The holidays are here. The office is filled with cheer. . . and gifts that might be putting your organization at risk.
During the holiday season, employees will give and receive more gifts from customers and third parties than any other time of the year. We've compiled 6 ways you can help employees stay compliant with your internal policies.
- Be clear in your policies and how you communicate with employees. For instance, if your policy says employees must pre-clear gifts, make sure that your employees know this means all gifts, no matter how small they are. Compliance Officers know that gifts - and their value - can add up quickly. Make sure employees know this too. Most important? Be prepared to answer questions.
- Remind employees about expectations. Everyone needs a refresher now and again. Consider scheduling an email series to prompt employees to report any gifts they may have forgotten about or not yet cleared.
- Consider having your employees confirm gifts they give after the gift has been given, even if they pre-cleared them first. Things can change. Maybe they went with something different than what they originally intended. An email prompt can help to make sure your compliance records are accurate and up to date.
- Consider the best way to watch for behavior patterns. Employees give or receive gifts at other times during the year as well so it's important to monitor their behavior. Some companies will set aggregate gift limits for groups or individuals to help with this. Automation like MCO’s Gift, Entertainment and Hospitality (GEH) can be helpful in this instance.
- Automation can mitigate risks associated with gifts and entertainment. This case study, "Gifts, Entertainment and Hospitality" discusses the benefits of automating your global policy, setting rules to deliver your policy and, maintaining control through pre and post clearances activities and reporting.
- Take advantage of the resources on the MCO website. If you are a financial firm, check out this on-demand webinar co-hosted with DLA, LLC, “Best Practices to keep your firm SEC & FINRA Compliant this season.” Co-host Jennifer Lin discusses relevant topics including the SEC Guidance on Gifts and Entertainment: Section 206 of the Advisers Act, FINRA Guidance on Gifts and Entertainment: Rule 3220 and year-end compliance considerations specific to financial services firms.
Most employees want to follow your policies. Compliance officers are well-positioned to make these efforts successful by implementing a few simple changes and utilizing clear communication during this sometimes chaotic time of year.
And remember, we're here to discuss your gift, entertainment and hospitality policies. We'll be expecting you.
Happy Holidays from all of us at MyComplianceOffice.