Contracting: Avoiding Personal Conflicts of Interest (PCI) and Maintaining Compliance

By Emily Sanders

Personal conflicts are different than organizational conflicts in that they deal expressly with specific employees within an organization. PCIs detail a situation in which a covered employee has their own financial interest or personal stake in a job that would impair their ability to act objectively and in the best interest of the government. Such financial interests could be research funding, real estate investments, business ownership, compensation, etc..

The Federal Acquisition Regulation (FAR) did not contain particular regulations for personal conflicts until 2011 when the council published rules that answered two key questions for companies who were hiring covered employees:

Who and what do these rules apply to?

  • The new PCI regulations apply explicitly to contracts which call for employees to perform very specific types of acquisition support work.

 What must firms do to comply to such rules?

  • Identify which employees are covered and acquire financial disclosures.
  • Oversee employee assignment.
  • Collect signed non-disclosure agreements from covered employees.
  • Train employees to identify and prevent PCIs.
  • Maintain PCI compliance.
  • Inform contracting officer of any PCI violations.
  • Discipline covered employees who disregard PCI policy.


A covered employee is one who performs acquisition functions that closely correspond with government functions. Covered employees must be an employee of the contractor or a self-employed contractor that is operating as a covered employee themselves. Because such employees are the only ones at risk of violating PCIs, they must be closely monitored and continually abide by their non-disclosure agreements to prevent disciplinary action.


How Concord Helps Identify and Prevent PCIs

Concord Worldwide has developed an online contract management system that simplifies and optimizes the way companies handle their contracts. With e-negotiation and free e-signatures, you can increase both speed and compliance of contract development by 90%.

Through Concord’s online system, you can manage contracts from creation to execution, always controlling who has access to edit and view your company’s documents. Enjoy online editing with track changes, contract templates, deadline alerts, etc..

With Concord’s cloud-based system, transparency and ease of use are increased markedly, allowing your company to more easily identify PCIs almost immediately and avert them before disciplinary action is necessary. With Concord’s new upgraded system you have access to amendments management, custom identification policies, subsidiary management and more. Advanced access control allows for administrative oversight, user groups, access roles and custom roles to more efficiently manage contract and employee information. Concord’s contract management platform will aid in the acquisition and maintenance of financial disclosures for covered employees and will be constantly monitored for ensured compliance. Concord will make contract administration easier and cooperation with FAR regulations hassle-free.

To learn more about how cloud storage can change the way you manage your contracts, fill out the form on this page to chat with one of our contract management specialists, or call us at 844-693-7446.