Compliance guide
Conflict of Interest Policy Template
A conflict of interest (COI) policy sets out how your people identify, declare and manage situations where personal interests could clash with their duties. This guide gives you a free policy template, a declaration of interest form sample, and a done-for-you option.
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Key takeaways
- A conflict of interest policy explains what a conflict is, requires people to declare conflicts, and sets out how they're managed.
- Conflicts come in a few forms: actual, perceived and potential, your policy should cover all three.
- It's paired with a declaration of interest form, the document employees and directors use to disclose interests.
- It works alongside your code of conduct and anti-bribery policy as a core governance document, and is commonly requested in procurement reviews.
- Write your own from the template below, or have a tailored, ready-to-issue version done for you.
What is a conflict of interest policy?
A conflict of interest policy is an internal document that helps your people recognise when a personal interest, financial, family, or otherwise, could improperly influence their work, and sets out how to declare and manage it. The goal is to protect decisions from bias and keep trust in the business.
It usually comes with a declaration (or disclosure) of interest form, the practical document people fill in to record an interest so it can be managed.
Types of conflict of interest (with examples)
A good policy names the different kinds of conflict so people can spot them:
- Actual conflict, a current clash, e.g. an employee approves a contract for a company they own.
- Perceived (apparent) conflict, it looks like a conflict to a reasonable outsider, even if no improper influence occurs.
- Potential conflict, a situation that could become an actual conflict, e.g. a manager's relative applies for a role on their team.
Common workplace examples include hiring or supervising a family member, accepting gifts from suppliers, holding a financial interest in a competitor or vendor, and side work that competes with the business.
What to include: conflict of interest policy template structure
Adapt this outline to your business:
- Purpose and scope, why the policy exists and who it applies to (employees, contractors, directors).
- What is a conflict of interest, a plain-English definition covering actual, perceived and potential conflicts.
- Examples, typical situations so people can recognise a conflict.
- Duty to declare, the requirement to disclose interests as soon as they arise.
- How to declare, the declaration of interest form and who to give it to.
- Managing conflicts, options such as recusal from decisions, oversight, or divestment.
- Gifts and hospitality, how these tie into conflicts (cross-reference your anti-bribery policy).
- Records, how declarations and decisions are documented (a register of interests).
- Responsibilities, what the business, managers and individuals must do.
- Breaches, the consequences of failing to declare or manage a conflict.
- Review and approval, who owns the policy, how often it's reviewed, and sign-off.
Download the editable conflict of interest policy template
Pop your email in and we'll send the conflict of interest policy template together with a ready-to-use declaration of interest form (Word and PDF).
Declaration of interest form
The declaration (or disclosure) of interest form is what people use to record an interest. A simple form captures:
- The person's name and role.
- A description of the interest (financial, family/personal, outside employment, etc.).
- The nature of the potential conflict and which decisions it affects.
- How it will be managed (e.g. recusal, oversight).
- Signature and date, with a section for management sign-off.
How to implement your conflict of interest policy
A policy works only when declaring conflicts is routine, not awkward.
- 1
Adapt it to your business
Tailor the examples and management options to how your organisation actually works.
- 2
Set up a register
Create a simple register of interests and decide who maintains it.
- 3
Approve and communicate
Have it approved by management, share it with staff, and include it in induction.
- 4
Collect declarations
Ask people to complete a declaration of interest form on joining and at least annually.
- 5
Manage conflicts consistently
Apply recusal, oversight or other measures the same way every time, and record the decision.
- 6
Review regularly
Review the policy and register at least annually.
Free template vs done-for-you document
Both routes get you a working policy plus a declaration form. The difference is who does the work, and how tailored the result is.
| Free template | Done-for-you document | |
|---|---|---|
| Price | £0 | Fixed fee |
| Effort from you | A few hours editing | A short intake form |
| Fitted to your business | You write it in | Done for you |
| Declaration form | Basic sample | Tailored to your roles |
| Register of interests | You set it up | Set up for you |
| If it needs changes | You redo it | We revise it free |
Prefer your COI policy done for you?
Tell us how your organisation works and we'll prepare a tailored conflict of interest policy and matching declaration form, ready to issue.
Requests for the conflict of interest policy are reviewed and prepared manually, we'll follow up by email.