Next Level COI
Goal: Taking conflict of interest (COI) reporting, tracking and mitigation processes to the next level for 15,000 employees to reduce associated risks to reputation and maintain the public trust.
Conflict of Interest
Conflict of Interest 2.0
Next Level COI with Osprey Compliance Software’s COI RiskManager.
By Tricia Ryan, Project Specialist, Business Ethics & Compliance, Consolidated Edison, Inc.
Con Edison’s Corporate Ethics & Compliance leadership chose COI RiskManager™, an industry leading web-based conflict of interest solution designed by Osprey Compliance Software, to achieve their corporate compliance goals.
In addition to offering an enterprise-level solution, Osprey’s dedicated representatives provide ongoing customer support throughout the onboarding process and after go-live.
Con Edison’s in-house solution presented a number of deficiencies that the vendor solution addressed, including: simplifying the filing workflow, storing historic responses, and offering comprehensive reporting.
The vendor offered a high-quality solution that supported single sign-on, HR data feed, and a historic response retention which allows for year-over-year tracking of potential conflicts.
One of Con Edison’s keys to success has been an unwavering commitment to doing business in an ethical manner. As a Project Specialist in Business Ethics & Compliance at Con Edison, I was tasked with taking the company’s conflict of interest (COI) reporting, tracking and mitigation processes to the next level for our 15,000 employees to reduce associated risks to our reputation and maintain the public trust.
In the past few years, companies in many industries have placed an emphasis on corporate compliance, as conflicts of interest have the potential to expose an organization to significant risk if appropriate mitigation measures are not taken.
To track and resolve conflicts of interest, Con Edison had been using an in-house software solution to manage the process. While the in-house system satisfied a number of needs and maintained compliance records, it also presented some challenges due to the high number of respondents to annual surveys and the need for streamlining and increased visibility of the information disclosed.
Prior to the implementation of COI RiskManager™ Con Edison’s workflow required employees to navigate through a number of screens. The system did not allow employees to reference past responses when completing new disclosures. These complications among others prompted a need for a better process for tracking reported conflicts, and more generally, a clearly-defined workflow.
After reviewing our challenges, we needed to find a solution that was proven, easy to use, reduced risk and cut costs. We identified a long wish list of items that we wanted in a new conflict of interest system, including:
- 1Flexible disclosures with branching logic, so that users only see questions they need to answer
- 2Automatic reminders and notifications for follow-ups
- 3Easy and confidential review of disclosures at various levels within the organization
- 4Case management for a collaborative mitigation approach between employees and managers
- 5Dashboards with instant visibility into compliance levels and potential conflicts
- 6Survey response tracking and reporting to ensure full review and closure of each disclosure
- 7Ability to communicate with employees regarding questions and completion of review
- 8Global search capabilities to easily find data
- 9Ability to easily retrieve and review current and past surveys for specific employees
- 10A centralized and easily accessible repository for storing COI mitigation plans
After carefully considering a number of vendors, we decided to move forward with COI RiskManager™, an industry leading, web-based, conflict of interest solution designed by Osprey Compliance Software. Osprey offered a high-quality, enterprise-level answer, combined with strong customer support and dedicated representatives. They were flexible and coordinated with us to keep things as simple as possible for our users, implementing single sign-on and importing response data from previous years. Having historic responses stored in COI RiskManager™ allows for accurate year-over-year tracking of potential conflicts and for closure of the in-house system, while retaining all essential compliance records.
Osprey Compliance Software’s team respected our timeframe and the system went live at Con Edison in July 2016. Employees received disclosure assignments according to a pre-planned roll-out, with select groups prioritized according to our own needs.
As a next step, we continue to coordinate with Osprey’s team to maintain the new system and access key information through a number of custom, real-time reports. As before, Osprey is working with us each step of the way, and employees across the organization are able to easily access what they need to maintain compliance. With COI RiskManager™ fully implemented, I am confident that our COI process adheres to the industry-leading ethics standards for which Con Edison is known. We look forward to using the system in upcoming years and the value it adds to our compliance program, while mitigating risk and maximizing efficiency.
“We look forward to using the system in upcoming years and the value it adds to our compliance program, while mitigating risk and maximizing efficiency.”