Conflicts of interest (COI) at work aren’t just an executive-level concern. They happen across all levels of an organization, often in ways that are subtle and easily overlooked. As seasoned compliance professionals, we know that even the perception of a conflict can be as damaging as an actual violation. The challenge isn’t just recognizing COIs—it’s ensuring employees understand their ethical and legal responsibilities before issues escalate.
But here’s the real question: Is our training on COIs actually preparing employees to make informed, ethical decisions—or just covering the basics? Many COI programs focus too heavily on check-the-box policy reviews without addressing the complexities that make conflicts so tricky in the first place. If we want to mitigate risk meaningfully, we need to evolve our approach to COI training.
The limitations of traditional COI training
Most organizations already have policies in place and require some form of annual COI training. Yet, COIs continue to be a recurring issue. Why? Because traditional training often falls short in these key ways:
- It’s too theoretical. Employees are given broad definitions and examples but aren’t taught how to recognize potential, real-world gray areas.
- It’s static and generic. Many COI training programs don’t differentiate by role, industry, or specific risk exposure.
- It negatively positions COIs. Employees are often conditioned to view COIs as inherently bad, leading them to fear disclosure rather than view it as a routine part of business ethics. When employees assume the company will prohibit or penalize all COI-related activities, they may avoid raising potential concerns—ultimately increasing risk for both themselves and the organization.
- It assumes employees will self-report. Without a strong culture of ethical decision-making and disclosure, training alone won’t lead to meaningful behavior change.
The result? Employees may pass a compliance test but remain unequipped to recognize, assess, and manage conflicts in their daily work.
Elevating COI training for a more sophisticated audience
Most compliance professionals don’t need another rundown of why COIs matter—we need better strategies for ensuring training resonates with employees and drives behavioral change.
Conflicts of interest at work arise for many reasons, and not all of them are negative. They can stem from career success, industry leadership, or professional networking. Employees who are thriving in their fields—serving on boards, engaging in thought leadership, or taking on high-profile roles—may inadvertently create COIs without realizing it. That means:
- Moving Beyond Conflict of Interest Policy Awareness – Employees need real-world, interactive training that challenges them to apply policies in nuanced scenarios.
- Shifting from Static to Adaptive Training – Training that adapts to an employee’s role, risk level, and proficiency ensures more relevant learning experiences.
- Using Data to Identify Blind Spots – Compliance teams should analyze training data to spot trends in misunderstandings and adjust programs accordingly.
- Encouraging a Culture of Disclosure – The goal isn’t just preventing COIs—it’s fostering an environment where employees feel comfortable disclosing potential conflicts before they become problems.
How to rethink conflict of interest training
If we want to move past compliance as a checkbox exercise, we need to integrate conflict of interest training into broader compliance strategies that emphasize ethical decision-making. Here are some ideas for taking COI training to the next level:
- Scenario-Based Learning: Instead of just defining conflicts, put employees in realistic dilemmas where they must assess and respond to a potential COI.
- Role-Specific Training: Tailor training to different functions—finance, procurement, HR, and leadership all face distinct COI risks that require different approaches.
- Microlearning & Reinforcement: COI isn’t a once-a-year issue. Short, scenario-driven refreshers throughout the year can reinforce key principles when they matter most.
- Built-in Disclosure Opportunities: Integrate COI disclosure directly into training modules, providing employees with a seamless way to report potential conflicts as they learn. This ensures that employees not only understand COI risks but also practice disclosure in real time.
- Ethical Culture Building: Training alone won’t fix COI issues. Organizations need leadership buy-in, strong reporting mechanisms, and cultural reinforcement to make disclosure the norm.
Final thoughts
COI training isn’t just about making sure employees know the rules—it’s about ensuring they have the tools and confidence to navigate conflicts in real time. If your current approach to COI training is overly policy-driven, it may be time to rethink how your program builds ethical decision-making skills.
So, ask yourself: Is your COI training helping employees make better choices, or is it just another policy reminder? If it’s the latter, a shift in strategy may be long overdue.
This post was updated on 20 March 2025 to reflect new insights and industry updates.
Deborah Mercier, Senior Compliance Counsel, is a licensed attorney with over 13 years of experience in the compliance field, spanning a diverse range of sectors.
She is deeply committed to developing engaging and effective ethics and compliance training programs and helping organizations align their business objectives with legal and regulatory requirements.