Conflict of Interest Policy template
Identifies, discloses, and manages situations where personal interests could compromise professional judgment.
- Duty of loyalty / fiduciary duty (common law)
- FCPA accounting provisions
- state false-claims and procurement statutes
What the policy covers
- 1. PURPOSETo ensure decisions made on behalf of your company are based on the best interests of the company, free from improper influence by personal financial or relational interests of the
- 2. WHO MUST COMPLYAll employees, officers, directors, and contractors with discretionary authority over your company business: including purchasing, hiring, vendor selection, performance evaluation,
- 3. WHAT IS A CONFLICTA conflict of interest exists when an individual's personal interests, financial, family, friendship, or otherwise, could reasonably influence, or appear to influence, decisions th
- FinancialMaterial ownership or financial interest in a vendor, customer, or competitor
- RelationalHiring, supervising, evaluating, or making compensation decisions involving a family member or close personal relationship
- InformationUsing non-public your company information for personal gain or for the benefit of others
- 4. DISCLOSUREDisclose actual, apparent, or potential conflicts as soon as you become aware of them.
- 6. OUTSIDE EMPLOYMENTOutside employment, board service, or consulting that involves a competitor, customer, or vendor of your company requires pre-approval.
- 7. PERSONAL RELATIONSHIPSRomantic relationships between an employee and someone in their direct reporting line must be disclosed; reporting lines will be adjusted to remove the conflict.
- 8. CONSEQUENCESFailure to disclose a conflict, or engaging in transactions tainted by an undisclosed conflict, may result in discipline up to and including termination, plus reversal of the affec
Who needs it
Any employer with more than a handful of staff. These are the policies a tribunal or agency looks for when something has gone wrong between people.
Questions people ask
Is a conflict of interest policy a legal requirement?
It rests on Duty of loyalty / fiduciary duty (common law) and FCPA accounting provisions and state false-claims and procurement statutes. Some policies must be written down once a business reaches a certain size or does certain work; others are simply how a tribunal, an inspector or an auditor expects to see that you have thought about it. A clear, dated, signed policy is the evidence either way. Guidance, not legal advice.
Can I change it to suit how we work?
Yes. Inside Work-Lynx it is a starting point: put your company name in, adjust the arrangements to what you actually do, set the review date and publish it. Staff read and acknowledge it on their phones, and you can see who has not.
Is it up to date?
Last reviewed April 2026. The pack is updated when the law moves, and every policy carries a review date so it does not quietly go stale.
How do I get it?
It is preloaded in Work-Lynx with the other 28 policies for the US. Work-Lynx is $3 plus $1.25 per employee, 14 days free, no card, and what you see on the pricing page is the bill.
Who is it for?
Any employer with more than a handful of staff. These are the policies a tribunal or agency looks for when something has gone wrong between people.
All 29 US policies, $3 a month
This policy and 28 others are already in Work-Lynx, alongside GPS clock-in, schedules, timesheets, PTO and an employment-question advisor. $3 base plus $1.25 per employee a month. 14 days free, no card, no sales call.
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