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Best Practices Employee Conflicts of Interest Gifts & Entertainment

Is Wining And Dining Back On The Firm Menu? How To Monitor Gifts And Entertainment

The future may be unwritten, but there’s enough writing on the wall to begin thinking about what firm risk might soon look like, post pandemic. Client hospitality will inevitably make a return, and Star software can help you manage the associated risk

Just writing about this possibility—putting words to screen on a notion we’ve all been burned on before—your Star blogger feels like he’s tempting fate. To wit, the idea that maybe, a year-plus into the pandemic, the world might be edging closer to something resembling normality. To life as we once knew it. Which means a return sooner than later for another aspect of life as we once knew it—firm spending on client hospitality. A look at market research data shows just how far this kind of activity has gone down, and therefore how far it has the potential to bounce back up. Looking at 2020 versus 2019, gift and entertainment activity in was down 35% year-over-year. The same kind of activity is down nearly 50% year-over-year for Q1 2021 versus 2019.

The people who have spent their professional lives wining and dining clients—sales reps, account managers, firm partners, c-suiters—are all itching to get back to this practice. It’s a time-honored and effective way to earn business and to keep it. And so long as it’s done ethically—in line with company codes of ethics that ensure internal conflicts of interest are avoided and anti-bribery regulations aren’t breached—there’s no reason to fear the return of this kind of employee activity. This, of course, presumes you have the necessary means to manage the associated influx of spends and requests. Do you have the kind of software that automates, streamlines, and centralizes the flow of critical data? The kind that makes pre-clearing and reporting spends easy to receive, monitor, and track? Here’s how Star’s Gifts & Entertainment software can help you can do all that and more.

Automated pre-clearance lies at the heart of Star’s Gifts & Entertainment product, like it does for other Star employee conflicts of interest monitoring software solutions. For gift giving and entertainment spending in particular, automated pre-clearance means that employees log in to the STAR Platform, submit their requests for any planned gift giving or entertainment spends, and receive automated approvals or denials within seconds. This frees your compliance team up from having to manually process and make decisions on every gift and entertainment request. Spend requests relating to specific individuals or companies are aggregated, to ensure that limits for each client, supplier, or employee aren’t exceeded. And you define pre-selected lists of companies and contacts for employees to choose from when making their requests.

When it comes to the automated approval or denial of gift and entertainment requests, you can be sure the STAR Platform is doing the job right because it’s fully configurable—rigorously following your firm’s precise policies when evaluating said requests. With Gifts & Entertainment, you define spending limitations by user group or job position to inform the software’s rules engine of company-defined limits. And with the STAR Platform, compliance officers are fully self-sufficient; they can manage and update the rules engine directly from their admin portal whenever a change needs to be made.

The STAR Platform is a web-based software system that centralizes all of your critical compliance data into one place for easy access by employees and compliance officers. The Star Gifts & Entertainment product operates as part of the STAR Platform. One of the major features of STAR is its capacity to easily integrate with other firm systems—such as HR, expense and order, and CRM. This means you can leverage decision-making data that already exists in systems across your business. You’ll survey high-risk employee records automatically, and in the process quickly surface transaction anomalies or patterns of behavior that may require further investigation. And since you define the rules for automated cross-referencing of existing data when any pre-clearance spend request is made, you’ll reduce the potential for any conflicts to slip between the cracks.

There comes a point for software automation, no matter how good it is—no matter how much of a lifesaver it is  when it comes to lightening the workload—when a situation needs the time and attention of a living, breathing, thinking human. And as you can depend on the STAR Platform to follow the rules you set, you can also depend on it to tell you when it’s time for a compliance officer to step in. In these times of request escalation, great compliance software will help that compliance officer review, investigate, and faithfully record the results.

Star’s Gifts & Entertainment makes this kind of case management easy. It allows compliance officers to view all possible spending breaches that may require investigation, and keeps a record of every case cycle for audit purposes. It collates data and evidence, allows for the easy addition of annotations, and can automatically assign cases to relevant compliance team members for resolution.

Good reporting allows compliance officers to see exactly what it is they want to see—to hone in on the details they’re most interested in. More than 100 reports come pre-loaded into the STAR software, and you can schedule these reports to be sent to a pre-defined list of recipients on a recurring basis, to ensure you and other business stakeholders stay up-to-date and in-the-know. You can design and build your own custom reports, and run them as frequently as you like. Useful visualizations make critical data and trends easy to interpret. In short, with Gifts & Entertainment, you get a simple and easy way to track and monitor the gifts and hospitality activity most likely to cause your firm risk. 

Wining and dining isn’t something that happens in the office. It’s something that happens out and about. Away from in-office and official remote-work setups. Away from desktop workstations and VPNs. But more than likely there’s a mobile phone nearby, in the employee’s pocket or purse, or sharing table space with the wine and hors d’oeuvres. With this mobile phone, and with the STAR Mobile app loaded onto it, the post-pandemic client-or-prospect schmoozer will be able to pre-clear gift and entertainment spends or report them immediately thereafter. And they can do it at the same level of data granularity and security as on the STAR desktop app.

When it comes to COVID the future may be unwritten, but there’s enough writing on the wall to begin initial planning and thinking about what firm risk might soon look like. Client hospitality will make a return—it’s too ingrained in firm culture not to—and so is as good a place as any to start.