Every Operator would in addition to the Codes and Guidelines provided by PenCom, institutionalise the process of identifying and dealing with Conflict of Interests scenarios. A proper process should be in place for identifying and dealing with Conflict of Interest scenarios and institutionalising same. These processes and policies are reflective of the organisation’s ethics and should be tailored to work within existing structure of the organisation. The policies should provide clear direction to staff and the following questions can act as a guide in drawing up a conflict of interest policy:
- · What is a Conflict of Interest?
- · How do I identify a Conflict of Interest?
- · What do I do when I identify a Conflict of Interest situation?
The policy would also need to clearly define the roles of all staff members in handling Conflicts of Interest issues as well as the roles of line and senior management, especially the Compliance Officer. The policy should also indicate how issues of conflicts of interest involving senior or executive management and Board members should be dealt.
One of the ways to entrench the culture of identification of conflicts is to encourage a culture of disclosure within the workforce and educating the workforce. Best practices often dictate that this disclosure is done at the point of joining the organisation and thereafter on an annual basis.
In conclusion, the proper identification and management of Conflict of Interests ensures objectivity and impartiality in the internal dealings of an organisation.
by Idu Okwuosa (Stanbic IBTC Pension Managers).