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About this episode. In a world where public trust in institutions continues to erode, organizations face a growing credibility challenge. Employees, customers, investors, and communities are increasingly skeptical of whether decisions are being made fairly, independently, and in the interests of the organization rather than a privileged few. Against that backdrop, conflicts of interest are no longer just a compliance issue. They are a trust issue.
In this episode, Zach and Hui explore why traditional conflict-of-interest programs focus so heavily on certifications, disclosures, gifts, and other easily measurable activities while overlooking the more consequential question: who influences important decisions and why? Drawing on examples from government, corporate compliance, procurement, and organizational culture, they argue that companies need to move beyond check-the-box procedures and spend more time focused onpatterns of influence, decision-making, and trust building. Because the goal isn't to eliminate conflicts. It's to identify and manage them before they undermine credibility, culture, or good judgment.
Who? Zach Coseglia + Hui Chen, CDE Advisors
Full Transcript:
ZACH: Welcome back to The Better Way? Podcast brought to you by CDE Advisors. Culture. Data. Ethics. This is a curiosity podcast for those who ask, “There has to be a better way, right? There just has to be.” I'm Zach Coseglia and I am joined as always by the one and only Hui Chen. Hi, Hui.
HUI: Hi, Zach. Hi, everyone.
ZACH: Welcome back to The Better Way, folks. Today, we're talking about conflicts of interest, and not just what they are, but why they're so difficult to identify, regulate, and manage. This is a very timely topic, is it not, Hui?
HUI: Oh, yes, it is. There's been some focus at a very high level on these conflict-of-interest issues—at the national and international level.
ZACH: Absolutely. There's in fact been some reporting, which you've been quoted in, raising questions about a series of overlapping business and diplomatic relationships involving Jared Kushner. Those questions have surfaced in a variety of contexts, including Middle East diplomacy, investments connected to Israeli companies with defense sector exposure, and negotiations involving the potential sale of international assets owned by Russian energy company Lukoil. Across these various stories, commentators have pointed to the increasingly blurred line between private business interests, personal relationships, and public policymaking. But what's really interesting about this topic, and what we're going to talk about quite a bit today, is that the issue isn't just about whether a law has been broken. The concern really is whether business relationships, investment interests, and sometimes long-standing personal connections, can create actual or perceived conflicts when people are involved in decisions of significant public consequence. And so, Hui, I'm going to do what I love to do and do so often, which is to quote you to you, because you were recent . . .
HUI: Always scares me when you do that.
ZACH: Well, you were recently quoted in a New York Times article on this very topic. And you said, “this is an alarming and very concerning set of entanglements. And it means you have to question how the Trump administration is evaluating the different bidders involved here” (in this Lukoil deal, specifically). You continued, “are the personal interests involved going to wrongly influence the outcome.” And Hui, what's interesting about this topic is that it very much goes beyond politics. And that's really what we're going to talk about today.
HUI: Yeah, this is something that everybody deals with. It's really not just because you're doing peace negotiations or other settlements, right? But the same question exists inside every company. When someone has a relationship, loyalty, investment, or interest that may intersect with an important decision that they have to make in their role in the company, how do we determine whether those interests are influencing the outcome? Is a hiring manager favoring a friend? Is a procurement executive steering work to someone they know? Is a senior executive advocating for something, a strategy, a decision, because it's best for the company? Or because it benefits them personally in some way. Those questions apply to everyone who runs an organization.
ZACH: Absolutely. Absolutely. So, we use the sort of political conundrum as a framing device, but what we're going to talk about today is really what exactly counts as a conflict. As we tend to do, we're going to start with a definition. Then we're going to talk about why conflicts are so difficult to regulate and disclose. And then we're going to talk about the conflicts that really matter, and whether or not as a discipline, compliance is really focusing on the ones that matter most. So, Hui, let's start with definitions, as we always do. What is a conflict of interest?
HUI: When most people hear conflict of interest, they often think corruption, but that's actually too narrow. A conflict exists whenever a personal interest could impair or appear to impair decision-making in their official role. So a conflict is not a “misconduct.” This is something we really need to focus on because it's often discussed in the compliance context. And I think a lot of people get the impression that if you have a conflict, that's the end of the road. A conflict is not a misconduct. A conflict is not even necessarily a problem. It actually is just something that you need to identify and manage. Now, most conflicts arise naturally through family relationships, friendships, investments, side businesses, side employment, political affiliations, professional loyalties, board memberships, volunteer work, right? We all have lives, I hope, outside of work. And there are interests and relationships that come from the life that we have outside of work. So, it's the interest from that life outside of work and the interest of the organization that you work for: when do they create actual or potential conflict with each other.
