Are you familiar with these problems?
There is a better way: EQS Approval Manager.
Benefits of EQS Approval Manager
Wish to take a closer look at EQS Approval Manager?
Why tracking gifts, invitations and conflicts of interest is important
- In context of FCPA, UK Bribery Act and Sapin II, regulators expect companies to implement processes to reduce the risk of corruption with regards to gift, entertainment and travel expenditures..
- Auditors, law firms and consultants recommend registers for gifts, invitations and conflicts of interest which have already established themselves as best practice in compliance-mature organizations.
- Employees need clear rules and processes regarding monetary limits and other critical factors relating to gifts, invitations and conflicts of interest in order to act in the best interests of the company.
Still have questions?
It’s easy: In their web-based customized Integrity Portal, employees can declare a new gift or invitation using quick links on the home page. They are guided through a questionnaire that can be customized according to your guidelines and needs. Your employees can send the request directly or save it as a draft for later. In the requests overview, employees can see at any time which drafts still need to be completed and sent, which requests are still in progress and which have already been accepted or rejected.
Entering a new gift or invitation is even easier and more convenient with the Integrity Portal App, which allows requests to be sent while on the road and offline. Using push notifications, employees are kept up to date on the current status of their requests.
Experience shows that employees are very uncertain as to which gifts and invitations are compatible with internal guidelines and which are not. Although companies often define country-specific thresholds and various criteria to help employees make decisions, this information is often not available at the decisive moment.
This is where our “Quick Check” offers assistance. Based on some crucial questions – such as the country of the business partner, monetary value and possible involvement of government representatives – employees receive immediate feedback as to whether the gift can be given directly or whether it requires prior approval from a direct supervisor or the compliance department. These questions are defined individually by the company. The Quick Check strengthens your employees’ decision-making confidence and promotes compliance with your gift policy.
Approval Manager can be made available to employees in any language worldwide. There are no restrictions regarding countries – you decide yourself which countries should be activated.
Approval Manager offers maximum flexibility – both with regard to request categories (gifts, invitations, conflicts of interest) and questionnaires, as well as workflows and authorization concepts. Thus, the Approval Manager can be set up in such a way that optimally maps your existing processes, avoiding costly process changes. Our experienced project managers can support you in this process.
Rules can be defined according to customer requirements to determine which workflows and approval processes should be triggered after a specific request has been submitted. These rules can be defined very granularly and based on the attributes of the requests – such as country of the employee, monetary value or participation of government representatives. You can also use these rules to control whether certain requests are to be automatically approved or rejected, or whether manual approval – single-level or multi-level – is required.
The types of requests that employees can submit via their Integrity Hub are flexible and can be set according to individual requirements. Typical request categories are gifts and invitations. But also conflicts of interest and sponsoring and donations and many more can be covered by the Approval Manager. You decide which categories you want to provide, which questionnaires should be displayed within these categories and how the authorization concepts and workflows are defined.
The Approval Manager follows a strict “need to know” principle: Only users or user groups with the appropriate permissions can access requests (gifts, invitations, conflicts of interest) and approve, reject, forward and manage them. The permissions can be set granularly. This granularity enables Approval Manager to map your internal work processes accurately. Here are a few examples:
- The Group Compliance Officer can see and manage all requests.
- The local Compliance Officer in Germany can see and manage all requests from German employees, but cannot delete or export them.
- The team leader can see and manage all requests from his team, but cannot forward, delete or export them.
The fight against corruption is high on the agenda of most regulators and supervisors worldwide. The appropriate handling of gifts and invitations is also reflected in many legal texts and guidelines – many of them with extraterritorial effect. Here are a few examples:
- In the USA, the Foreign Corrupt Practices Act (FCPA) provides for preventive measures to combat corruption. Among other things, the DoJ and SEC expect companies to establish compliance processes that minimize the risk of gifts and invitations being made in a corrupt manner. Due to the FCPA’s broad scope of application, business relationships with US companies, locations in the US, or simply transactions in US dollars may already trigger an investigation by US authorities.
- In the UK, the UK Bribery Act also requires a critical approach to gifts and entertainment. Although the Serious Fraud Office (SFO) recognizes signs of hospitality as such, it also points out that attempts at bribery are possible under this cloak of secrecy. The scope of the Bribery Act is similarly broad to that of the FCPA, as offers, promises and payments to any third party with the purpose of bribery can be pursued.
- In France, the anti-corruption law Sapin II, which came into force in early 2018, provides for a whole range of measures to combat corruption. At the end of 2019, the French anti-corruption authority AfA published a guide to help companies establish rules and processes specifically for dealing with gifts and invitations. The authority also uses these guidelines as a benchmark when investigating companies.