Navigating the Festive Season: A Compliance Officer’s Guide to Gift and Hospitality Risks

The holiday season in the corporate world is often marked by a flurry of activities, including the exchange of gifts and extending hospitality. While these gestures are part of the festive spirit, they can also pose significant risks from a compliance perspective. As compliance officers, the challenge lies in ensuring that the season’s goodwill does not compromise the ethical standards of the organisation.

To effectively manage these risks, clear and consistent communication about the company’s policies on gifts and hospitality is essential. However, we recommend you that the communication should not be done in a dry, easily overlooked memo. Instead, it should be an engaging and ongoing campaign, underpinned by creative and practical strategies to ensure that the message is both heard and adhered to It should also emphasise the responsibility everybody has in the organisation when it comes to gifts and hospitality.

A key element is to use the communication to bring attention to the gift register. This can be done by regularly reminding employees of its existence and purpose through internal newsletters, intranet posts, or even quick reminders at the beginning of meetings. The gift register should be easily accessible and user-friendly, encouraging employees to record any gifts or hospitality received or given, as per company policy. Senior management also plays a crucial role in reinforcing the importance of compliance. When leaders visibly adhere to policies and openly discuss the importance of compliance, it sends a powerful message throughout the organisation. Having senior management address gift and hospitality policies at events or through personalised communications can significantly strengthen this top-level commitment. Their involvement demonstrates that compliance is not just a checkbox exercise but a core value of the organisation.

An innovative approach to encourage compliance is to turn the act of declaring gifts into a positive and engaging activity. For instance, employees who report gifts could be entered into a “compliance bingo” with small but meaningful rewards. Gifts received can also be put in the department bingo, breaking the chain of a potential conflict of interest by having faith determine the recipient of the gift. This not only makes the process more engaging but also helps in building a positive association with compliance practices.

Another effective method is to encourage the donation of gifts to charity. This can be particularly impactful during the holiday season, resonating with the spirit of giving and community. It also provides a practical solution to managing gifts that might otherwise pose a conflict of interest or breach company policy. It is also beneficial to host workshops or interactive sessions where employees can discuss scenarios related to gifts and hospitality. These sessions, ideally led by members of the compliance team or senior management, can help clarify grey areas and provide a platform for employees to ask questions and voice concerns.

As we approach the holiday season, it’s crucial for you to use smart strategies to reinforce the importance of ethical standards. By effectively communicating policies, engaging with staff in innovative ways, and leveraging the support of senior management, the festive season can remain a time of joy and celebration, free from compliance concerns. To make it even easier, plan your communications ahead for the year in January.

To wrap this up (pun intended) – the festive season should be a time of joy, not worry. By adopting these strategies, you can ensure that ethical standards are not just maintained but celebrated, embodying the true spirit of the holidays.