Finding the unexpected: How to effectively build and manage your Gifts, Travel and Entertainment policy

March 22, 2017

Managing your Gifts, Travel and Entertainment (GTE) is no easy task.  It is one of the most common ways for compliance failures to occur, particularly in the areas of bribery and corruption. However, providing reasonable GTE to customers, vendors and suppliers is a part of any business. The government expects clear controls to be in place to prevent irresponsible, unreasonable and lavish GTE from companies to government officials or even other businesses.

Once you have created your GTE policies and procedures, it is a matter of detection, prevention, awareness and enforcement along with ongoing monitoring so improvements can be made to your programme.  A single gift to a potential customer may be appropriate and not set off any red flags, but if that gift is part of a regular batch of incentives from a rotating group of employees, your business is at risk.

Multinational companies have the extra burden of reconciling GTE standards across many regions where gift-giving customs make it hard to follow a single global policy.  There is also the logistical nightmare of keeping track of all the GTE requests to be certain that only permissible gifts are both given and received. Using technology makes these tasks much easier to accomplish. Technology allows you to evaluate, approve and document each gift that is given or received and for your team to make sound decisions.  Automating the GTE process and workflow can save companies headaches and time.

Key takeaways include:

  • How to reconcile relative limits (i.e. “reasonable or lavish”) with absolute limits (US$150)
  • How enforcement activity and government guidelines provide lessons on how to manage GTE risks
  • How to efficiently manage GTE risk against resource constraints
  • How to explore your GTE data and automatically be alerted to yellow and red flags.


Slide deck available here

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