Califix COI · Continuous Conflict of Interest Monitoring

Declaring a conflict of interest is not enough. You have to monitor it.

Automate the full conflict-of-interest process and keep your organization under continuous monitoring all year.

A declaration is a snapshot. Califix turns the process into a video.

An unseen conflict can cost US$1.5 million.

At Anglo American Sur, the relationship continued after the vendor was rejected.

The damage

A conflict in a purchasing role can cost US$1.5 million and continue after the vendor is rejected.

In January 2025, Anglo American Sur filed a criminal complaint for fraud and conflict of interest against its former Road Safety and Emergencies superintendent. The mining company estimated the loss at CLP 1,353 million, about US$1.5 to 1.6 million.

  • His own company

    The complaint says the scheme ran through Ingeniería SIGCT SpA, a company founded by and tied to the employee himself.

  • Emergency purchases

    Between August 2022 and November 2024, 46 emergency purchase requests were issued outside a tender. The complaint estimates CLP 1,168 million in unsupported services.

  • Rejection did not close the route

    The system flagged SIGCT as medium risk and rejected it as a vendor. Payments continued, triangulated through Ambipar Response Chile Ltda.

A 2022 declaration would have been a snapshot. The relationship continued for more than two years and moved to another company when the first control blocked it. The case is under criminal investigation by the Public Prosecutor.

Most companies know how to ask for a declaration. The problem starts after that.

An annual declaration shows one person’s situation at one moment. Califix collects the declaration, records the signature, keeps the PDF, calculates validity, and reopens the cycle when it is due.

Traditional approach

Califix COI

Annual form

Declaration + continuous monitoring

Snapshot

Video

Excel / file storage

Structured evidence

Manual review

Follow-up and attention signals

Reviewed when someone remembers

Validity all year

Hard to reconstruct history

Audit trail for every signature

Reactive management

Preventive management

The real risk is not only that someone fails to declare. It is that their situation changes and nobody notices.

Move from an annual declaration to continuous control

The process does not end when the employee declares. Califix keeps the cycle active all year.

  1. 01

    Declaration

    The employee completes the digital declaration.

  2. 02

    Signature / acceptance

    They accept the legal text. Date, email, and IP are recorded.

  3. 03

    Review

    Compliance sees the result: no conflict, or a relationship.

  4. 04

    Validity

    The renewal policy calculates the next expiration.

  5. 05

    Continuous monitoring

    The register stays current, expiring, or expired.

  6. 06

    New signal

    Pending, expiring, expired, or signed with a conflict.

  7. 07

    New campaign

    The invitation reopens. The previous declaration stays.

  8. 08

    Effective control

    The relationship stays in view. If it moves to another company, the earlier signature does not close the control.

What Califix COI includes

Less manual administration. More control.

  • Digital declarations

    Centralizes each employee’s declaration, with campaign, signature follow-up, and result.

    • Digital declaration form
    • Invitation and reminder campaigns
    • Renewal policy by role
    • Acceptance of the legal text and signature
    • Each person’s status on the register
  • Signature and traceability

    Each signature is tied to evidence that can be opened again.

    • Who declared
    • When they declared
    • What they declared
    • Which version of the text they accepted
    • PDF with date, email, IP, and hash
  • Review

    Compliance separates declarations with no conflict from those that report a relationship, and keeps the PDF.

    • No conflict or with a conflict
    • Relationship, role, and company identifier
    • Cross-check against the principal’s contractors
    • Declaration PDF
    • Record history
  • Alerts

    What needs follow-up shows up on the register and in reports, without waiting for someone to remember.

    • Pending declaration
    • Expiring
    • Expired
    • Signed with a conflict
    • Relationship that matches a contractor
  • Effective control

    The relationship stays in view. If it moves to another company, the earlier signature does not close the control.

    • The relationship stays visible all year
    • The earlier signature does not close the case
    • The contractor cross-check continues
    • A new company reopens the review
    • The previous declaration remains as evidence

Continuous monitoring

The declaration happens once. Monitoring happens all year.

The renewal policy sets how often each role must sign again. The register shows current, expiring, or expired. When the cycle is due, a new invitation goes out and the previous signature remains.

  1. Declaration
  2. Validity
  3. Status change
  4. Attention
  5. New review

Audit trail

Everything is recorded.

The platform keeps what was declared, when it was signed, and which earlier declarations are still available. It is there to show later what happened.

Compliance dashboard

Example

Signature coverage, pending items, result with or without a conflict, register validity, and the series of invitations and signatures over time. Filter by campaign and by role.

Signed / active
86%
Pending
41
With a conflict
7
Current
312
Expiring
28
Expired
14

A conflict can appear after the declaration. Califix keeps watching.

Turn conflict-of-interest control into a continuous, traceable process. Full traceability. All year.

  1. Jan

    Declaration

  2. Feb

    Monitoring

  3. Mar

    Validity

  4. Apr

    Monitoring

  5. May

    Expiring

  6. Jun

    Monitoring

  7. Jul

    Monitoring

  8. Aug

    New signature

  9. Sep

    Monitoring

  10. Oct

    Monitoring

  11. Nov

    Validity

  12. Dec

    History

Who it is for

  • Chief Compliance Officer

    Visibility into the register, signature coverage, and the evidence behind the program.

  • Compliance Manager

    Fewer spreadsheets. Campaigns, reminders, and expirations stay in one cycle.

  • Internal Audit

    Each signature has a PDF, a date, and a trace. Earlier declarations are not deleted.

  • Legal

    The accepted text, the version, and the signed document stay tied to the person.

  • Risk and governance

    Conflict control lives alongside the rest of Califix compliance modules.

Less manual administration. More control.

  • Less administrative work

    Fewer loose forms, files, and manual tracking of who signed.

  • Broader coverage

    The campaign and validity stay active after the annual close.

  • Stronger traceability

    Each declaration’s history is centralized, with the PDF of every signature.

  • Cycle detection

    Expiring, expired, and signed with a conflict show up before the next audit.

  • Audit readiness

    The evidence is organized when someone asks to reconstruct what was declared.

  • Scale

    The same cycle works for hundreds or thousands of employees.

Security and trust

Califix is working toward ISO 27001 certification.

  • Access control

    The module is enabled by permission: register, campaigns, declarations, policy, reports.

  • Protected evidence

    The PDF is encrypted, with no public listing. It opens through a time-limited link.

  • Traceability

    The record keeps additions, changes, and invitations. Each new signature leaves the previous one in place.

  • Cloud infrastructure

    Each country runs on its own database. Available in the United States, Chile, Peru, Brazil, Mexico, and Colombia.

Start with one control. Expand to your full compliance program.

COI is one module of the Califix platform for centralizing and monitoring compliance and third-party risk. Start where the problem is. Expand when you are ready.

  • Conflicts of interest
  • Data protection
  • Sanctions
  • Labor management
  • Supply chain

Stop managing conflicts of interest in spreadsheets.

Automate the declaration, monitor changes in validity, and keep evidence of the whole process all year.