Conflicts of interest
Practical guidance for preparing this disclosure. Use this card to identify datapoints, verify claims and organise supporting evidence. For exact requirements, always refer to the official GRI source.
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This disclosure asks an organisation to explain how it identifies, manages and reports conflicts of interest that could affect decision-making, judgement or trust. In practice, it is about showing whether there are clear rules and processes for spotting actual, potential and perceived conflicts, and how those are handled across the organisation rather than only in a few visible parts of the business.
The practical focus is on coverage and consistency: the explanation should show whether the approach applies to the whole organisation, including governance bodies and relevant staff, and how it works in day-to-day operations. It should also make clear what happens when a conflict is identified, such as disclosure, recusal, review or other controls, so readers can see that the organisation is managing the issue in a systematic way.
* This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official GRI source.
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
| Datapoint | What to capture | Evidence hint | Owner |
|---|---|---|---|
| Conflict controls | A plain description of how the board prevents conflicts from arising and how it deals with them when they do arise, including the main checks, approvals, disclosures, recusals or other controls used. | Board policy on conflicts, committee terms of reference, code of conduct, declarations of interest, meeting minutes showing recusals or approvals. | Company secretariat / Legal / Governance |
| Cross-board conflicts | Whether conflicts are shared with stakeholders when they involve people serving on more than one board, and how that disclosure is handled in practice. | Governance disclosures, annual report narrative, board and committee minutes, director declarations, stakeholder communications. | Company secretariat / Legal / Investor relations |
| Supplier shareholdings | Whether stakeholders are told about conflicts that arise from the company and its suppliers or other stakeholders holding shares in each other, and the way those cases are disclosed. | Related-party and conflict registers, supplier relationship records, governance disclosures, procurement or legal files. | Procurement / Legal / Finance |
| Controlling owners | Whether stakeholders are informed when a controlling shareholder exists and that this is treated as a conflict matter in the disclosure. | Share register, ownership structure chart, annual report governance section, shareholder agreements, board papers. | Company secretariat / Legal / Finance |
| Related-party dealings | Whether conflicts linked to related parties are disclosed, including the relationship itself, any transactions, and any unpaid amounts still outstanding at the reporting date. | Related-party note, trial balance, intercompany and other receivables/payables schedules, board approvals, disclosure checklist. | Finance / Legal / Company secretariat |
Show GRI 2-15 sub-elements (LRA working checklist)
- Set out how the board prevents and reduces conflicts of interest.
- State whether conflicts are shared with stakeholders, including any overlap in board membership.
- State whether conflicts are shared with stakeholders, including any supplier or other stakeholder cross-holdings.
- State whether conflicts are shared with stakeholders, including where a controlling shareholder exists.
- State whether conflicts are shared with stakeholders, including connected parties, their links, transactions, and any unpaid balances.
LRA working checklist - paraphrased; see official source
- Set the reporting boundary first: identify which governance-level processes you are describing, and make sure the write-up covers how the top decision-making group handles conflicts of interest in practice.
- Map the prevention and mitigation controls: gather the policies, approval routes, declarations, recusal rules, monitoring checks, and escalation steps that show how conflicts are stopped or reduced before they affect decisions.
- Decide what counts as a conflict for this disclosure: include the four stakeholder-linked areas named in the source — board overlap, supplier or other stakeholder shareholdings, a controlling owner, and related-party links, dealings, and unpaid amounts.
- Collect the supporting evidence and turn it into a clear statement on disclosure: confirm whether these conflicts are shared with stakeholders, and note the relevant channels, reports, registers, or governance papers that support that answer.
- Draft the disclosure with both narrative and, where relevant, factual detail: explain the process in plain language, then state the disclosure position for each of the listed conflict areas without adding extra categories or omitting any of them.
- Record any exclusions, changes, or limitations, then check the final wording against the official source to make sure the meaning is complete, the scope is consistent, and nothing has been added, removed, or misstated.
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
Use your organisation’s own terms first, then map them to the reporting disclosure. For example, you may talk about director declarations, board registers, related-party papers, shareholder disclosures, or governance notices rather than using framework language in the request.
Can you confirm whether the organisation has conflicts of interest disclosures and whether the highest governance body has processes to prevent and mitigate them?
Please send the board conflict register, director interest declarations, related-party schedule, and any annual report or website wording for [period] covering [entity]. We need the material that shows how the board handles declarations, review, escalation, and follow-up for possible conflicts, and any external disclosure about board overlaps, supplier ownership links, controlling shareholders, and related-party relationships, transactions, and balances. Please include source, date, owner, and coverage, and flag any gaps.