ZACH: Yeah. Well, and what's really interesting is that we focus so much on the relationship, but the danger is actually in the influence.
HUI: Exactly.
ZACH: And even more so than that, what makes conflicts such a sort of unique beast is that the biggest risk may actually be in the perception, irrespective of whether it is a violation of policy, irrespective of whether it is in fact legally problematic. The perception of influence, the perception of favor, the perception of outside relationships or loyalties impacting company or corporate decision making is in and of itself a huge risk.
HUI: Yes, because that's important because that goes to your very credibility. Do people trust you? If they perceive that you are conflicted in your interests, in your loyalties, they don't want to trust you because how do they know that you're really acting in the organization's best interest? So, conflict really isn't about corruption. They're about competing loyalties.
ZACH: Yeah. So, what's the goal for a company that's dealing with conflicts and that's trying to build a conflicts program? It's not eliminating conflicts, because as you say, we all have lives outside of work that we want to have and that we should have, and we have competing loyalties, but it's about what, if not eliminating them.
HUI: It's about identifying and managing before the trust is damaged or, you know, that perception or that distrust arise enough to the point that people don't believe you can make a sound decision.
ZACH: I mean, the thing that I always think about with conflicts and that makes conflicts so hard to manage, kind of moving on from the definition and moving on to the question of how do we go about managing them, is that we seem to rely so much, naturally, on self-disclosure of these relationships. And I wonder, Hui, whether or not that is the best way to be managing conflicts of interest or whether we should be putting more emphasis on other things beyond just self-disclosure.
HUI: Self-disclosure is a beginning, but it really isn't enough because when you think about it, we require people to self-disclose based on a very strict set of legal definition. And that this is really some of the core challenges when it comes to conflict of interest. I will always remember one time I did this training when I was in house, and I was explaining, you know, giving examples about conflict of interest. And I said something like, the company wants to make sure that you are not awarding contracts to people who are related to you. And this woman in a room raised her hand and she said, “excuse me, I'm from Qatar. In Qatar, everyone is related to everyone. So, what do I do?” Which I just . . . it was such a great comment that I . . . you know, I never . . . obviously I never forgot it, right? Legally, you ask people to self-disclose, you want to give them a framework. And that framework is oftentimes, you know, a clearly definable kind of relationship. So, you know, we want you to disclose that if you have your spouses, your domestic partners, children, parents, you can define degree of relatedness to whatever degree you want. Sometimes, as I . . . we all know, I may have a brother that I would never. in a million years, steer business to him for whatever reason. And I may have a best friend that I have no business relationship with, no legally defined family relationship with, but it's my best friend. And I trust this friend. And I think this friend would do a good job in the things that, you know, that are handed to her. So, I'm going to steer business to my best friend. The best friend . . . and how you can't, you know, it's very hard to have a disclosure program based on that kind of definition. Like, well, you know, disclose your best friends. Well, how do you know? Is it your definition of best friend, my definition? That gets really tricky. So, I think the disclosure idea is a beginning, but if we want people to disclose, what we really need to do is to help them think about what needs to be disclosed in ways beyond those legally defined relationships.
ZACH: Yeah, let me just say, so there's two thoughts, there's two concepts there. The first is, with respect to the legally defined relationships, we have to have clarity in definition so that you don't have the question that your Qatari colleague articulated. And then there's also, well, this whole other . . . realm of relationships. Just on the first piece, the clarity of the legally defined or the policy defined relationships, I have to tell you, I've seen plenty of policies that don't do that well.
HUI: Exactly.
ZACH: That use terms like close family relationship. And it's like, okay, well, what does that mean? So, I think just like as a very baseline matter, as you said, disclosure is going to be a foundational element of a conflict-of-interest program, we’ve got to make sure we define the terms really well for the things that can be defined. Because if we don't do that well, we're really not going to be able to do the other thing, which is all of these other relationships that just simply aren't going to be definable. And give us some examples of those. You've used the close friend, the best friend, but it goes beyond that.
HUI: Yeah, you mean you have former business, you could have former business partners, you could have political allies, you could have mentors, donors who are not donating necessarily to your organization, but donors who support a charity that you really care about. You could have longtime professional acquaintances in your informal network. I mean, all these things are not legally observable or are legally definable. And attempting to define them, you can try. Like I said, like you said, actually. So, your first tier is you want to clearly define the relationships and the positions that can be defined. But then it gets to a point where you cannot, like all the things I just named, right? So then . . . yeah and then you have to really . . . this is where you need to sort of teach people to think about what is the nature of the conflict.
