Is there a procedure for reporting conflicts of interest?

A separate reporting channel for conflicts of interest is not included in the VSME

The VSME basic module does not ask about a specific procedure for conflicts of interest. What is included is a question about a policy against bribery and corruption, and these two topics are often addressed together in practice: many customer portals ask about "integrity" as a collective term, and conflicts of interest typically fall under this as an example alongside bribery. If the undertaking has a code of conduct or integrity policy that also mentions conflicts of interest, this is the supporting document that fits such a question.

If a separate section on conflicts of interest is missing from the policy, then the most honest answer is that the question is not covered — do not enter a "yes" based on the broader anti-corruption policy if that word does not appear in it. The same nuance applies to the reporting channel itself: if the customer asks whether there is a channel where an employee or third party can report a suspicion, this is often the same question as about an internal reporting channel for whistleblowers. A whistleblowing scheme that is set up broadly enough typically also covers reports on conflicts of interest, even if that word does not appear literally in it.

Basis: the policy against bribery and corruption in the VSME

The VSME basic module of EFRAG contains a question about the undertaking's policy against bribery and corruption; a separate, standalone question about conflicts of interest is not included in it. This means that an answer about conflicts of interest is in practice derived from the broader integrity policy — see the explanation for the policy against bribery and corruption for what exactly falls under this and which document belongs to it. If that policy contains no mention of conflicts of interest, this is a reason to review the answer critically before confirming it.