Key points of the new guide
Further Best Practice Recommendations to Manage Gifts and Invitations
AFA refers to using software tools as a good practice for managing these approval processes. Dedicated tools allow the setting e.g. monetary thresholds per country, define approval workflows depending on country, monetary value and other factors, and guarantee documentation of all benefits given, received or refused, including recipients, context and more information.
Besides creating the policy and a software-supported gift register, another very important point is training employees and managers. Even the best process or tool will not eliminate corrupt practices if employees are not properly trained and aware of potentially difficult situations. To examine whether a gift or an invitation could be problematic, AFA recommends the “newspaper test”: Would it damage the company’s reputation if the gift or invitation would be published in the press? If the answer is yes, it’s probably not a good idea.
The AFA guide should help – not only French – companies to critically examine their current practice on gifts and invitations and sets reliable guidelines and best practices. Following the guide is an important step in making sure the company’s Compliance program meets the requirements of Sapin II. And, of course, it helps to safeguard company reputations and reduce compliance risks, something which always pays off.