Formal email template
Subject: Request for board conflict and related-party evidence for [reporting period] Hi [name/team], We are preparing the governance section for [reporting period] and need your help with the board conflict and related-party material. Please send, for [entity/boundary], the documents or extracts that show: - how the board handles declarations, review, escalation, and follow-up for possible conflicts; - whether and how conflict matters are shared outside the organisation; - any items covering overlap with other boards or committees; - any items covering ownership links with suppliers or other counterparties; - any items covering controlling shareholders; - any related-party material covering relationships, transactions, and outstanding balances. Please include the source document name, date, owner, and the period covered. If any item is not available, please say so and explain the gap. A possible LRA training template is attached below; please adapt this to your organisation’s own terms and check the official source before sign-off. Thanks, [preparer name]
Short Teams / Slack version
Hi [name/team] — could you send the board conflict register / related-party pack for [period] for [entity]? We need the papers or extracts showing how conflicts are handled, plus anything shared externally about board overlaps, supplier ownership links, controlling shareholders, and related-party relationships/transactions/balances. Please include source, date, owner, and coverage. If anything is missing, let me know. Please adapt this to your organisation’s own terms and check the official source before sign-off.
Financial services
Context. The company has a board, several committees, and a formal related-party process managed by the company secretariat and legal team.
Adapted request. Please share the board conflict register, committee declarations, related-party paper, and the annual governance note for [period]. We need the records showing how director interests are declared, reviewed, escalated, and tracked, plus any external wording about board overlaps, ownership links with counterparties, controlling shareholders, and related-party relationships, transactions, and balances. Include source, date, owner, and coverage.
Example response. Board register updated quarterly; annual report note approved by the board; related-party schedule from finance; website governance statement. External disclosure includes board overlap and related-party note; supplier ownership links are not separately disclosed.
Manufacturing
Context. The company has a family shareholder structure, a small board, and procurement relationships that may create ownership links with suppliers.
Adapted request. Please provide the director interest log, board minutes showing conflict handling, shareholder structure note, and any supplier ownership review for [period]. We need the material showing how possible conflicts are identified and managed, and whether any of these matters are shared in the annual report or on the website. Please also include any related-party relationships, transactions, and unpaid balances.
Example response. Director interest log maintained by the company secretary; board minutes record recusals; annual report includes a related-party note and a statement on controlling shareholders; supplier ownership review completed by procurement and legal; no separate public note on cross-board links.
The full request pack — response form, data table, evidence metadata and sign-off — is in the Download Centre.
LRA training templates — adapt them to your organisation, and check the official source before sign-off.
Explain how the organisation defines a conflict of interest, which governance groups are covered by the review, and what evidence was used to confirm the prevention, mitigation and disclosure arrangements.
Set out what the figures mean in practice by linking the disclosure approach to how the board manages independence, transparency and trust in decision-making.
If the disclosure pattern changed from the prior period, note whether this was due to new governance arrangements, a broader review of conflict types, or changes in what was shared with stakeholders.
GRI 2-15 Conflicts of interest — [location / page] / [notes]
Professional preparation tools and forms for GRI 2-15. Each download includes a concise “How to use” guide.
| Claim | Risk | Evidence to check |
|---|---|---|
| The information reported for this disclosure reconciles to the underlying source records. | What is reported cannot be traced back to the systems or documents it was drawn from, or does not tie out to them. | calculation_workbook reconciling the reported value to source_system_export |
| The information reported for this disclosure is current as at the reporting date. | The disclosure reflects a different period, a cut-off before the reporting date, or stale data carried over from a prior period. | approval_record showing the data cut-off date and the period covered |
| The scope behind the information reported for this disclosure is applied consistently. | Parts of the organisation are silently in or out of scope, or the scope differs from the prior period without that change being explained. | methodology defining the scope and a site_register of what it covers |
| Everything in scope is included in the information reported for this disclosure — nothing material is left out. | Parts of the population that should be reported are omitted, understating or overstating the disclosure. | site_register of the full population vs the calculation_workbook of what was actually included |
- The governing policy or written commitment behind this disclosure
- A methodology / definition note setting out how the disclosure was scoped and prepared
- Source-system exports the figures or facts were drawn from
- The internal approval / sign-off record for the disclosure before publication
- Minutes or records evidencing the relevant engagement or consultation
- The information is presented without a date or as-at point.
- The scope or boundary of the statement is left undefined.
- Key terms are used inconsistently across the report.
