Enablers Association Conflicts of Interest Policy

Version: 1.0
Effective Date: 1 January 2026
Approved by: Enablers Mission Circle
Questions? [email protected]

Purpose

This policy ensures that members of Enablers Association identify and appropriately manage conflicts of interest that could compromise professional judgment, objectivity, or the interests of clients and the Association.

A conflict of interest exists when personal, financial, or professional interests could improperly influence decisions or actions in professional engagements. Conflicts are not inherently wrong, but they must be disclosed and managed appropriately.

What Constitutes a Conflict of Interest

2.1 Competing Client Relationships

A conflict exists when:

You are coaching or providing services to executives at competing organizations simultaneously
You possess confidential information from one client that could benefit or harm another client
You are working on similar strategic issues with competing companies
Client-imposed non-compete restrictions prohibit the engagement

Examples:

Currently coaching the CEO of Company A while being asked to facilitate strategy sessions for Company B (direct competitor in same sector)
Working with two companies bidding for the same major contract
Providing organizational development services to companies competing for market share in the same industry

Not typically conflicts:

Working with companies in different industries or geographic markets
Working with companies that are not direct competitors
Providing different types of services (e.g., executive coaching vs. team facilitation) to companies in same sector
Working with companies at different points in time (completed engagement with one, new engagement with another)

2.2 Personal Relationships

A conflict exists when:

You have family, romantic, or close personal relationships with participants in the engagement
You have personal friendships that could affect your objectivity
You have social or personal connections that could create bias or appearance of favoritism
Previous professional relationships (former colleague, former boss/employee) could affect objectivity

Examples:

Asked to coach or provide feedback on someone you’re personally close to
Facilitating a leadership program that includes your spouse’s business partner
Former work colleague is participant in team intervention you’re leading
Close personal friend works in department where you’re conducting assessment

Not typically conflicts:

Casual acquaintances or professional network connections
Brief previous professional interactions (attended same conference, LinkedIn connection)
Relationships developed after engagement concludes (see Code of Conduct)

2.3 Financial Interests

A conflict exists when:

You have financial stake in organizations that could benefit from your recommendations
You receive compensation or benefits beyond agreed professional fees
You stand to personally gain from specific outcomes of the engagement
You have business relationships with vendors or partners you might recommend

Examples:

You own stock in a technology vendor and are asked to recommend technology solutions
You have ownership stake in a competing consulting firm
You receive referral fees from service providers you recommend to clients
You have financial interest in outcome of client’s strategic decisions (e.g., merger success)

Not typically conflicts:

Diversified investment portfolios with minimal holdings in many companies
Standard professional fees and expenses
Reasonable gifts and entertainment within Anti-Bribery Policy limits

2.4 Professional Reputation and Interests

A conflict may exist when:

Your public statements or published work could prejudice your objectivity
You are being asked to evaluate your own prior work
The engagement outcome could significantly enhance or damage your professional reputation in ways that affect objectivity
You have strong pre-existing views on the issue being addressed

Examples:

Asked to evaluate effectiveness of a program you previously designed for the client
Facilitating strategy session where you’ve publicly criticized one of the strategic options
Coaching someone who has publicly criticized your work or methodologies

2.5 Member-to-Member Conflicts

Potential conflicts within the Association:

Competing for the same client opportunities
Financial disputes over project fees or commissions
Personal conflicts affecting professional collaboration
One member in position to evaluate or recommend another member

Duty to Disclose

3.1 When to Disclose

You must disclose potential conflicts:

Before accepting any project assignment – even if you’re unsure whether situation constitutes a conflict

Within 48 hours of becoming aware – if conflict emerges during an engagement

Before participating in decisions – that could affect parties with whom you have conflicts

3.2 To Whom to Disclose

For client project conflicts:

Primary: Client Responsible Member (project owner)
Copy: [email protected]

For Association governance conflicts:

Primary: Chair of relevant Circle or Committee
Copy: [email protected]

3.3 What to Disclose

Your disclosure should include:

