During the holiday season, organizations give and receive more gifts from customers and vendors.
There is no time like the present for companies to refresh employees’ memories about their company’s gifts and hospitality rules. The general message to employees should be absolutely clear: follow the rules, seek help if you aren’t sure what you can or can’t do, use good judgment and never do something that just doesn’t feel right.
With the many different laws aimed at preventing unfair business practices and the growing recognition of the importance of ethics in the conduct of all business, companies understand that there are some real risks when people who work for them provide or accept gifts and hospitality. That’s why it’s so important to remind them about the company’s expectations.
Certain verticals, such as in the health care/pharmaceutical space, have more stringent policies in place and are driving awareness across other industries. Regardless of industry, however, clear policies and communication about this topic to employees is critical.
Even though the holidays provide an opportunity to raise the topic of gift-giving and -receiving best practices, it is important to remember that this topic matters all year long. In the corporate setting, gifts occur all the time and for many occasions. For this reason, companies should regularly remind their employees about this topic and always be prepared to address any questions or concerns. Regular communication year-round is the foundation of an organization’s successful risk mitigation strategy in the area of gift giving and receiving.
When communicating with employees, you might consider including some variation of the following list of important reminders:
- The rules apply when you give gifts and provide hospitality and when you are on the receiving end. Check company policy to make sure you know what is required in each situation.
- Remember any dollar limits and any required reports or approvals, whether internal or external.
- There are some gifts and hospitality that are always prohibited – like gifts of cash, gifts where the recipient is expected to feel some sort of obligation and gifts or hospitality that are excessive or offensive.
- Make sure that all gifts and hospitality you provide are properly reported in your expense account so they will be properly recorded in the company’s books and records.
- Contact your manager or any other company ethics resource, including the company’s chief compliance officer or legal department, if you have any questions or concerns.
- Be cognizant of the company policies of our customers and vendors. Be sensitive to this when giving and accepting gifts; ask customers if they can accept a potential gift and if it fits within their policy, and be thoughtful and considerate if a customer has to decline a gift.
A clear communication plan which emphasizes to employees the basic principles of reviewing the rules, seeking guidance and using good judgment will help companies to significantly mitigate risks associated with gifts and entertainment.