- Material changes since the previous period are not disclosed.
- Assertions are made without supporting detail or a source record.
- Boilerplate is used that does not actually answer what is asked.
- Wrong owner
The request goes to the wrong team, so the board process, disclosure practice, or related-party records are never pulled together from the people who actually run them.
- Framework language only
The data call uses GRI-style labels instead of the organisation’s own terms, and the people answering cannot map the request to their registers, approvals, or reporting packs.
- Scope not fixed
The team does not define which board members, committees, subsidiaries, or business units are in scope, so the data set ends up incomplete or too broad.
- Wrong reporting period
The collection window is left vague, so some teams send current-year information while others send opening balances, year-end positions, or a different cut-off date.
- Mixed counting basis
One source reports individual cases while another reports entities, transactions, or balances, and the results are merged as if they were the same measure.
- Source labels lost
Original tags from the register, board paper, or finance schedule are stripped out, making it impossible to trace each item back to the underlying record.
- Separate populations merged
Cross-board links, supplier holdings, controlling owners, and related-party items are lumped into one file even though they need to stay distinct for review.
- Evidence trail missing
The pack contains figures or statements but no note of where they came from, who checked them, or when the source was last updated.
- No sign-off record
The draft data is circulated without a clear approval trail, so nobody can show who reviewed the inputs before the disclosure text was written.
- What counts as the group that oversees conflict controls
Decide whether to describe the board alone or the board plus its committees, and explain the practical checks each part uses to stop and reduce conflicts.
- How to handle board links that sit across more than one entity
If a director serves on another board, state how you judge that link as a conflict and whether you tell external audiences about it.
- Whether supplier shareholdings are material enough to mention
Set a clear threshold for when an ownership stake in a supplier or other business partner is treated as relevant, and disclose the basis for that cut-off.
- How to treat a controlling owner with indirect influence
Explain whether you look only at direct control or also at indirect routes of influence, and say how that choice affects what you tell stakeholders.
- Which related-party links and balances are included
Define the relationships, transactions and unpaid amounts you include, and note any exclusions where the connection is too remote or immaterial to report separately.
- How to deal with entities entering or leaving the group during the year
State whether you report conflicts and related links using the year-end group, the average group, or another cut-off date, and explain how acquisitions or disposals change the scope.
- How to apply local definitions across different countries
Where local law or market practice uses different labels or tests, explain the rule you used to align those cases so the same type of conflict is treated consistently.
- When to use estimates, aggregation or rounding
If exact figures would expose personal or commercial details, say when you group items, round amounts, or use estimates, and make clear that the method is applied consistently.
Synthetic, written by LRA — not from a company report, not text from any standard.
We use a formal conflicts register, annual declarations, and pre-approval checks for outside interests so the board and its committees can spot, stop, and manage any issue before it affects decisions. In this synthetic example, 12 of 12 directors and 18 of 18 committee members filed declarations on time, and 3 potential conflicts were escalated, with 2 resolved through recusal and 1 through removal from the decision process.
- We also make selected conflict information available to stakeholders in our governance report, including links created by shared board membership, cross-holdings with suppliers and other counterparties, the presence of a controlling shareholder, and related-party relationships, transactions, and balances.
- For this illustrative disclosure, 4 of 4 identified related-party arrangements were reported, and 2 of 2 material outstanding balances were shown in the notes; no unreported material conflicts were identified at period end.
Our board requires annual declarations, meeting-by-meeting checks, and a documented escalation route so any personal or commercial conflict is identified early and handled before it can influence oversight. In this synthetic example, 9 of 9 directors completed declarations, 6 of 6 audit committee members confirmed no new issues at the latest review, and 2 matters were managed by abstention while 1 was referred for independent review.
- We tell stakeholders about relevant conflict matters in our annual report, covering overlapping board roles, share links with suppliers and other stakeholders, the existence of a controlling owner, and dealings with related parties, including the relationships involved, transactions made, and balances still open.
- In this illustrative case, 5 of 5 reportable related-party transactions were disclosed, alongside 3 of 3 outstanding balances; the same report also explained that no undisclosed cross-board or shareholding conflicts were found during the year.
How to turn the collected data into a draft disclosure. Suggested visuals and a GRI content-index line generated from this disclosure's datapoints.
Suggested visuals
- Board-level conflict prevention and mitigation process — table: A simple matrix showing the main controls, review steps and escalation routes used by the board and its committees to stop and manage conflicts of interest.