ZACH: Absolutely. And the Kushner example, to take it back to the kind of macro political world that we're framing this around, is a really great example of that, because the public concern may not actually be, “did person A own stock or have a seat on a board, or is there a legally definable conflict?” It really is: do the relationships that exist create incentives? Do they create loyalties? Do they create influence that could affect decision making? And that's a much harder question. And I really love the way you framed this as we were sort of talking about and prepping for this discussion. You know, we look at a conflict-of-interest disclosure form and often see things like, does your spouse work for this company? Like that's easy. We can do that. We can define spouse, we can define company, we can define work. Like, that should be really easy.
HUI: Yes.
ZACH: But what it can't realistically ask is, who would you be willing to take a phone call from at midnight and then go out of your way to help them?
HUI: And that's the real question. That second question is far more predictive of influence than, you know, does so-and-so work or own, you know, own stock or have a seat. Those absolutely matter. But that second question is the one that is hard to ask, yet far more predictive. So really, the most consequential relationships are oftentimes the least reportable. That's the irony of it.
ZACH: Yeah, you know it's funny because as we talk more about this, like it just feels like almost everything else that we talk about in the compliance world, which is, it's just so often treated as this like exclusively legal, regulatory, and enforcement exercise. It's like we define the lines based on what is legal and what is not, what is compliant and what is not. These things that can be defined, but the truth is the real risk is so much broader than that. And . . .
HUI: And so much more complex.
ZACH: . . . It really is . . . so much more complex because we're talking about human decision making, we're talking about human relationships, we're talking about things like influence, we're talking about things like friendship. I mean, these are all like very human concepts that can still expose your company to a huge amount of risk on perception alone and is not, in most cases, consistent with the way companies want to be operating. So, all right. So we've talked a little bit about what a conflict is. We've talked about why it's so difficult to regulate. Let's talk a little bit about . . . how we go about sort of chasing conflicts and whether or not we're chasing the small ones instead of the big ones. Your point at the very beginning is very well taken that conflicts is not corruption, necessarily. But what we see in the anti-corruption space is so much time and resources and money being put toward identifying, you know, T&E related violations; you know, really small potato violations of policy around how money is spent. And I think that the same is largely true in the conflict space. Like, there's so much attention to whether someone is sitting on an outside board, often at a pretty low level in the organization, and often on something like a charitable organization that's part of their local community or their church or, you know, just a hobby that exists outside of work. There's a lot of attention on relationships with suppliers and vendors, but often on things like whether or not you received like a $30 meal from them, as opposed to like really bigger, higher stakes, conflicts issues that not only create legal risk, but also that reputational and perception related risk. And I'm wondering if like that comparison to the anti-corruption space rings true for you.
HUI: Oh, so true. And it's, you know, it brings me back to a conversation that I had in my first compliance job. And I was talking to the CFO, the Chief Financial Officer of the company that I was working for; and he said, you know, I don't want to focus on gifts and entertainment. And he said, gifts and entertainment, at most, a few $100, maybe $1000, $2000. But discounts and margins, those are 10s and hundreds of thousands of dollars, and that's where the risks really are. And he was talking about this in the context of anti-corruption work, but it equally applies to the conflict-of-interest management. Rarely does the sales manager accepting a gift basket is going to materially harm the organization—but you may have a senior executive whose outside interest may influence a decision he or she makes for the company. You can have major political activities outside of the company that influences how someone shapes the decision in the company. Undisclosed personal relationships, related party transactions, insider influence and procurement. Indirect . . . oftentimes, it's indirect. You recently, in an investigation workshop, crafted this hypothetical that was a very great example of conflict of interest where you really, you had a senior manager who had his own outside company, but it was disguised. And in the internal procurement work, he really just, you know, didn't leave any fingerprints on the transactions, right? So that is how a lot of times these things are done, that when you're . . . particularly when you're senior enough, you can hand all the work, you can make it seem like it's going through the process. You can work very well behind the scenes to make sure things go the direction you want. But there is really nothing overtly obvious about those relationships and influences.
