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A Conflict of Interest Policy sets clear rules for how employees and board members should handle situations where their personal interests might clash with their professional duties. It's a cornerstone of good governance under Singapore's Code of Corporate Governance and helps organizations maintain transparency and trust.

The policy typically outlines specific procedures for disclosing potential conflicts, such as when staff members have financial stakes in competitor companies or close relatives working with suppliers. It also explains the steps for managing these situations - from simple disclosure to complete recusal from decision-making. Singapore-listed companies must implement these policies to comply with SGX listing requirements.

Implement a Conflict of Interest Policy when your organization grows beyond informal management or faces increased regulatory scrutiny. This policy becomes essential for Singapore companies preparing for public listing, seeking institutional investment, or expanding into regulated sectors like finance or healthcare.

Use it to protect your organization during key business moments: when hiring family members, engaging with vendor-partners, managing outside directorships, or handling sensitive procurement decisions. The policy proves particularly valuable during MAS compliance reviews, SGX listing preparations, and when establishing governance frameworks for new subsidiaries or joint ventures in Singapore's business landscape.

• Basic Corporate Policy: Outlines fundamental disclosure requirements and review processes, commonly used by private SMEs and startups in Singapore
• Enhanced Listed Company Version: Includes SGX-specific requirements, detailed reporting mechanisms, and stricter disclosure thresholds
• Financial Services Variant: Features MAS-aligned controls, specific rules for trading activities, and enhanced documentation requirements
• Non-Profit/Charity Format: Focuses on donor relationships, volunteer management, and grant allocation procedures under Singapore's charity regulations
• Family Business Adaptation: Addresses unique challenges of family-owned enterprises, including relative employment and business dealings

• Board Directors: Primary stakeholders who approve and oversee the Conflict of Interest Policy, setting the tone for organizational governance
• Company Secretaries: Draft and maintain the policy, ensure compliance with SGX and MAS requirements, manage disclosures
• Senior Executives: Must declare personal interests, follow disclosure procedures, and model compliant behavior
• HR Managers: Implement policy during hiring, handle staff declarations, conduct training sessions
• Employees: Required to understand, sign, and follow policy guidelines, report potential conflicts promptly
• Compliance Officers: Monitor adherence, investigate violations, update procedures as regulations change

• Company Structure: Map out your organization chart, identifying key decision-makers and reporting lines
• Risk Assessment: List common conflict scenarios in your industry and existing relationships needing disclosure
• Regulatory Check: Review SGX listing rules, MAS guidelines, or sector-specific requirements affecting your business
• Disclosure Process: Design clear reporting forms and approval workflows for potential conflicts
• Enforcement Plan: Outline consequences for violations and establish review committees
• Training Strategy: Develop materials to help staff understand and follow the policy effectively
• Documentation System: Set up secure storage for declarations and committee decisions

• Purpose Statement: Clear objectives and scope of the policy, aligned with Singapore's Code of Corporate Governance
• Definitions Section: Precise explanations of what constitutes a conflict, immediate family relationships, material interests
• Disclosure Requirements: Specific procedures for declaring conflicts, including timing and documentation needs
• Review Process: Steps for evaluating disclosed conflicts and decision-making protocols
• Compliance Measures: Consequences of violations and enforcement mechanisms
• Confidentiality Clause: Protection of sensitive information shared during disclosures
• Documentation Standards: Record-keeping requirements for declarations and decisions
• Policy Review Cycle: Timeframe for regular updates and amendments

A Conflict of Interest Policy differs significantly from a Compliance and Ethics Policy in several key ways. While both support organizational governance, they serve distinct purposes in Singapore's regulatory framework.

• Scope and Focus: Conflict of Interest Policies specifically address personal interests clashing with professional duties, while Compliance and Ethics Policies cover broader ethical conduct and regulatory compliance
• Implementation Timing: Conflict policies activate during specific situations like procurement or hiring decisions, whereas ethics policies guide daily operations continuously
• Reporting Requirements: Conflict policies mandate immediate disclosure of specific situations, while ethics policies often involve regular attestations and general compliance reporting
• Enforcement Mechanisms: Conflict policies typically require case-by-case review and management decisions, whereas ethics policies establish ongoing behavioral standards and disciplinary frameworks