- Disclosure coverage by conflict type — stacked bar: A breakdown of which conflict categories are disclosed to stakeholders, split across cross-board roles, supplier or stakeholder shareholdings, controlling owners, and related-party matters.
- Stakeholder disclosure status by conflict category — bar: Which conflict categories are openly reported to stakeholders and which are not, using one bar per category for a clear at-a-glance comparison.
- Related-party disclosure detail — table: The specific information shared on related parties, including the relationship, any transactions, and any unpaid balances outstanding at the reporting date.
- Governance conflict disclosure map — donut: The share of identified conflict areas that are disclosed versus not disclosed, to give a quick visual of overall transparency coverage.
What separates a figure from a disclosure.
We have a process to spot and manage conflicts of interest.
We use board-level checks to prevent and reduce conflicts, and we tell stakeholders about them, including links to other boards, supplier shareholdings, controlling owners, and related-party dealings.
During the year, our board and committees used declarations, reviews and escalation steps to prevent and reduce conflicts across the group, and we disclosed them to stakeholders, including cross-board links, supplier shareholdings, controlling owners, and related-party relationships, transactions and unpaid balances; the main change was that we added a clearer review step after a new supplier link was identified.
Real reports where this topic is disclosed. The confidence label shows how closely each match maps to GRI 2-15 — these are report practice, not exact disclosure examples.
| Company | Sector · Country | Year | Match | Page | Report | Assurance | |||||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Interconexión Eléctrica S.A. E.S.P. | Electric Utilities / IPP / Energy Traders · Colombia | 2024 | Topic-family | p. 34 →p. 33 →p. 136 → | ISA Integrated Management Report 2024 → | ey | |||||||||||||||||||
Evidence in Interconexión Eléctrica S.A. E.S.P.’s reportWhat the report shows Interconexión Eléctrica S.A. E.S.P.'s 2024 Integrated Management Report provides partial information on the policy and practice of requesting external verification, mentioning this context on page 131 without specifying a headline value. There is no evidence found regarding the involvement of the highest governance body or other detailed narrative items related to this disclosure. Overall, the report offers limited coverage, with several key aspects notably missing or unclear.
Evidence-based summary of this company’s own report — not a disclosure template to copy, and not a compliance verdict. Datapoint coverage
Source trail
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| Thai Beverage Public Company Limited | Food and Beverage Processing · Thailand | 2024 | Partial | p. 142 →p. 79 →p. 14 → | Sustainability Report 2024 → | LRQA | |||||||||||||||||||
Evidence in Thai Beverage Public Company Limited’s reportWhat the report shows Thai Beverage Public Company Limited’s Sustainability Report 2024 provides coverage on the role of the highest governance body, including a reference to the Chair of this body on page 182. The report also details stakeholder engagement processes, with management interviews used to capture stakeholder perspectives as noted on page 180. However, there is no available evidence in the report regarding narrative items (b-ii), (b-iii), and (b-iv), indicating these aspects are not addressed or are unclear.
Evidence-based summary of this company’s own report — not a disclosure template to copy, and not a compliance verdict. Datapoint coverage
Source trail
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| Sumitomo Forestry Co., Ltd. | Home Building · Japan | 2025 | Exact | p. 11 →p. 449 →p. 34 → | Sustainability Report 2025 → | EY; BSI | |||||||||||||||||||
Evidence in Sumitomo Forestry Co., Ltd.’s reportWhat the report shows Sumitomo Forestry Co., Ltd.’s Sustainability Report 2025 includes coverage of governance aspects related to sustainability, such as the highest governance body’s role and conflicts of interest (p.528), as well as data on the proportion of senior management hired from the local community (p.530). The report also addresses corporate governance policies on cross-shareholding and standards for concurrent board positions (pp.456, 449). However, there is no evidence found for narrative item (b-iv), indicating a gap in coverage for that specific disclosure element.
Evidence-based summary of this company’s own report — not a disclosure template to copy, and not a compliance verdict. Datapoint coverage
Source trail
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A board member has joined a committee at another organisation that also does business with your organisation. The governance team is drafting the annual report and has a note that this outside role could affect how decisions are seen.Should this outside board role be treated as a conflict that is explained to stakeholders, and how should the team decide what to include?
Your organisation owns a minority stake in a supplier, and that supplier also has a small shareholding in your organisation through an investment vehicle. The reporting team is unsure whether this cross-ownership belongs in the governance section or can be left out because the amounts are small.Do you need to consider this cross-ownership when deciding what conflict information to share with stakeholders?
