Особистісний аспект процесів управління конфліктами інтересів в небанківських надавачів платіжних послуг

The general policy of managing conflicts of interest within non-bank payment service providers is a multi-component and complex process, which consists of the development of the necessary internal documentation, and constant interaction between employees and the second line of the internal control system, which includes compliance and risk managers, and cultivation of values of intolerance to any manifestations of abuse of authority and corruption. The article focuses on the personal side of the conflict of interest management process, i.e. how to build and create a microclimate in the team in which employees will be conscious of the proper identification and timely detection of potential conflicts of interest and will have the necessary level of awareness and theoretical training. The National Bank of Ukraine, as the payment market regulator, sets high standards that supervised entities must meet in order to build an effective conflict of interest management model. The study provides a rationale that proves that, first of all, an ecosystem should be formed within payment service providers to make it impossible to conceal cases of conflicts of interest or to fail to identify them in a timely manner, and to form high-quality channels and methods of communication between different levels of the organisational structure with the ultimate goal of effective identification, thorough assessment, and proper management and control of conflicts of interest. The author emphasises that payment service providers should not be limited to the provisions of the regulator’s regulations, but should be guided by the specifics of their activities, personal characteristics of their employees and focus on an individual approach to the process of regulating conflicts of interest. Based on the results of the study, the author draws attention to the practical aspects that can qualitatively influence the process of staff understanding of the importance and necessity of the conflict of interest management policy implemented within the enterprise and its interdependence with the business reputation of the payment service provider.