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Open Disclosure: Why and How to Manage Conflict of Interest Disclosures
April 30, 2015
Chelsie Chmela Events Manager [email protected] 847.293.8806
We encourage you to engage during the Q&A porKon of today’s webcast by using the chat funcKon located within your viewing experience.
HOST
QUESTIONS
RECORDING The event recording and PowerPoint presentaKon will be provided post event.
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SPEAKING TODAY Philip Winterburn Chief Product Officer, Convercent
Marc Leu Global Head of Ethics and Compliance Risk Management & Planning , Philip Morris InternaKonal
Charles Pare Manager, Compliance Risk Management & Planning , Philip Morris InternaKonal
OPEN DISCLOSURE: WHY AND HOW TO MANAGE CONFLICT OF INTEREST DISCLOSURES LIVE WEBINAR | APRIL 30, 2015
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Introductions
Charles Pare Manager, Compliance Risk Management & Planning Philip Morris International
Philip Winterburn Chief Product Officer Convercent
Marc Leu Global Head of Ethics and Compliance Risk Management & Planning Philip Morris International
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Background
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What is a Conflict of Interest (COI)?
When an individual’s personal interests have the potential to interfere with their ability to act objectively in the best interests of the company.
Other Jobs Investments Personal Relationships
Direct and indirect relationships (influence and sharing)
The downside of COIs:
• Hard to detect • Tough for individuals to recognize/manage on their own • Escalate in likelihood/severity at executive levels
The opportunity with properly managed COI disclosures:
• Easier to disclose than misconduct • Provide a first and ongoing interaction with compliance • Allow gap analysis and early insight to risk • Foster employee responsibility
é risk, ê employee trust and retention
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Impact of COI
ê risk, é employee trust and retention
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Managing the Process: The Traditional Ways
Annual certification, free-form narrative
Hotline reporting channel
The drawbacks: • One and done • Unstructured • Intimidating • Cumbersome • Follow-up action and
communication impaired • Impossible to analyze • Volume and scale issues • Difficult to ensure
consistency
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Managing the Process: The New Way
Compliance
Human Resources
Management
Disclosure(s) & Update(s)
Real-Time Dashboard & Historical Reporting
Clearance/Conditions
Clearance/Conditions Disclosures/Updates
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Managing the Process: The New Way Easy to comply, easy to manage, easy to report on
Employee perspective
Admin perspective
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Ensuring Success
• Make it easy to comply • Make it easy to manage • Make it ongoing • Focus on clearance and conditions • Keep managers apprised • Provide picklists • Translate the intake • Close the communication loop • Mince words:
• Disclose, not report • Save, not submit • Clear, not accept/reject • Disclose and manage, not investigate and sanction
Give employees ownership à shape and change behavior à manage risk
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Measuring the Impact
• Richer data and insight (by region, job, nature of conflict, conditions, etc.) • Easier to act on • Better benchmarking
• Continuous dialogue between employees and compliance • Drive participation and engagement • Validate with survey results
• Easier, more informed investigation process • Less time spent on administrative tasks • Improve organizational justice, transparency and employee retention
What’s the cost and impact of not knowing about and managing COIs?
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Q&A
Thank You.
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