Conflicts of Interest Assessment & Model
Answer 11 quick questions and you’ll get a personalized maturity score along with practical next steps for strengthening your program.
Maturity Assessment
How Mature is Your Conflicts of Interest Program?
Take the self-assessment to learn where your program sits and steps you can take to improve.
How are conflicts of interest addressed within your policy framework?
Which categories of conflict does your program formally treat as in scope?
Who is subject to the COI disclosure obligation?
Which resources does your company offer to help a person determine whether a conflict exists?
How would you describe your COI certification process?
How do employees submit a COI disclosure?
How are submitted disclosures triaged and routed for review?
Who reviews a disclosure, and how is that review conducted?
Once a real conflict is identified, how is it managed to resolution?
How does the compliance function report on the COI process?
How does the organization gain assurance that the COI program is working?
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Phase 1: Ad-Hoc
Phase 1: Ad Hoc
Your program has little or no formal structure. COI are managed only when they surface — usually when it's too late. The risk of undisclosed conflicts harming the organization, and of failing regulatory scrutiny, is significant. The immediate priority is establishing baseline policy, a disclosure obligation, and a record-keeping mechanism.
Phase 2: Reactive
Phase 2: Reactive
You have a policy foundation, but the program relies heavily on individuals taking the right action without strong process support. Disclosure rates are likely low, review is inconsistent, and you're managing by exception rather than by design. Formalizing your certification cycle and building a structured disclosure channel will unlock the next level.
Phase 3: Structured
Phase 3: Structured
Your program is operational: defined scope, consistent certification, a structured disclosure process, and documented remediation. This is where most large organizations sit — and it's where regulators set their minimum bar. Moving to Proactive requires shifting from compliance activity to risk intelligence: scoring disclosures, segmenting data, and using the program to surface risk before it becomes an issue.
Phase 4: Proactive
Phase 4: Proactive
Your program goes beyond compliance activity to generate actionable risk intelligence. Disclosures are risk-scored, review is multi-function, mitigation is tracked to closure, and reporting is segmented and trend-based. The gap to Optimized is continuous monitoring: moving from periodic to always-on detection of undisclosed conflicts, and integrating COI data into broader enterprise risk frameworks.
Phase 5: Optimized
Phase 5: Optimized
Your COI program operates at the highest level of maturity: comprehensive taxonomy, universal scope, AI-assisted triage, continuous monitoring for undisclosed conflicts, and real-time board-level reporting. This is a strategic risk management asset, not just a compliance function. The focus now is continuous improvement, benchmarking, and ensuring the program evolves as the business and its risk profile change.
GAN INTEGRITY COI MATURITY MODEL
Five Phases. A Clear Path Forward
Manual processes with little visibility.
Siloed workflows with limited insight.
Standardized workflows and centralized data.
Integrated systems with real-time insights.
Predictive intelligence aligned across the enterprise.