ZACH: Yeah, well, and what was great about that example, which by the way, like, it's not like we're just sitting here coming up with examples that we use in our trainings or in our education sessions. It's all based on stuff we've seen. We've seen this stuff in the wild. We've seen this stuff in the real world. And what we saw in that hypothetical is someone who not only had the personal interest but then kept arm's length from the transaction so that all the paperwork would be on the up and up and they would be sort of insulated from it. But what we also saw in that case was, which again, based on real stuff, we saw a bid that wasn't the highest bid. It's not like this party, you know, got some exponentially larger contract than the other people who participated in the legitimate—purportedly legitimate—procurement process but they knew what to bid so that they would look like they were totally on the up and up. And that's how these things materialize.
HUI: Exactly, exactly. Yeah, this is absolutely right. But you know, the thing is, for decades, anti-corruption and conflict of interest work have often centered around gifts, travel, and entertainment, because theirs are easy to define. They're easy to define. They're easier to monitor and audit. But the harder question is influence, and influence often sits at the highest level of the organization.
ZACH: 100%. And it's very much tied to the next segment that we're going to talk about, which is moving beyond disclosure and certification, because disclosure and certification are often not going to alert you to potentially problematic influence, because oftentimes the people who are exerting problematic influence
are doing everything in their power, like the hypothetical we just provided, to mask that from you. But before we get there, before we get to what you should be doing, what we need to see beyond disclosure and certification, I want to talk a little bit more about the sort of macro level political environment in which we're operating. You know, we were at a talk with some academics recently and someone said something that very much inspired this conversation and that rang very true to me and I think to a lot of people, which is, we now live in a world where a foreign government has gifted our president, I suppose our government, a 400-plus million dollar plane. We live in a world in which all of these entanglements that we referenced at the outset and that you spoke about in this New York Times article exist. We live in a world where the ambassador to Greece was recently asked to resign and did so as a result of alleged conflict of interest involving financial payments and a sort of pay-to-play scheme. There are so many other examples that we could give on, frankly, both sides, all sides of the political spectrum. And so, what worries me; and what I think is really challenging for those managing these risks within a company is that I got to think that employees who are confronted with conflicts of interest certifications and disclosure forms and trainings and policies
are at least as cynical as I am on this topic. When they see these headlines of politically connected individuals engaging in these types of questionable relationships and entanglements, how do they take it seriously when you're asking them to certify to something relating to a $30 lunch that they had with a vendor?
HUI: It really creates, I should say, you know, in the very least, a cognitive dissonance and perhaps creates anger and resentment, right? I mean, you're looking at all this that's playing out certainly in the headlines, but it may also be playing out in the organization because sometimes in organizations when these conflicts of interest happen, people do know about it, or they hear about it, or they hear rumors about it. So, they're going to say, boy, you know, like when so and so is doing that, I'm being asked to certify to this $30 lunch, or I'm being sort of reprimanded for accepting a holiday gift basket. Come on. Like, you know, get a life is basically what I would say, right?
ZACH: Yeah, yeah. 100%. Well, and it goes to this bigger topic that we talk about here a lot and that's so deeply kind of ingrained in our approach to compliance, which is that all the policies in the world, all the certifications in the world, all the reports that are telling your board that 100% of people certified or 99% of people complied with your certification requirement, all of the training, hundreds, if not thousands of hours of training that's been provided, only go so far. And the truth is, none of that stuff actually goes far enough because the thing that actually influences people's decision making and the thing that actually influences people's behavior is what they see around them, what they see their bosses doing, what they see their peers doing, what they see in their community. And, you know, these bigger cultural issues that we're talking about. I mean, those things are drivers of behavior. They shape how people feel about an organization. They shape how people make decisions within an organization far more than any of the sort of traditional rote elements of your program. And so, I say all of that because I think that on one hand, that means that we should look in a different direction for our solutions. But I also say it from a frustrated perspective because it just makes the job of all of us in the compliance and ethics space so much harder and so much more complex.
HUI: And, you know, it creates a credibility problem, right? Because if you see, you know, when you have that dissonance and you see the big problems being played out in the headlines or being played out in your organization, and yet you're being chased for these small things, really small things, compared to the big picture. That's, you know, you can have employees conclude that that's all you care about is chasing me for these, you know, insignificant things that you don't actually care about the big stuff. And that creates a credibility problem for your program.
