There are varying schools of thought on conflict of interest disclosure. Many organizations choose to focus on high risk employee subsets, such as executives and the sales team. But I recommend making COI disclosure a requirement across the organization. While it may seem daunting because once you have the data you have to do something about it, that's really the point. Think of a COI disclosure as the whisper before the helpline. A COI properly disclosed, vetted and with the right conditions in place, prevent an issue bubbling up later that requires an investigation.
Best practice is to require employees at all levels to submit ad hoc disclosures as conflicts arise. Then once a year, require employees to complete a questionnaire that walks them through the various types of conflicts in a question format. By deliberately asking an employee, "do you have an outside job" vs. "do you have a conflict of interest that you haven't disclosed" surfaces many more issues to light that the organization should be aware of to manage risk.
If tapping your whole organization at once seems a daunting task, consider breaking it up into separate campaigns by anniversary date or department.
Good luck and have fun de-conflicting!
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