Staying Ethical and Maintaining Conflict-of-Interest Compliance in the Season of Giving

In a recent article by Navex, the authors remind compliance professionals that holiday generosity can easily blur ethical boundaries, making conflict-of-interest (COI) compliance especially critical this time of year. 

A conflict-of-interest risk arises when personal interests—such as friendships, family ties, or gifts—interfere with an employee’s duty to act in their organization’s best interest. During a season defined by giving, even well-intentioned gestures can raise red flags if they appear to influence business decisions.

Navex outlines several best practices for navigating these challenges. Employees should evaluate not only the intent behind a gift but also how it might appear to others. The value of a gift matters, as lavish or extravagant items may imply expectations of reciprocity. 

Transparency remains central: when in doubt, employees should disclose gifts, document details, and, where possible, share them within the office to avoid personal benefit. Navex also emphasizes that soliciting gifts from vendors or clients is never acceptable, and cash or cash equivalents should be strictly avoided unless directed to a charitable cause approved by policy.

The article encourages compliance officers to revisit their organizations’ codes of conduct, verify alignment with anti-bribery laws such as the Foreign Corrupt Practices Act (FCPA), and ensure employees receive timely COI training. Gift expectations may vary across cultures, so global policies should strike a balance between consistency and local sensitivity.

For compliance teams, transparency and clear communication remain the most effective safeguards against conflicts of interest, especially when good intentions meet holiday cheer.