![]() ![]() Your findings will inform the creation of your rules, your deployment strategy and priorities you want to implement, and more generally your change management plan. This is relevant whether you already have a procedure in place or not. You can also use your corruption risk mapping to assess current practices related to gifts and hospitalities. They can give you a very solid idea of the current ongoing practices. Partner up with internal control/audit (or other relevant teams) to further enhance your understanding. This will give you a very solid idea of the key risks you face, which departments are the most exposed and help you prioritize your next steps. Assess the practices within your organization However, if you are in a non-regulated industry, and if you are looking to further structure or implement a process around gifts and hospitalities in your organization, here are a few tips. If your top management has a full zero gift policy, go for it, it is by far the simplest rule to implement and will save you a lot of time. This will make them hate the system, and you with it. And unless you work in a highly regulated industry, the worst thing that you can do is ask people to register every coffee they give away. You need a process that is manageable and properly enforced. At the end of the day, the key to your success lies in defining clear rules to cover real risks and avoid overburdening the team with administrative tasks that don’t really make sense. If you are about to define, refine, or deploy a G&H process in your organization, pragmatism should be your motto. Maybe it's also an easier topic for the compliance team, the organization, and your employees alike to tackle? It’s interesting, right? Maybe it's because the topic is easier to fathom than bribes that could be hiding behind that undetailed invoice from your distributor in some risky part of the world. I have never seen a topic so passionately discussed at all levels: compliance committees, at the coffee machine, and at an organization's board meetings. Have you ever noticed how talking about gifts and hospitalities (G&H), and potential limitations thereto, tends to get people excited? Everyone seems to have an opinion! ![]()
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