COI & Gifts · Conflicts of interest

Conflicts and gifts, declared and on the record

Send a declaration campaign to your roster, let people flag a gift the moment it happens, and keep one register showing who declared, what's under review, and who hasn't responded. Nothing here is anonymous — a conflict register only works if you know whose it is.

What this proves

No single law requires a conflict-of-interest register or a gifts log. Three things ask for one anyway: anti-corruption management under ISO 37001, the wider compliance-management standard ISO 37301, and the due-diligence questionnaire a bigger customer sends before it signs a contract. All three ask the same question — can you show who was asked to declare, what they said, and what you did about it.

A declaration only counts as evidence if it's attributable. Unlike a whistleblowing report, which this platform keeps anonymous by design, a declaration with no name behind it answers nothing an auditor asks. Every declarant here is a known person on your roster, and every gift entry is tied to the employee who reported it.

This product doesn't set your thresholds, write your code of conduct, or decide what counts as a conflict in your business. It gives your roster a direct way to declare and to disclose a gift, and keeps the record of both.

The dates are yours to set

No regulation times a conflict declaration or a gift disclosure, so nothing on this page is a statutory clock — every date here is a choice your organisation makes.

You set a due date when you open a declaration campaign. It's a request to your roster, not a countdown the product enforces or turns red over.

Reminders go to whoever hasn't declared yet, on your own instruction, so chasing a round doesn't mean building a list by hand.

A gift is never tied to a campaign. Someone can disclose one the day it happens, any time of year, through their own standing link, straight into the same register a campaign fills.

How it works

  1. Build the roster once

    Add people one at a time or import a CSV of names, work emails and departments. Importing the same file twice updates the same people rather than duplicating them.

  2. Open a declaration campaign

    Name the round, set a due date, and opening it invites everyone currently on the roster by email, each with their own one-time link. The round's own screen shows submitted against total, by department.

  3. People declare, or disclose a gift, on their own link

    The declaration form asks about seven set kinds of conflict — outside employment, an ownership interest, a family relationship, gifts or hospitality, public office, a board seat, a related-party transaction — plus a free-text catch-all. A gift is reported separately, any time, through a standing link that doesn't expire between campaigns.

  4. Only what's flagged reaches a reviewer

    A clean declaration is filed straight away. One that raises something, and a gift that crosses the line your organisation set, land in a queue a reviewer opens, decides on, and records a decision against.

  5. Chase what's outstanding, export what's done

    The campaign screen names who hasn't responded so you can chase them directly. Once a period is finished, the export produces the CSVs and the audit segment an auditor reads.

What's included

A roster, not user accounts

Add people by hand or import a CSV of name, email, department and your own staff reference. A second import of the same file updates existing people instead of creating duplicates.

Declaration campaigns

Open a round with a due date, and the current roster is invited by email with a one-time link each. Coverage is fixed at the moment you open it, so a late joiner doesn't count against this year's figures.

Seven-category declaration form

Outside employment, ownership interests, family relationships, gifts or hospitality, public office, board membership and related-party transactions, each a plain yes or no, plus a catch-all for anything else.

A gifts and hospitality register

A gift is reported through a standing link, any time, with its direction, who it involved, a description and when it happened. Your own thresholds decide whether it's simply filed or sent for approval.

Review and approval queues

A declaration that flagged something, or a gift above your threshold, lands in a queue. A reviewer records accepted, mitigated or rejected for a declaration, and approved or rejected for a gift.

Coverage and a combined register

Every campaign shows submitted against total by department, and names who hasn't responded. Declarations and gifts also sit in one filterable screen — by date, department and whether a declaration flagged a conflict — with gift totals by direction.

An auditor export

A period picker produces a bundle of CSVs for declarations, gifts and coverage, a one-page summary, and the audit-trail segment for that period, so an auditor reads the evidence without the product itself.

Built for advisors

A partner looking after several clients sees each one's current campaign and coverage from a single screen, then opens one client at a time to work on their roster or register.

Data and security

Everything runs in EU data centres: application, database, file storage, backups and email.

A roster entry's name and email are envelope-encrypted under a key unique to your organisation, as is the detail behind a flagged declaration and a gift's counterparty and description. A declaration's yes-or-no answer and a gift's value, currency and date stay as plain figures, letting a register be filtered, counted and totalled without decrypting anyone's name.

Opening one flagged declaration or one gift is its own entry in the audit trail. A page of register rows writes one entry, never one per row.

A gift decision, once recorded, is final — there is no edit and no delete on a gift's detail. A correction is a new entry referring back to the old one, so the register is never quietly rewritten.

Someone who leaves is deactivated, never deleted. Their past declarations and gift entries stay exactly as they were, because an auditor reading last year's round has to still see who took part, leavers included.

Where it applies

Applies across the EU.

Questions

Does an employee need an account to declare a conflict or report a gift?
No. A declaration arrives as a one-time link by email for a given campaign, and a gift is reported through a standing link that keeps working between campaigns. Neither needs an account or a password.
What counts as a gift that needs approval?
Whatever your organisation decides. You set two figures in your own currency: below one, nothing needs recording, though a person can still log it; above the other, it goes to a reviewer. Everything in between is simply filed.
Who can see the detail behind a flagged declaration or a gift?
A reviewer, when they open it — and opening it is recorded. Colleagues browsing the register see that something was flagged, not the detail, unless they are the one reviewing it.
What happens to someone's record when they leave the company?
They're deactivated, not deleted. Their past declarations and gift entries stay in the register exactly as submitted.
Can a conflict be declared outside the annual round?
Yes. Every employee has their own standing link for reporting a gift at any time, and a conflict that comes up between campaigns can be declared without waiting for the next round.
We act for several client organisations. Can we work from one place?
Yes. A partner sees each client's current campaign and coverage from one screen, then opens a single client at a time to work on their roster or register.