Conflicts of Interest Register

Directors and officers have a legal duty to disclose conflicts of interest. For corporate groups where individuals hold positions across multiple entities, conflicts are common — a director of the parent company who also sits on a subsidiary board, an officer with a financial interest in a supplier, or a trustee who is also a beneficiary. EntityFlo's Conflicts of Interest Register provides a structured approach to managing conflict declarations. Each declaration is recorded with full details, linked to the relevant entities and individuals, and tracked through a clear management workflow.

When a director or officer declares a conflict of interest, EntityFlo records: • The nature of the conflict (financial interest, related party transaction, competing directorship, etc.) • The entities affected by the conflict • The date of disclosure • Whether the conflict is material • Whether the individual receives remuneration from the conflicting interest • The management strategy (abstain from decisions, recuse from meetings, resign from position, etc.) • Supporting documents (written declarations, board minutes recording the disclosure) Each declaration is linked to the individual's officer profile, making it easy to see all conflicts across their entire appointment history.

Conflicts don't disappear after initial declaration — they need ongoing management. EntityFlo tracks the status of each conflict (active, managed, resolved) and prompts periodic review to ensure management strategies remain appropriate. For directors who hold positions across multiple entities in the group, EntityFlo can automatically identify potential conflicts based on cross-entity appointments and transactions. This proactive identification supplements self-declaration, helping to catch conflicts that individuals may not recognise or may fail to disclose.

Conflict declarations are integrated with EntityFlo's board meeting workflow. At the start of each meeting, the system can prompt for conflict declarations related to agenda items. When a director has a declared conflict relevant to a specific agenda item, the meeting record notes their recusal and records that they were absent for the relevant discussion and vote. This integration ensures that conflict management isn't just a register sitting in a drawer — it's an active part of your governance practice, enforced at every decision point.