ZACH: 100%. So let's talk about what it means to move beyond disclosure and certification. I don't think any of this is going to be like fully new to anyone. I think the most, you know, well-established and mature compliance programs are thinking about this stuff and doing a lot of this stuff. But look, we just said disclosures aren't enough, certifications aren't enough. So, what should organizations be doing? Well, one, continuous education, of course, but continuous education, just to beat the dead horse that we talk about on this podcast all the time, doesn't mean just doing more education and checking the box and then reporting on the percentage of people that completed it. It means really looking at what kind of education is necessary. And that requires us to understand a little bit more about maybe where people have gotten these things wrong, where there is confusion, where there's a lack of maturity and understanding about what is required so that we're able to train to meet people where they are. It also, though, means doing a better job of measuring the effectiveness, measuring the outcomes coming out of that education, and those outcomes being more than just whether people filled out the certification, really based on whether or not they learned something and they understand what these things mean. They understand the complexity of some of these issues. So continuing education, fully part of the solution, but there are better ways to do this. And we've talked a lot about this in various episodes. We obviously want to have escalation channels. We want to see, and this is really important and we don't see enough of this, targeted executive oversight. We talked before about how there's not enough happening where the risk is greatest, and it would be really nice to see more targeted oversight at the executive and board level. And that means not just more attention, but like a bit of a deeper dive into the potential ways in which they may be intentionally or unintentionally entangled in ways that could create risk. But the biggest area that we'd like to see more focus on is more data-driven monitoring, and that monitoring, again, should meet the complexity of this topic and shouldn't just be about the relationships, but in fact about the influence. So, to me, that means we should be asking questions like, “does one vendor win business despite weaker bids?”
HUI: Or weaker qualifications.
ZACH: Weaker qualifications, exactly. Which was the scenario in our hypothetical based on real life events.
HUI: Yes, yes.
ZACH: Questions should be like, “do contracts increase sharply after a particular executive intervenes?” You know, looking at the patterns of what happens when an executive inserts themselves unexpectedly into a contract negotiation. “Are exceptions to normal procurement processes disproportionately associated with one leader or one team or one part of the business?” “Does a company repeatedly hire the same external advisors or consultants despite there being credible alternatives?” You know, this is a common scenario that should be easier to find, but you know, you have a completely new player in this field with a wide range of known entities that maybe even have institutional knowledge about the company—and yet the unknown entity is the one that is chosen. “Are acquisitions or investments or commercial partnerships consistently favoring a narrow network of counterparties?” You know, I think a lot of people look at their third-party risk management and try to manage very large third-party networks. Well, there's similar risk in managing very narrow third-party networks. Why are these the ones that are being chosen? Is there a potential problematic influence creating that? These are just some of the questions that folks should ask and work to answer. But what it all speaks to is, one, going beyond just the certification and the disclosure. Two, really focusing on the lifecycle of the relationship. So much happens at the time a third party or a relationship is commenced. But what we also really need to do is to look at the holistic relationship to understand how risk over time may materialize. And then third, as is the case with so much of the discourse that we have around monitoring, it's looking for trends that reflect potentially peculiar decision making and patterns of behavior that ultimately, if you're not looking for them, could really just go unnoticed in a traditional monitoring and red flag system.
HUI: I completely agree, but I want to acknowledge something that I think needs to be said, which is monitoring and advising the most senior leaders in organization is a position that makes a lot of ethics and compliance professional uncomfortable.
Sometimes they don't even have access to that level of counseling and problem solving. I remember a situation where I was part of the group of people that advised a local government official, the senior most official in this particular jurisdiction, on whether there should be some kind of disclosure involving people who bring expensive wines to his dinner party. Okay, so, and I'm, you know, I have this like, okay, so what? Like you're having a dinner party, you have rich friends, of course, because you know, you didn't get to be an elected official without some significant donor base. And they bring expensive wines, which they are going to drink at the dinner. Like what is . . . you know, I mean, hours were spent, something was drafted and blah, blah, blah. Yet this very same person has been reported in the press multiple times for having links to individuals who got contracts, multi-million dollar contracts from the local government that have no background in doing the kind of work that they got the contract for. And every one of those, the commonality was that this person . . . this the company was run by a person who is a former acquaintance or associate or friend of the senior executive. You have energy spent on things that really is not the biggest deal. I don't think most voters care that much about somebody bringing an expensive bottle of wine to the, you know, to someone's house for dinner. But they should care about why contracts are being awarded on so source basis, in some cases, to people and companies who don't seem to have the qualification. And if that commonality is there, you can see what the problem is. Yet the people around this leader don't feel comfortable raising these issues. And even the people whose job it is, you know, to raise these issues, don't feel comfortable raising these issues. And that is a real challenge.