A family trust controls 62% of the voting rights in your organisation, and several directors are related to the trust’s beneficiaries. The draft report mentions the ownership structure but says nothing about possible conflicts because the trust is already named elsewhere in the report.Is it enough to mention the ownership structure, or should the team think about conflict disclosure as well?
Two senior managers are related to a company that provides key services, and one of those managers also sits on the procurement review panel. The finance team has recorded the relationship internally, but the external report currently only lists the supplier name and contract value.Should the report go beyond the contract details and explain the related-party link and any balances or transactions that matter to stakeholders?
See how companies actually report GRI 2-15 — drawn from their own published reports, with the exact pages, and an LRA AI-assistant that works through it with you. Available to LRA Community members and to students throughout their platform access.
How this disclosure maps across the major reporting frameworks.
For GRI 2-15, what data do I need to gather before I start drafting the disclosure?
The page says to prepare five datapoints: conflict controls, cross-board conflicts, supplier shareholdings, controlling owners, and related-party dealings. Use those as the starting checklist before you draft anything. ↑ section
How do I use the step-by-step 'how to prepare' section for GRI 2-15?
Use it as a practical workflow to move from scoping and data collection to drafting and checking the disclosure. The page is designed to help you prepare the disclosure in a structured way rather than leaving it as a last-minute write-up. ↑ section
Who should own the GRI 2-15 data collection in practice?
The page is aimed at sustainability/ESG managers, HR or data owners, and assurance reviewers, so ownership should sit with the people who can source and explain the underlying records. The key is to assign clear responsibility for each datapoint and the evidence behind it. ↑ section
What should I include in the evidence pack for GRI 2-15 assurance readiness?
The page includes an evidence pack with five items to support assurance readiness. Build it around the source records and supporting documents for the five datapoints, so a reviewer can trace the draft back to evidence. ↑ section
What are the four assurance claims I need to verify for GRI 2-15?
The page says there are four assurance claims to check, each with a claim, risk and evidence angle. Use those claims to test whether the disclosure is complete, supported and consistent with the underlying records. ↑ section
What are the common reporting gaps or mistakes on GRI 2-15?
The page lists common gaps and mistakes to help you avoid weak drafting and missing support. Use that section as a pre-submission check against your data, scope and evidence pack. ↑ section
How can I use the synthetic illustrative example for GRI 2-15 without copying it blindly?
The example is there to show how a disclosure might look, including a quantitative table where relevant. Treat it as a formatting and logic guide only, and make sure your own figures and narrative match your organisation’s actual data. ↑ section
What should the draft output for GRI 2-15 look like?
The page gives draft-output ideas including visualisation options, narrative starters and a GRI content-index line. Use those to turn your checked data into a first-pass disclosure that is easy to review and evidence. ↑ section
How do I use the Prep & Assurance workbook for GRI 2-15?
The Download Centre includes a Prep & Assurance workbook in .xlsx format. Use it to organise the datapoints, evidence and assurance checks before you finalise the draft. ↑ section
What is the printable Library Card PDF for GRI 2-15 used for?
The Download Centre also includes a printable Library Card in .pdf format. It is a quick reference version of the page content that you can use alongside the workbook during preparation and review. ↑ section
Does the page give real company examples for GRI 2-15 that I can compare against?
Yes, the page includes a 'From company reports' table that links to real published reports where the topic is disclosed. Use it to see how others have presented the topic, but keep your own disclosure grounded in your organisation’s data. ↑ section
- What are the five datapoints to prepare for GRI 2-15?
- How do I scope GRI 2-15 data for a first draft?
- What evidence should support conflict controls in GRI 2-15?
- What evidence should support cross-board conflicts in GRI 2-15?
- What evidence should support supplier shareholdings in GRI 2-15?
- What evidence should support controlling owners in GRI 2-15?
- What evidence should support related-party dealings in GRI 2-15?
- How do I turn the GRI 2-15 workbook into a draft disclosure?
- What narrative starters are suggested for GRI 2-15?
- What visualisation ideas are suggested for GRI 2-15?
- What are the common mistakes to avoid when drafting GRI 2-15?
- Where can I find real published reports for GRI 2-15 examples?
Get a practical answer for your reporting context. Your first answer is free — create a free account to continue the conversation.
Sources, status and disclaimer
This LRA assistance tool is designed for educational and internal data-collection purposes. It is not an official interpretation of the GRI Standards, IFRS Sustainability Disclosure Standards or EU CSRD/ESRS requirements. When applying these frameworks in professional practice, users should consult and double-check the official standards, guidance and applicable regulatory sources.