Article Content

Overview

User Account Requirements

Related Information/Setup

Navigation

Alternate Navigation

Reviewing a Conflict of Interest Disclosure 

Overview

A Compliance Officer must review all Conflict of Interest disclosures within the system. Conflict of interest disclosures can have more information requested or accepted depending on the information within the request.

User Account Requirements

The user account used to log into Kroll's Managed Compliance Software must have Compliance Officer permission to review conflict of interest disclosures.

Related Information/Setup

Please refer to the Viewing a Request's Change Log History article for more information on viewing a request's change log.

Navigation

1. From the Home screen, click the Sort dropdown menu in the My Task section.

Sort Dropdown Menu

2. From the Sort dropdown menu, select Type to sort requests in the My Tasks section by type.

Note:
Clicking Type for a second time will sort the My Task list by type alphabetically.

Type

3. Click a Conflict of Interest Disclosure request in the My Task section. Conflict of interest disclosure requests are indicated by a D followed by a number, indicating the request ID (e.g., D - 19).

Complaint Request Link

4. (Optional) If you know the name of the conflict of interest request, click the Search link and enter the conflict of interest request name in the Search field.

Alternate Navigation

1. From the Home screen, click the Home dropdown menu.

Home Dropdown Menu

2. Click the Compliance Team Portal link.

Compliance Team Portal Link

3. From the Personal Trade screen, click the Disclosures tab.

Disclosures Tab

4. From the Disclosures screen, click a request in the Pending Review/More Information Required section.

Disclosure Request Link

Reviewing a Conflict of Interest Disclosure

1. From the Conflict of Interest Request screen, review the information in the Conflict of Interest section. 
   • Conflict Status: The conflict status (Actual, Potential, Other).
   • Conflict Type: The conflict type (Personal, Firm, Client/Investor, Other).
   • Provide details of the conflict: A brief description outlining the conflict of interest.
   • Support Documentation: Additional files or websites that give evidence supporting the suspicious activity.

Conflict of Interest Section

2. After reviewing the Conflict of Interest section, select an option to the question: Confirm whether this is a conflict of interest? Under the Compliance Review section. 

Confirm whether this is a conflict of interest? Radio Button

3. If the user selects the Yes radio button under the Confirm whether this is a conflict of interest? field, the following fields will appear:
   • Conflict Rating Pre-Mitigation: Select a pre-mitigation conflict rating. A pre-mitigation rating indicates the probability and impact the conflict of interest has.
     • Low
     • Medium Low
     • Medium
     • Medium High
     • High
   • Please provide a description of mitigating controls: Enter a brief description covering the migrating controls that need to be corrected or reassessed to prevent the conflict of interest for occurring in the future.
   • Conflict Rating Post-Mitigation: Select a post-mitigation conflict rating. A post-mitigation rating determines if the proper mitigating controls have been put in place or have issues with the existing controls been addressed.
     • Low
     • Medium Low
     • Medium
     • Medium High
     • High
   • If required, has the conflict been disclosed to clients?: 
     • Yes: The client has been made aware of the conflict of interest.
     • No: The client has not been made aware of the conflict of interest. If the user selects No, they will have to include further details.
   • Has the conflict been added to the Firm's Conflicts Register?: 
     • Yes: The conflict was added to the Firm's conflict register.
     • No: The conflict was not added to the Firm's conflict register. If the user selects No, they will have to include further details.

Compliance Review Section

4. Include support documentation by dragging and dropping files into the designated area on the Supporting Documentation field or select the top proportion of the Supporting Documentation field and select a file from the connected PC.

Supporting Documentation Field

5. Click the designated area on the Supporting Documentation field to add a web link. For more information on adding a web link to the project, see the Adding a Web Link article.

Web Link

6. (Optional) Click the following icons to edit or delete an image from the request:
   • Edit: Click the Edit icon to rename the file.
   • Delete: Click the Delete icon to remove the file from the request.

Image Icons

7. (Optional) Click the History tab to review the request's change log history.

History Tab

8. Select the Request More Information button to request further information from the employee. The employee who submitted the request will get a notification requesting for more information. The employee will see any comments in the Comments field.

Request More Information Button

9. Select the Complete Review button to approve the complaint disclosure request. The employee who submitted the request will get a notification. The employee will see any comments in the Comments field.

Complete Review Button