Nature of the conflict: Describe the relationship, interest, or circumstance
Parties involved: Organizations, individuals (maintaining confidentiality where required)
How it affects the engagement: Why this could compromise objectivity
Proposed management approach: Your suggestion for handling the conflict (if any)
Relevant timelines: When relationship began, expected duration

Example disclosure:

“I am currently providing executive coaching to the CFO of [Company X] under a personal contract. I have been invited to join an Enablers project with [Company Y], which competes directly with Company X in the European pharmaceutical market. Both engagements involve strategic planning discussions. I have confidential knowledge of Company X’s market strategy that could be relevant to Company Y’s planning. I recommend either: (a) declining the Company Y project, or (b) obtaining written permission from Company X to accept the engagement with appropriate confidentiality safeguards.”

Evaluation Process

4.1 Initial Assessment (Client Responsible Member)

Step 1: Client Responsible Member receives disclosure

Step 2: Makes preliminary assessment:

Clear conflict requiring escalation → Forward to Network Development Circle immediately
No apparent conflict → Approve with documentation
Uncertain → Consult with Network Development Circle

Timeline: Within 2 working days

4.2 Network Development Circle Review

Step 1: Information gathering (if needed)

Request additional information from member
Consult with relevant parties (maintaining confidentiality)
Review applicable client agreements and restrictions

Step 2: Evaluation

Network Development Circle assesses:

Severity and nature of conflict
Risk to client, participant, or Association
Whether conflict can be effectively managed
Member’s judgment in identifying and disclosing

Step 3: Recommendation

Network Development Circle determines recommended resolution (see Section 5)

Timeline: Within 5 working days of receiving disclosure (may be extended for complex situations)

4.3 Decision Authority

Network Development Circle decides: Most conflicts

Escalate to Enablers Mission Circle when:

High-value client relationships at risk
Significant reputational implications
Member disputes Network Development Circle recommendation
Legal implications require senior review
Complex multi-party conflicts

Resolution Options

5.1 Approval (No Conflict or Manageable)

Determination: No meaningful conflict exists, or conflict can be effectively managed

Conditions may include:

Written documentation of the relationship
Enhanced confidentiality measures
Limited scope of involvement in certain discussions
Regular check-ins with Client Responsible Member
Disclosure to client (with member’s agreement)

Documentation: Approval documented in writing, filed with [email protected]

5.2 Disclosure to Client

When appropriate:

Conflict is real but manageable with client’s informed consent
Transparency enhances trust rather than undermining it
Client has right to make informed decision about member’s involvement

Process:

Draft disclosure for client (reviewed by Network Development Circle)
Client Responsible Member presents to client
Obtain client’s written consent to proceed
Document in project file

Example client disclosure:

“[Member Name] has disclosed that they previously worked at [Organization] in [timeframe] and maintain professional relationships with several individuals there. While this does not affect their objectivity in this engagement, we want to ensure transparency. We have implemented additional confidentiality measures and [Member] will not be involved in [specific activities] where this background could present concerns. Please let us know if you have any questions or concerns about this arrangement.”

5.3 Recusal (Limited Scope)

When appropriate:

Conflict is narrow and affects only specific aspects of engagement
Member can meaningfully contribute to other parts of project
Other team members can handle conflicted activities

Implementation:

Clearly define which activities member will not participate in
Brief team on reasons (to extent appropriate)
Document scope limitations in writing
Monitor compliance

Examples:

Coach participates in all sessions except evaluation/feedback involving personal acquaintance
Member provides facilitation but does not participate in vendor selection discussions
Member contributes to design but not to assessment phase

5.4 Declining the Engagement

When required:

Conflict is substantial and cannot be effectively managed
Client would not consent to member’s involvement if fully informed
Risk to objectivity is too high
Client-imposed restrictions prohibit participation
Member’s existing obligations preclude new engagement

Process:

Member declines invitation to project
Client Responsible Member identifies alternative member
Brief explanation provided (without disclosing confidential details)
Document decision in member file

This is the appropriate response in many cases. Declining engagements where conflicts exist demonstrates professionalism and protects the Association’s reputation.