ZACH: 100%. I mean, which is why it goes back to the . . . as it often does, to the conversation around, you know, an organization's culture, because it actually shouldn't be hard to do oversight and monitoring and to ask tough questions and to dig deeper with executives, if from the very top, we've set a standard, that this is the way we do business. It's the common sort of refrain that, you know, the companies that need compliance the least are the ones that do it best.
HUI: Exactly, yes, yes, that is where we are.
ZACH: You know, it's interesting. I saw . . . you know, I'm, you know . . . I'm like almost not allowed . . . I'm really not supposed to be looking at things on LinkedIn because it does very little but frustrate me.
HUI: That's right.
ZACH: But I just saw a thought piece from some of our colleagues in the compliance community about conflicts of interest and third-party risk management. And, you know, I agreed with about 80% of this piece. It was, you know, along the same lines of what we often talk about around better metrics. And we always push back on training completion. We always push back on, you know, celebrating 100% certification in something like conflicts of interest disclosures. And this piece said, what we really should be doing is asking better questions about the 5% of people who didn't take the training or the 2% of vendors that didn't go through the diligence as they were expected to. And that's where I kind of got lost. Because while I agree that we should focus on that 5% and we should focus on the 2% or whatever it is that is the piece in the margin. It's missing to me the bigger, better question, which is, how do we know that the other 95% is “good?” How do we know that the 98% of people who certified actually did so truthfully and completely? How do we know that the vendors who went through diligence don't actually have hidden issues? And, it just, everything we talk about always comes back to this very common refrain from us, but it is making sure that what we're celebrating is worthy of celebration. And getting people to complete something, and this is sort of the like I suppose the most basic thesis of our conversation about conflicts of interest, getting people to complete something is not something worthy of celebrating. Whether it's a certification around conflicts of interest, whether it's a training, or whether it's due diligence relating to third party risk management. It's, did we identify the things that we needed to identify so that we could effectively manage the risk? Completing something is an activity metric. It is an output. Risk identification, risk management, risk reduction is an outcome. And that's what we should be focusing on.
HUI: Absolutely. And there's also, you know, this also reinforces the point that that, one, you have people, you ask people to disclose things; and when they say they do, you want to make sure they're actually doing it right. And then the next thing you want to make sure is that you're actually following up. So I, you know, I know of an organization where someone disclosed that they own a company outside of work.
They continue to funnel business to this company.
ZACH: Oh, man.
HUI: And it's just like, you know, I was kind of blown away by this whole scenario because it was like, he told you that this is his company, yet you did nothing. You continue to have relationship with this company after he has disclosed it to you. So at that point, it's not just on him, it's also on you, the company, right? So I, you know, the one . . . if you're gonna ask somebody to do something, make sure you help them do it right. Two, after they do it, you better do your part.
ZACH: 100%. Amen. Okay, we're just about at the end of our time. Let's wrap this up. If you could give compliance officers one piece of advice on the conflicts of interest topic, what would it be?
HUI: I think it will be a summary of what we discussed, which is, stop treating conflict of interest as a disclosure exercise and start treating them as an influence exercise. Most organizations already know how to collect forms, but what we need to learn to do is understand where loyalty influence, relationships, and incentives may be affecting decision making.
ZACH: Yeah. I think my piece of advice, and it's probably my piece of advice on just about everything that we talk about, but I think you just got to get a handle on your culture. You've got to understand your culture. You've got to be asking hard questions about your culture, not just because those are the things, as we've talked about, really matter and really drive decision making. But because I don't think you can understate the impact of what's happening in the broader world. I think that there is cynicism. I think that there are authenticity issues in the ways in which compliance is being talked about within organization today because of that cynicism. And it's creating a credibility problem as you articulated. And I think that if you don't understand that, and if you're not measuring that, if you're not asking these questions, this topic in particular is going to be a really hard one to manage effectively.
HUI: Amen to that.
ZACH: All right, Hui. Well, it's been a great discussion. Any closing words for our listeners?
HUI: I guess we'll just say that the best conflict of interest program don't just ask employees what relationships they have. They help organizations understand which relationships truly matter.
ZACH: Well said. Thank you so much and thanks to everybody for listening.
HUI: Thank you, everyone.
ZACH: And thank you all for tuning in to TheBetter Way? Podcast. For more information about this or anything else that’s happening with CDE Advisors, visit our website at www.CDEAdvisors.com, where you can also check out the Better Way blog. And please like and subscribe to this series on Apply or Spotify. And, finally, if you have thoughts about what we talked about today, the work we do here at CDE, or just have ideas for Better Ways we should explore, please don’t hesitate to reach out—we’d love to hear from you. Thanks again for listenin.