If the internal audit department offered to run a March Madness pool which was open to all employees of the organization would this be considered a breach of ethics or potential conflict of interest?

If the internal audit department offered to run a March Madness pool which was open to all employees of the organization would this be considered a breach of ethics or potential conflict of interest?
The breach of ethics part is a better question for an attorney, but it is definitely a potential conflict....... unless internal audit was using the pool as a ruse to determine if an employee has a gambling problem. However, if that was the case, there SHOULD be a paper trail someplace indicating the purpose of the pool, etc in the minutes, corporate documents, etc.

If it's not an procedure designed by the internal audit staff for a legitimate purpose, then at best it's a bad judgment call on their part.