Recognising conflicts of interest

1. Regulatory Concept & Core Standards

In this video we will work through a concrete decision: identify an interest that may affect judgment. The aim is to explain the criterion used and apply it to a workplace situation. We will start with the concept, move to the procedure and finish with a case to solve. Managing interests protects impartiality before a decision is affected. A conflict is not automatically proven corruption. An internal monetary limit does not make every offer below it lawful.

Personal, family or financial interests may impair impartiality or reasonably appear to do so. The legal duty depends on role and procedure.

Apply the following rule: Article 4 covers specified EU-law matters, EU financial interests and the internal market. Law 5095/2024 article 20 adds the specified national bribery and trading-in-influence offences. Law 5232/2025 article 9 adds EU restrictive-measures breaches. Law 5321/2026 article 20 adds the AI Act to the Annex and updates the general-product-safety reference. Apply the particular provision’s temporal and material scope; not every workplace disagreement qualifies.

2. Practical Implementation & Procedure

Assess the relationship to the decision. Disclose relevant interests through the required process. An authorised impartial person determines the response. Before moving on, turn this procedure into a sequence you could explain to a colleague. Identify the first check, the action that depends on its outcome and the record that allows the decision to be reconstructed. Follow the sequence on screen and identify the point where an error would change the result.

Consider how a colleague taking over tomorrow would understand the decision. Identify the verified information and its source, who is authorised to decide and who checks the result. The record should connect the decision to the material actually used rather than repeat the whole file. State critical gaps and assign a specific action to resolve them. This makes continuity independent of one person’s memory. Apply the proposed organisational steps within legal powers. In the case, distinguish observation, conclusion and hypothesis. An observation describes available evidence, a conclusion explains what can reasonably be inferred and a hypothesis still needs checking. Do not infer motives merely from unusual behaviour. Identify which further information could change the decision and whether it can be obtained lawfully and proportionately. Incomplete knowledge justifies neither certainty of guilt nor indifference to an actual risk.

For Greek public contracts, Law 4412/2016 article 24 provides for prevention, identification and remedy of conflicts of interest. Disclosure enables the contracting authority to decide appropriate corrective measures. Check the specific role and applicable regime. A private-purchasing policy must not automatically be described as the same public procedure.

3. Case Study & Compliance Action

An evaluator’s relative works for a bidder. She believes she can be objective and does not disclose it. Now read the case carefully. Separate established facts from information you would still need to confirm. Do not add motives or events that have not been described. This distinction matters when choosing a response proportionate to the information available.

The exercise is as follows: Is personal confidence in impartiality enough? Choose an answer and write one sentence explaining it. During the pause, compare your choice with the criteria we have just considered. Also think about the material you would retain to explain the decision later.

No. Assess the relationship under law and procedure independently of self-assessment.

One mistake to avoid is: self-approval of one’s own conflict.

Now apply the national rule to a second decision. A report is automatically called protected because it includes the word corruption. What check is missing?

Assess the facts, work-related context and national protection conditions. The form label helps organise information but does not decide legal coverage. If the case is outside scope, identify an appropriate procedure without unnecessary disclosure.