Conflicts of Interest: The Evolving Risk Integrity Professionals Can’t Ignore

Conflicts of interest (COI) have long been seen as ethical grey areas —sometimes downplayed as harmless overlaps or managed informally behind closed doors. But recent shifts in the global integrity landscape are pushing organizations to rethink that. 

In fact, the 2025 update to ISO 37001, the international standard for anti-bribery management systems, places greater emphasis than ever before on conflict of interest —its definition, identification, disclosure, and documentation.

While the 2016 version only provided a brief definition, the revised standard reflects a growing recognition: conflict of interest, if unmanaged, is a foundational risk. It can distort decision-making, facilitate misconduct, and weaken anti-bribery controls, even when no bribe is ever offered.

Before we can manage conflicts effectively, we need to be able to speak about them clearly. That starts with distinguishing between three commonly misunderstood forms:

Actual conflict: The interest has already compromised impartiality. The decision-maker cannot act independently due to a known connection.
Example: A procurement officer awards a contract to a company owned by their sibling.