The Worst Conflict of Interest Move of All-Time (at least since Enron)

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In every Code of Conduct that I have seen there is a Conflict of Interest (COI) provision. Many people, including myself, have wondered why something so self-obvious as a written company Code of Conduct would be listed as the point number 1 in a best practices compliance program. The reason I believe that a written Code of Conduct should be the first is because, as stated by Jeffery Kaplan in introducing his Conflict of Interest Blog, conflicts of interest, “as a general matter, present the most common sort of C&E issues in business organizations. They can also be the most difficult to resolve, both because there is no overarching set of COI-related laws (unlike, for instance, competition law) and also because COI issues are frequently raised in an intensely personal circumstances.” If you work for a large publicly owned entity, the COI provision probably prevents ownership in another entity, other than some level of stock, without notice to and consent by your employer. The reason this notice and consent requirement exists is so that you will not be in the same position as Commissioner Stern; that is conflicted, leading you to making bad decisions.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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