Executive Conflict Disclosure Routing

executive conflict disclosure routing

Route an executive conflict disclosure with complete facts, limited access, independent review, and a visible record of any required recusal.

Capture the disclosure without deciding the outcome

Record the relationship, transaction, role, financial interest, outside activity, or other fact the executive supplied. Note the relevant decision and deadline. Do not label the situation a conflict or clear it as harmless.

The authorized ethics, legal, compliance, board, or governance owner must apply the organization's rules with enough independence to review the executive's position.

Limit distribution to the review path

Use the designated disclosure form and secure channel. Avoid putting sensitive ownership, family, compensation, or relationship details in calendars, shared meeting notes, or broad task systems. The assistant may confirm that required fields are complete, but should not ask speculative questions beyond the approved intake.

If another person reports the concern, protect that record under the applicable reporting process.

Keep the affected decision from moving silently

Flag the meeting, approval, vendor action, hiring step, investment, or other decision for the responsible process owner without disclosing more than necessary. Ask the reviewer whether the executive should pause participation while review is pending. Do not let scheduling convenience create an implied clearance.

A neutral status such as review pending can preserve the process until formal direction arrives.

Record the authorized mitigation

The reviewer may require recusal, divestment, altered reporting, independent approval, disclosure to a governing body, or another response. Capture the exact instruction, effective period, decision owner, and review date. The assistant should implement only the operational pieces assigned to the office.

Legal or governance judgments remain with the qualified owner who issued them.

Make recusal work in real workflows

Remove the executive from affected approval routes, agenda items, document access, and briefing distribution as directed. Identify the alternate decision maker and inform relevant process owners using approved language. Avoid sending the executive informal updates that defeat the recusal.

Check recurring meetings and automated notifications, where old permissions can quietly restore participation after the formal record looks complete.

Review changes and close carefully

A new role, transaction, ownership change, or family relationship can alter the facts. Schedule review when instructed rather than treating a disclosure as permanent clearance. When the reviewer closes or changes the matter, update operational controls and preserve the decision record under policy.

Remove temporary restrictions only after written authorization reaches the people who manage the affected systems.

Common questions

Can the assistant determine a conflict?

No. The assistant records and routes facts to the independent owner designated by policy.

Should the executive attend while review is pending?

Ask the authorized reviewer and follow the temporary participation direction they provide.

How is recusal verified?

Check the actual meetings, approvals, files, notifications, and alternate authority named in the instruction.

Source and service boundaries

Organizations can review our executive assistant support, use the approval routing guide, or contact our team about governed executive support. Source: IRS conflict of interest policy guidance.