Make personnel and relevant interested parties aware of the policy, of what a conflict of interest looks like in their own roles, of the duty and timing of disclosure, of how to disclose and where to get advice, of the protection given to those who disclose or report, and of what follows from failing to declare. Train personnel, including the governing body and top management, when they join and at planned intervals suited to their exposure, update the programme when new information warrants it, and keep records of what was delivered, when and to whom.
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.