5.5 Terminating Existing Relationship

Rarely appropriate, but may be considered when:

New opportunity is significantly more strategic for the Association
Existing relationship is near natural conclusion
Member can ethically withdraw from existing relationship with appropriate notice
All parties agree to transition

Requirements:

Must not breach existing contractual obligations
Must not harm parties in existing relationship
Requires approval from Enablers Mission Circle
Proper transition and notice provided

Special Situations

6.1 Client-Imposed Non-Compete Restrictions

Some client agreements restrict members from working with specified competitors during and after engagements (see Member Agreement Section 14c).

When such restrictions exist:

Client Responsible Member must inform all members before project begins
Restrictions documented in Individual Project Agreement
Members acknowledge acceptance before commencing work
Violations may result in liability under Member Agreement Section 14a

Example from client agreement:

“During this engagement and for 3 months after completion, Project Personnel who have access to Client’s Confidential Information may not perform substantially similar services for [list of named competitors] in the same sector where such services would involve use or disclosure of Client’s Confidential Information.”

Members must:

Review restrictions carefully before accepting assignment
Disclose existing relationships that may conflict
Track restriction expiration dates
Decline projects that impose unacceptable restrictions on professional practice

6.2 Conflicts Between Association Members

When members compete for opportunities:

Both members may pursue the opportunity
No obligation to disclose pursuit to each other
Whichever member wins the work becomes Client Responsible Member
No hard feelings – professional competition is healthy

When conflicts arise between members:

Attempt to resolve directly and professionally first
If unresolved, raise to Network Development Circle
Circle mediates or recommends resolution
Escalate to Enablers Mission Circle if needed

6.3 Inadvertent Conflicts Discovered Mid-Engagement

If you discover a conflict during a project you’ve already started:

Pause immediately – Do not continue activities affected by conflict
Disclose immediately – To Client Responsible Member and [email protected]
Await guidance – Network Development Circle will advise on next steps
Document thoroughly – What you’ve done so far, what information you’ve accessed
Implement resolution – Follow Network Development Circle decision

No penalty for honest disclosure of inadvertent conflicts. We recognize that conflicts sometimes only become apparent mid-engagement.

Documentation and Record-Keeping

All conflict disclosures and resolutions must be documented:

Maintained by [email protected]:

Original disclosure from member
Network Development Circle assessment and recommendation
Decision and conditions
Any client disclosure and consent
Monitoring notes (for ongoing situations)

Retention: 6 years after engagement concludes or conflict resolves

Confidentiality: Conflict information kept confidential; shared only with those who need to know

Consequences of Non-Disclosure

Failure to disclose conflicts of interest is a serious violation of professional standards.

Consequences may include:

Immediate removal from project
Liability for any damages to Association or client (Member Agreement Section 14a)
Suspension from future project assignments
Written warning or probation
Termination of membership (for egregious violations)

Intentional concealment of conflicts is grounds for immediate termination.

When in Doubt, Disclose

Guiding principle: If you’re uncertain whether something constitutes a conflict, disclose it.

Better to:

Over-disclose and be cleared to proceed
Ask questions early rather than late
Err on the side of transparency

It will not be held against you to:

Raise potential conflicts that turn out not to be issues
Ask for guidance on ambiguous situations
Decline opportunities out of abundance of caution

Contact [email protected] with questions anytime.

Quick Reference: What to Do

Before accepting any project:

Review client name and scope
Consider all relationships and interests
If any potential conflict → Disclose immediately
Wait for clearance before accepting

During a project if conflict emerges:

Pause affected activities
Disclose immediately (within 48 hours)
Await guidance
Follow resolution decision

Not sure if it’s a conflict? → [email protected]

Timeline for decisions:

Simple cases: 2-5 working days
Complex cases: Up to 14 days
Urgent situations: Same-day response

Acknowledgment: I have read and understood the Conflicts of Interest Policy and agree to comply with disclosure requirements.

Member Name: _______________
Signature: _______________
Date: _______________