Earlier this month I had the privilege of moderating a webinar with our customer, Monique Ortner who is on the compliance team at LEONI along with our Chief Strategy Officer, Valerie Charles. In the session, Monique outlined the conflicts of interest process the LEONI compliance team followed to build a best-in-class system, from designing the process itself to implementing GAN’s technology to automate it.
Engagement in the live conflicts of interest (COI) webinar was incredible, with over 400 registrants and over 45 different countries represented, it was truly a global community who tuned in to learn about Monique's program. The audience asked lots of various questions across a myriad of topics. There were so many questions, in fact, that we did not get to answer them all during the session so we decided to sit down with Monique to finish the Q&A. Below you will find Monique's answers to all of the questions asked during the webinar.
Q&A on Conflicts of Interest Process
How do you narrow in on COI related to personal relationships with persons who work at Customers or Competitors?
Monique Ortner: We use a risk-based approach and these categories are definitely considered high risk and all business partners, competitors, and suppliers of LEONI are included. Although there is no direct relationship with competitors, there is potential interest. Due to the potential interest, we include competitors. For persons who do not work at customers or competitors - there cannot be a conflict if LEONI does not have a business relationship
Who is informed if a conflict of interest is reported?
MO: Managers, HR (only for outside employment), and Compliance (as a consultant for decision making).
What are good sources for putting together the questions in a disclosure?
MO: A few of my go-to sources include:
- Existing conflicts of interests
- Internal investigations
- Known external fraud patterns
- Factors that could influence the final decision/mitigation measures
Do you provide training simultaneously? Or annually?
MO: Both – depends on the target group and risk potential of LEONI. Outside of formal training, we work to spread awareness of the policy.
How long has the COI process been in place at LEONI?
MO: The LEONI conflicts of interest process has been recently redesigned and structured into an online-based process.
For implementation, did you have executive sponsorship or other internal factors (besides the process) that led to success?
MO: Yes, two main internal factors stand out:
- The tone from the top (executive sponsorship)
- Board of Directors
- At the start, BoD sponsored topic
- In the end, BoD gave final policy approval
- COI is included in our new Code of Conduct
Why was this successful for LEONI?
MO: The process is risk-based and we have an efficient process to report, approve, and document.
Are all your 94K employees within the scope of the COI declarations?
MO: No – this is a risk-based approach with a focus on white-collar employees with contact with business partners who are potential decision-makers and could influence business decisions.
Do you require your employees to make mandatory no conflict declarations?
MO: No, it is optional. We encourage reporting but it is not mandatory. The compliance tool and conflicts of interest process only allow in-scope requests to move into the approval review.
How did LEONI introduce the conflicts of interest process to its employees?
MO: We distributed the guidelines to all in-scope employees which were supported by e-learning & personal training. We also communicated the new policy on the company intranet and made a presentation to various management boards.
Do you allow employees to accept free conference registrations from vendors? If so, are there limitations?
MO: This is not part of our COI guidelines but is subject to our anti-corruption/anti-bribery guidelines. It is allowed but with specific restrictions – including in advance approval requirements and documentation.
If the process starts with HR as the first entry filter, what do you suggest if HR is the center of COI? (Meaning the entry of staff is undermined by COI).
MO: For our conflicts of interest process, the approval workflow starts with the employee’s manager and HR is not the decider but provides a recommendation. The manager is the ultimate decision-maker and this structure guarantees that at least two independent parties are involved in the review/approval process.
How to Create a Best-In-Class Conflicts of Interest Process
If you are intrigued by these answers and have not yet watched the full 45-minute webinar (or would like to go back and watch it for a second time), I would highly encourage you to do so. Monique and Valerie shared some great insights throughout the webinar as well. Finally, I would like to give a big thanks to Monique for her expertise and time. It is through knowledge sharing like this that the whole compliance industry benefits.
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