Disclosure management

Conflicts of interest, declared and decided

Build declaration forms around your policy and send them to the right people. See who still owes one, then review and approve each declaration, with your reasoning on record.

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A declaration is where managing a conflict starts

A declaration nobody reviews doesn't manage the conflict. The employee describes their interest, and your team decides whether it matters and what happens next, on a record anyone can follow.

  • Catch conflicts while they're small

    Most conflicts are simple to resolve when declared early. Left undeclared, they come back later as reports.

  • Treat similar conflicts alike

    One review process for every team, so no one gets a stricter or softer hearing for the same conflict.

  • Show how you decided

    Every answer, reviewer, and decision note stays with the declaration, so you can back up any decision later.

  • Build forms around your conflict of interest policy

    In Disclosure Management, write the questions and the guidance employees see, with AI to help you draft them, then choose how each form reaches people.

    • Ask about shareholdings, family ties, and board seats, with your policy shown above the questions

    • Invite new starters or everyone due for the annual refresh, straight from your employee list

    • Share a link so people can declare whenever their circumstances change

    • Email a personal invite to anyone moving into a new role

  • Decide each declaration, and record why

    Most declarations need no action, so routine ones can be approved automatically, and your time goes to the ones that need judgment.

    • Set form rules that approve a declaration without review, for example when every answer is “no”

    • Assign a declaration to a colleague in legal, HR, or finance for review

    • Record the actions taken and the reasoning behind each decision

    • Move each one from review to a final decision, and reopen it if circumstances change

  • Follow up when a conflict wasn’t declared

    Sometimes a colleague spots a conflict first, like a manager hiring a relative or a buyer close to a supplier. Their report becomes a case, kept apart from your declarations but under the same login.

    • Add conflicts of interest as a reporting category, with the questions you need answered

    • Ask follow-up questions in a private chat, whether or not the reporter shares their name

    • Hide the case from anyone it names, and from their managers

    • Open an investigation when needed, with interviews, evidence, and findings kept together

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One platform for disclosures, reports, and cases

Disclosure Management, Anonymous Reporting, and Case Management work together in FaceUp. Declarations surface the conflicts people know about, and reports and cases handle the ones someone else notices.

Disclosure Management

Employees declare conflicts, gifts, and outside activities on forms you send. You see who’s pending and review each one.

See how disclosures work

Anonymous Reporting

A colleague who sees an undeclared conflict can report it online, in the app, or by hotline, anonymously if they choose.

See how reporting works

Case Management

Each report gets an owner, deadlines, and a full history, and moves into an investigation when it needs one.

See the case workflow

Why teams use FaceUp for conflicts of interest

Every declaration stays confidential, from the first answer to the final decision. FaceUp fits the systems and policies you already have, and your team adjusts it without IT.

  • Know who still owes a declaration

    See who was asked and who's answered, then remind everyone still pending in one click, as often as you need.

  • Automatic approvals

    Auto-approve routine “nothing to declare” answers, so your team only reviews the ones that need judgment.

  • Secure, confidential declarations

    Declarations are stored in your region, outside your IT systems, and only colleagues with access can open them.

  • Ask at the right moments

    Run separate forms for new joiners, the annual refresh, and changes in someone's role or situation.

  • Works with your existing systems

    Sync employees from BambooHR or Paylocity, get alerts in Slack or Microsoft Teams, and connect more apps via Zapier.

  • Adjust forms as your policy changes

    Edit questions and guidance each round. Once answered, forms lock so everyone sees the same version.

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Seamless integrations with 8,000+ apps

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Built for the conflict of interest laws and standards you answer to

Laws, regulations, and standards like these expect you to show how conflicts were declared, reviewed, and resolved. FaceUp keeps that record for every declaration, ready when an auditor or regulator asks.

    Sarbanes-Oxley Act, Section 406 (code of ethics for senior financial officers)

    NYSE Listed Company Manual, Section 303A.10

    Nasdaq Listing Rule 5610

    DOJ Evaluation of Corporate Compliance Programs

    Companies Act 2006, sections 175 and 177

    Bribery Act 2010, section 7 (failure to prevent bribery)

    Markets in Financial Instruments Directive (MiFID II), Article 23

    Federal Decree-Law No. 32 of 2021 on Commercial Companies

    Companies Law (Royal Decree M/132 of 1443H)

    ISO 37001:2025 (Anti-bribery Management Systems)

    ISO 37301:2021 (Compliance Management Systems)

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From the teams who run it themselves

Enterprise-grade security

Independently certified. Encrypted and anonymous by design.

FaceUp protects sensitive compliance data with independently verified security controls, so employees can trust the channel and speak up safely.

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