This document discusses conflicts of interest and provides guidance on how to handle them. It defines a conflict of interest as a situation where a person's interests could compromise their judgment or actions. It gives examples of common conflicts like self-dealing, accepting gifts, and using confidential information for personal gain. The document outlines seven keys to properly managing conflicts, which include knowing requirements, training employees, documenting compliance procedures, implementing regulations, understanding consequences, requesting exceptions when needed, and getting help from the appropriate authorities. The overall message is that conflicts must be identified, disclosed, and either eliminated, mitigated, or waived to ensure integrity and avoid problems.

1. CONFLICT OF INTEREST
PRESENTING BY
CHIRANJIVI BANJADE
MANISH NEUPANE

2. Conflict of interest
A conflict of interest (COI) is a situation in which
a person or organization is involved in
multiple interests, financial or otherwise, and serving
one interest could involve working against another.
Typically, this relates to situations in which the personal
interest of an individual or organization might adversely
affect a duty owed to make decisions for the benefit of
a third party.

3. BREAKING DOWN 'Conflict of Interest'
A conflict of interest in business normally refers to a
situation in which an individual's personal interests
conflict with the professional interests owed to his
employer or the company in which he is invested. A
conflict of interest arises when a person chooses
personal gain over the duties to an organization in
which he is a stakeholder. For example, all board
members have fiduciary duties and a duty of loyalty to
the corporations they oversee. If one of the board
members chooses to take an action that benefits him
at the detriment of the firm, he is harming the
company with a conflict of interest.

4. Leading examples
[1] Self-dealing. For example, you work for government and use your
official position to secure a contract for a private consulting
company you own. Another instance is using your government
position to get a summer job for your daughter.
[2] Accepting benefits. Bribery is one example; substantial gifts are
another. For example, you are the purchasing agent for your
department and you accept a case of liquor from a major supplier.
[3] Influence peddling. Here, the professional solicits benefits in
exchange for using her influence to unfairly advance the interests
of a particular party.
[4] Using your employer’s property for private advantage. This could
be as blatant as stealing office supplies for home use. Or it might
be a bit more subtle, say, using software which is licensed to your
employer for private consulting work of your own. In the first case,
the employer’s permission eliminates the conflict; while in the
second, it doesn’t.

5. [5] Using confidential information. While working for a private
client, you learn that the client is planning to buy land in your
region. You quickly rush out and buy the land in your wife’s
name.
[6] Outside employment or moonlighting. An example would be
setting up a business on the side that is in direct competition
with your employer. Another case would be taking on so many
outside clients that you don’t have the time and energy to
devote to your regular employer. In combination with [3]
influence peddling, it might be that a professional employed in
the public service sells private consulting services to an
individual with the assurance that they will secure benefits
from government: “If you use my company, I am sure that you
will pass the environmental review.”
[7] Post-employment. Here a dicey situation can be one in which
a person who resigns from public or private employment and
goes into business in the same area. For example, a former
public servant sets up a practice lobbying the former
department in which she was employed.

6. 7 Keys to Handling Conflicts of Interest
• Conflicts of interest arise when officials or staff stand to benefit--
either directly themselves or indirectly through business partners
or relatives--from the awarding or contracting of grant funds.
Grantees are encouraged to avoid conflicts of interest to the
extent possible. When conflicts of interest arise, grantees must
identify, disclose, and manage them in compliance with applicable
rules and regulations. When conflict-of-interest issues are
overlooked or hidden, this creates problems for the individuals
involved, as well as grantees, sub recipients, or contractors. This
bulletin discusses common types of conflicts of interest, offers
best practices for avoiding and managing them, and the potential
consequences of not handling them appropriately.

7. 1. Know the Requirements
The existence of a conflict of interest does
not necessarily mean that any individual
acted improperly or illegally, but it does
mean that, unless properly handled and
addressed, he or she could end up being in
violation of Federal rules. Therefore, all
such cases must be identified and resolved
by eliminating the conflict or obtaining a
written exception.

8. 2. Train Employees
• Grantees and sub recipients ought to build an
organizational culture that is conscious of potential
conflicts of interest so that action can be taken to avoid
or mitigate conflicts as they arise. Provide conflict-of-
interest training for all employees, including those of the
organization and the governing authority, the
organization’s leadership and, as appropriate, the
organization’s agents. To have the most impact, the
organization should have a written policy requiring
annual conflict-of-interest training, and legal counsel or
other qualified individuals should review the policy with
employees (and board members), sub recipient officers,
and pass-through entity staff at least annually.
Documenting training is a best practice.

9. 3. Create Procedures to Document
Compliance
• Conflict-of-interest policies and procedures
should describe how conflicts will be handled.
When a conflict or potential conflict of
interest exists, the person with the conflict
should advise the board or management
committee in writing and seek guidance on
how to resolve the conflict.

10. 4. Implement the Regulations
• Often people are unaware that their
activities are in conflict with the best
interests of the organization. A goal
should be to raise awareness, encourage
disclosure and discussion of issues that
may constitute a conflict, and constantly
encourage a “culture of candor.”

11. 5. Know the Consequences
• Violating conflict-of-interest rules can have
serious consequences for a grant program.
Bad publicity surrounding undisclosed
conflicts may seriously undermine the public
trust in the program as well as damage
personal reputations. Audits and
investigations can result in the grantee’s
having to repay Federal funds, or individuals
being fired or prosecuted.

12. 6. Request an Exception
• HUD may grant an exception to non-
procurement conflicts of interest on a
case‐by‐case basis. It is the recipient’s
responsibility to submit a written request
for an exception to its local HUD CPD
office.

13. 7. Get Help
• Conflict-of-interest requirements are
often nuanced and must be reviewed
case by case. HUD provides assistance
when conflict-of-interest situations arise
or are in question. You can get help from
your local CPD office when such issues
arise.

14. Identify, disclose, and manage all real
and apparent conflicts of interest
through elimination, The primary goal in
managing conflicts of interest is to
ensure that as decisions are made, they
are seen to be made on proper grounds,
for legitimate reasons, and without bias
or unfairness. mitigation, or waivers.
Conflicts of interest are situations not
allegations… BUT they must be disclosed
and managed properly.

15. THANKS