A “conflict of interest” (COI) is a situation in which a person or organization is involved in multiple interests, financial interests, personal or other interests, one or more of which could possibly influence the motivation of the individual or organization.

A person or entity avoids a conflict of interest by:

• a.) not engaging in activity that might be conflicted by a duality of interest, or
• b.) disclosing the potential conflict – allowing associated parties to be aware and decide independently if the conflict is influencing behavior.

In essence, when presented with a potential conflict of interest, be truthful and provide full disclosure.
If unsure, err on the side of full transparency, and do so as soon as the conflict presents – don’t wait.
This becomes the generally accepted best ethical practice to avoid potential issues that may arise as a consequence of conflicted interest; especially financial conflicts.
♦ Recently, the financial payments by political entities upon media personalities has created quite a stir.  When CTH revealed (from FEC filings) financial payments by Political Action Committees to media pundit Erick Erickson (and others), the response was to besmirch CTH for revealing the payments.

The response to the sunlight reveals more about the entity engaging in the scurrilous conflict than it does about the entity who exposes it.   The reaction is intended to distract from the original issue, and generally reveals what everyone already knows: if there’s nothing to hide, and no issue inherent, then why was the conflict never disclosed?
It can most certainly be true that Eric Erickson is, as a matter of pure position, ideologically aligned with Katie Packer (Our Principles PAC), and therefore a natural benefactor of advocacy/advertising payments from Packer to Erickson.  This is not disputed, nor is it an issue.
The conflict arises when Erickson does not reveal his political punditry positions are also gaining financial benefit from those who align with him ideologically in common purpose against their mutual opponent, candidate Donald Trump.
As a consequence, when financial reports reveal (two months delayed) that Mr. Erickson received $15,000+ from “Keep the Promise” and “Our Principles” PACs’, and then immediately thereafter begins a #NeverTrump social media campaign – well, it doesn’t take long to see how they could be related.
If the financial conflict was stated earlier, before or immediately after the transaction transpired, there wouldn’t be such an issue.
As much as George Will is an insufferable tool of the professional republican party establishment; on several occasions of punditry Mr. Will revealed his wife was working for Governor Scott Walker’s presidential campaign.
Mr. Will, by revealing the possible conflict, avoids the conflict of interest trap, and allows the audience to review his opinions through the prism of transparency.  That’s the way ‘conflicts’ are supposed to be handled.
♦  When Fox News broadcasts a presidential debate and the executive in charge of producing the content (Bill Sammon – below left), is also the person who directly approves the questions from the moderators, and is also the father of the national spokesperson (Brooke Sammon – below right) for Marco Rubio – one of the candidates – Fox News has an obligation to reveal the conflict.

Just because Fox News chose to not disclose the conflict of interest does not mean the conflict of interest does not exist.   Exactly the opposite is true – there is a clear conflict of interest when the executive in charge of the debate (Dad) is directly related to a person who may benefit from the debate outcome (Daughter).

The lack of disclosure says more about the ethical perspectives of Fox News executives than it does about the person or entity who brings sunlight upon the conflict.
♦  When Fox News pundit Megyn Kelly receives a $10 million dollar book deal from Harper Collins, which is also owned by Rupert Murdoch the Chairman of Fox News – and a person who has engaged in political advocacy as a direct consequence of his influential position – the viewing audience should be made aware the possibility of conflicted interests carried by Megyn Kelly as she opines her pundit opinion with the same political advocacy as her financial benefactor.

