that runs itself
The declaration is a short form. What fails is the surrounding decision, the approval that proceeds before the assessment lands, and the register nobody rechecks before the next choice.
Holds the declaration register against appointments and circumstance changes, and flags entries never carried into the next review.
Checks a declared interest against pending supplier and procurement decisions before they proceed, and holds the write for approval.
Cross-checks supplier-linked declarations against supplier approval records, so an award decision accounts for the interest.
Links the declaration to conduct training, so a management approach requiring a role change produces a competency action.
This template lives in KnowComply — audit and governance. Audit programmes, legal register, management review, risk and certification.
Meet KnowComply→Glossary
Conflict of Interest Declaration definitions and key terms
- Conflict of interest
- A situation where a person's private interest could improperly influence, or appear to influence, a decision they are involved in making.
- Perception risk
- The likelihood a reasonable third party would suspect improper influence, assessed independently of whether influence actually occurred.
- Recusal
- Removing the interested person from the decision entirely, the strongest management response short of a role change.
- Materiality
- The scale of the financial or relational stake, used to judge how serious the conflict is, not whether one exists.
- Central register
- The maintained record of current declared interests, checked ahead of decisions rather than only when a concern is raised.
FAQ
Frequently asked questions about conflict of interest declaration
Does disclosure alone resolve a conflict?+
No. Disclosure is the point the conflict becomes visible; the management response, recusal, independent approval, a role change, is what addresses it. A declaration filed with 'disclosure only' against an assessed conflict has documented the exposure, not removed it.
What counts as an interest worth declaring?+
Anything a reasonable person would think could affect the decision, whether or not it actually would. A financial stake, a family relationship, an outside directorship or significant hospitality all qualify, because the test is perception as much as fact.
How often should declarations be reviewed?+
On a stated periodic cycle, and immediately whenever circumstances change: a new role, a new relationship, a change in who the person deals with commercially. The periodic date is a backstop; the change trigger keeps the register accurate.
What if the interest is discovered rather than declared?+
It should still be recorded and assessed, but the fact it was not declared when it arose is a separate and more serious issue that typically routes through whistleblowing or disciplinary process rather than being resolved by the late declaration.
Who decides whether it is acceptable to continue?+
The compliance lead, based on the assessed conflict level and management approach applied, not the person who declared the interest. Self-assessment of one's own conflict as acceptable defeats the purpose of an independent record.
Does a small or historic interest need declaring?+
Yes, if it could plausibly affect a decision the person is involved in. Materiality determines how the conflict is managed, not whether it needs declaring, and a pattern of undeclared small interests is itself a finding.
Keep going
Related templates and programmes
Industries this is written for
Programmes this belongs to
Ethics, Labour and Anti-Bribery
A reporting channel people trust, and labour risk assessed where it actually sits.
Supplier Onboarding and Lifecycle
No supplier trading before onboarding completes, and none left active after it ends.
Payment and Procurement Fraud Control
Payment redirection defeated by one independently obtained phone call.
Used together in Ethics, Labour and Anti-Bribery
Code of Conduct Acknowledgement
Records that a worker has read and accepted the code of conduct, at hire and on revision
Whistleblowing Report Record
Records a concern raised confidentially about wrongdoing, and how it was handled
Modern Slavery and Labour Standards Assessment
Assesses the site and its labour supply chain for forced labour, debt bondage, withheld documents and unlawful deductions
Anti-Bribery Risk Assessment
Assesses exposure to bribery and improper payments across procurement, permits, inspections and customer relationships
Agency Labour Provider Assessment
Assesses an agency for how it screens, trains, inducts and supervises the people it sends
Just Culture Determination
Separates a system problem from a genuine choice to take a risk, using a consistent set of questions
More in Ethics and Conduct
Code of Conduct Acknowledgement
Records that a worker has read and accepted the code of conduct, at hire and on revision
Whistleblowing Report Record
Records a concern raised confidentially about wrongdoing, and how it was handled
Modern Slavery and Labour Standards Assessment
Assesses the site and its labour supply chain for forced labour, debt bondage, withheld documents and unlawful deductions
Anti-Bribery Risk Assessment
Assesses exposure to bribery and improper payments across procurement, permits, inspections and customer relationships
Written and reviewed by
Siddarth Singh
Founder & Chief Executive Officer, Knowella
Certified Safety Professional and industrial and systems engineer with more than a decade inside food supply chain, freight and manufacturing operations. This page was written against the current text of the standards it cites, not against secondary summaries of them.
- Certified Safety Professional (CSP), Board of Certified Safety Professionals
- MBA, University of Chicago Booth School of Business
- MS and BS, The Ohio State University, Industrial and Systems Engineering
- Six Sigma Black Belt
Sources and last review. Reviewed 16 August 2026 against:
- ISO 37301:2021 clauses 6.1, 6.2, 8.2, 5.1, 5.3, 7.5 and 9.1
- Companies Act 2006, s.175, duty to avoid conflicts of interest (UK)
- SEC Regulation S-K, Item 404, related person transactions (US)
This page is general guidance, not legal advice. Confirm requirements with your jurisdiction’s regulator.