Conflicts of interest sit at the centre of Saudi governance reform: the Companies Law regulates related-party dealings, NAZAHA targets the corruption that undisclosed interests enable, and boards are expected to manage conflicts rather than merely prohibit them. A working conflict of interest policy — and the declaration machinery behind it — is how that expectation is met.
What counts as a conflict of interest
A conflict exists whenever a personal interest could improperly influence professional judgement: a shareholding in a supplier, a relative in a department you oversee, an external board seat, a side business competing with the employer, or gifts and hospitality from a counterparty. The policy should define these concretely with Saudi-context examples, and cover actual, potential and perceived conflicts — perception damages trust as surely as reality.
Declaration duties: who declares, when
Three triggers structure a mature programme: an annual campaign covering all staff (with certification even when there is nothing to declare — a nil declaration is evidence too); event-driven declarations when circumstances change (new supplier relationship, marriage, inheritance, board appointment); and role-based declarations at hiring or transfer into sensitive functions like procurement and finance. Boards and executives declare under the Companies Law’s related-party regime with additional formality.
From declaration to management: reviews, plans, recusal
A declaration is raw material; management is the product. Each disclosure should be risk-scored and routed to review, producing one of: no action, a management plan (restrictions, monitoring, divestment timelines) with an owner and deadline, or recusal from specified decisions. Recusal is where policy meets systems: when a whistleblowing case or procurement decision touches a declared interest, exclusion should be automatic — enforced by the platform, not by memory. This is exactly what Raqeeb’s COI module automates, including auto-recusal of investigators inside case management.
The register and the audit
Keep a living COI register: declarations, scores, decisions, plans, attestations — timestamped and immutable. Auditors ask three questions: is the campaign complete, are high-risk declarations managed, and did recusals actually happen? A register that answers all three on screen is the difference between an observation and a finding.
- Cover actual, potential and perceived conflicts with concrete Saudi-context examples.
- Run annual, event-driven and role-based declaration triggers; require nil declarations.
- Every disclosure gets a decision: clear, manage with a plan, or recuse — automatically enforced.
- A living, immutable register is your audit defence.
Frequently asked questions
What should a conflict of interest policy include in Saudi Arabia?
Definitions with examples, declaration duties and triggers, the review and risk-scoring process, management-plan and recusal rules, board/related-party procedures aligned with the Companies Law, register and retention arrangements, and consequences for non-disclosure.
How often should employees declare conflicts of interest?
Annually as a certification campaign — including nil declarations — plus immediately upon any change in circumstances, and at hiring or transfer into sensitive roles.
What happens when a declared conflict touches an investigation?
The conflicted person should be automatically recused from the case before assignment, with the recusal logged. In Raqeeb, declared interests recuse investigators inside case management without relying on anyone remembering.
Whistleblowing, case management, conflict-of-interest and gifts registers — one Arabic-first platform, hosted entirely in the Kingdom.