Fox employee Megyn Kelly and Fox Owner Rupert Murdoch may hold the same coincidental opinions as a consequence of their similar world-views;  However, there is a financial bond which presents a potential conflict of interest and therefore should be revealed to the consuming audience.
Failure to do so says more about the professional ethics of Kelly and Murdoch than it does about anyone who would challenge them to be transparent in their business arrangement.
These undisclosed conflicts become increasingly problematic when Fox News holds further undisclosed content shaping executive meetings with Senator Marco Rubio and broadcast pundits on the topic of immigration reform.
Absent of honest disclosures the motive(s) inherent in the content delivered and political policy discussion becomes questionable.
♦ The same problem exists for Salem Communication radio talk show host, Hugh Hewitt who takes a lead role in setting up an exclusive Marco Rubio interview for radio hosts only, and then telling the Salem Co employees how they are to deliver their punditry to benefit Senator Rubio’s immigration platform.
When Hugh Hewitt and the company corporate vice-president, Tom Tradup, tells the radio hosts (Mike Gallagher, Katie Pavlich, Mark Davis) and peers they are not allowed to challenge the orthodoxy of the Salem Communication advocacy agenda on behalf of immigration (early 2014) – an automatic conflict of interest is presented.
Salem Communications Group also owns RedState, HotAir, Twitchy, Human Events, TownHall, and BearingArms – It is not coincidental these websites are all engaged in the transmission of the exact same message and points of advocacy.
♦ When the chairman of Glenn Beck’s charity group, David Barton – Mercury One, is also an executive in charge of a Pro-Cruz “Keep the Promise” Super-PAC another network of possible conflicts arise.
Yes, it is true the network of affiliated media and political groups may just form a natural alignment as a matter of ideological familiarity.  However, that does not mean the entities within the arrangement lose their responsibility to tell the consuming audience about their inter-connected financial affiliations.

Again, it’s not for the person or entities within the conflict to decide whether or not full disclosure compromises their intended activity.  If perspective influences the decision to reveal the conflict – the conflict is even more in need of disclosure.
♦  The ‘personal conflict aspect’ is where media personality Mark Levin appears to be uncomfortable with disclosure and seemingly became agitated.  Levin failed to reveal his fiancé’s son was a full-time staff member for Senator Ted Cruz.  We noted his agitated state after he made the admission on air.
Long before Mark Levin began endorsing Senator Cruz he should have revealed the personal conflict of interest.  It is always better to reveal a conflict before it surfaces because the lack of disclosure implies something to hide. Occam’s razor would reveal it was far more likely Levin didn’t want his radio audience to become aware of his divorce. Not disclosing the connection to his fiancé’s son – appears to be a personal decision driven by emotion.
No-one in the disappointed listening audience ever said the soon-to-be son-in-law doesn’t have a right to work wherever he chooses, of course he does.  The issue is the political pundit having a personal familial connection to the advocate of his voice – and not revealing the relationship.
Again, like all conflicts of interest, small issues can become much bigger credibility issues when they are not disclosed.  Mark Levin’s entire business model is almost exclusively based around the premise of paid opinion/punditry.  In that profession there is an even greater burden to disclose anything that might appear as a conflict of interest.
The appearance of impropriety can evolve to become impropriety by itself.
♦  Another more brutally obvious conflict of interest lies with Ben Shapiro and the foundation for another media enterprise “The Daily Wire”.   The billionaire Wilks Brothers put up the money to start the Daily Wire for Mr. Shapiro;  The Wilks Brothers also funded Keep the Promise III PAC to benefit Ted Cruz.  Mr. Shapiro now writes exclusively pro-Cruz material on his outlet, and attacks any Cruz opposition.
It can be factually accurate that Shapiro just likes Ted Cruz and so too do the Wilks Brothers.   Shapiro’s opinions and media presentations -including appearances on Megyn Kelly Fox Show- may have nothing to do with the political opinions of the people paying him.
However, again, when it comes to conflicts of interest, disclosure matters.  Why doesn’t Ben Shapiro give a George Will type disclaimer and openly say: “the billionaires backing my punditry enterprises are also financially backing Ted Cruz”.    The disclosure eliminates much of the conflict and allows the audience to be objective in considering the opinion.
In the current climate of highly-charged political opinion, simple honest disclosures can avoid many of the inherent issues.  Conversely, the refusal to present simple and honest disclosures increasingly implies there is an agenda behind the punditry.
The modern era of almost instantaneous communication, along with exponentially more modern internet resources to find data at its origin, is creating increased cynicism and skepticism each time one of these hidden conflicts are dragged into the spotlight.  A political pundit can lose credibility literally overnight.
Those who derive their income from the delivery of information would be far better served doing everything they can to support transparency and honesty – rather than align themselves with those who hold ulterior motives in the vain hope they will not be discovered.