ISO 37009:2025

Overview

ISO 37009:2025 - Conflict of interest in organizations - Guidance provides practical, sector‑neutral guidance for identifying, assessing, resolving and monitoring conflicts of interest. Built on the principles of trust, integrity, transparency and accountability, the standard is intended for all organization types (public, private and not‑for‑profit) and distinguishes between actual, apparent and potential conflict of interest. ISO 37009 is a guidance document (no normative references) that complements governance, compliance and risk management frameworks.

Key topics

ISO 37009 organizes conflict‑of‑interest management into a structured framework and covers these technical topics:

• Principles and framework: core values (trust, integrity, transparency, accountability) that underpin policies and processes.
• Leadership and policy: leadership commitment, governance responsibilities, and policy development for conflict‑of‑interest management.
• Roles and responsibilities: duties of the governing body, top management and personnel in prevention and remediation.
• Support mechanisms: required resources, competence, awareness, training and communication to implement the framework.
• Process lifecycle:
  • Identification (including disclosure procedures)
  • Assessment of actual, apparent and potential conflicts
  • Resolution procedures and decision‑making safeguards
  • Monitoring strategies to track and control conflict‑of‑interest risks
• Performance evaluation: review, compliance checks and evaluation of framework effectiveness.
• Annex and guidance: Annex A provides practical material on managing conflict of interest.

Practical applications

ISO 37009 helps organizations embed conflict‑of‑interest management into their governance and operational processes to:

• Mitigate risk and reduce corruption exposure
• Strengthen ethical decision‑making and stewardship
• Protect reputation and build stakeholder trust
• Improve compliance and dovetail with enterprise risk management

Typical users and functions:

• Boards and governing bodies setting policy and oversight
• Top management implementing governance and controls
• Compliance, legal, HR and procurement teams operating disclosure, assessment and resolution processes
• Internal audit and risk teams monitoring effectiveness and reporting

Related standards

ISO 37009 is intended to be used alongside other governance and integrity standards, including:

• ISO 37000 (governance of organizations)
• ISO 37001, ISO 37002, ISO 37003, ISO 37004, ISO/TS 37008 (anti‑bribery, whistleblowing and integrity tools)
• ISO 37301 (compliance management)
• ISO 31000 (risk management)

Keywords: ISO 37009, conflict of interest, conflict-of-interest management, governance, trust, integrity, transparency, accountability, risk management.