Implementing a GTE approval and tracking technology
Key aspects of anti-corruption policies
Many of these policies have the following key aspects:
- They set limits on the expense of gifts to government and (sometimes) commercial third parties.
- They set guidelines on what satisfies a gift, entertainment or travel benefit and give guidance on what will or will not be allowable.
- They offer an approval mechanism for special consideration of requests that fall outside of the stated dollar limits.
Some of the policies used by companies are quite restrictive and set out myriad rules that lead to approvals/non-approvals in certain circumstances. These include:
- limits on the number of gifts given by an employee per year
- limits on the value of gifts given by an employee each year to a particular customer
- limits on the value of gifts given by the company each year to a particular person within a customer
- limits on the cost and number of times entertainment is provided to a particular customer by an employee or by the broader company
- restrictions on the type and category of locations in which any entertainment can be given to a customer
- requirements that paid travel for a customer is limited in type, size, category and cost
- requirements that donations and sponsorships of industry, customer events, customer marketing, charitable foundations and donations of product undergo additional approvals and due diligence.
There is no end to the type of limits, restrictions and requirements that are possible when implementing a policy to manage gifts, travel and entertainment.
Many companies are looking for a way to implement tools and technology to manage the issues that arise from the policies described above. While technology is often a great way to simplify and manage policy management, the issues that it raises require significant thought before embarking on the implementation of such a system.
Things to think about when implementing gift, travel and entertainment technology
CATEGORY 1. Buy-in from the business
- Does the business acknowledge and understand that the tool will lead to greater scrutiny in the approval process and identify potential misuse of gifts and hospitality with ease?
- Has the business team been informed of the change to the existing process and the added requirements for approvals?
- Have the approvers been trained on how, and what, to approve?
- Is the use of the tool mandatory after the cut-off?
CATEGORY 2. Setting up the style and approach for requests
- What are the questions that should be asked when a person completes a request for a gift, for travel, or for entertainment?
- Do you want this register to also cover receiving gifts? Is it simply a recording tool, or an approval tool as well?
- What levels of expense does the register cover – all gifts and entertainment, or is the obligation to register only for certain gifts or entertainment over certain levels or to certain people?
- Should the approval for gifts be different to entertainment? Will it be routed to different people? How many levels of approval are there? Should certain requests be routed immediately to certain people at HQ/corporate? Can all requests be dealt with sequentially?
- Are there certain requests that should be automatically approved, rather than be sent for approval?
- Do you want to have some warning language around the accuracy of the submission and the certification that it is complete?
- What data should the requester upload into the system for each request? What are the unique questions that the requester should complete?
- In what language should someone fill out a request – English or local language?
- If the actual expense was greater than the approved expense, do you want the ability to go back in post-approval and match the actual expense with the pre-approved amount, and adjust the workflow (kicking off another round of approvals)?
- Do you want to set limits on each expense: per person, per recipient company, per recipient individual, per giver, per period?
- Does the policy differentiate between government and non-government recipients or donors?
- Do you want approvers to be sequential?
CATEGORY 3. Implementation and rollout
- Does the technology platform meet the expected volume?
- Does the platform need to be in multiple languages?
- How do you want the users to be managed? Do you want different levels of users that can see and do different things within the technology?
- Have you communicated the change and supported a changeover period, or thought about a pilot in certain countries?
- How will the data link to the expense claim process? Will someone on the expense-approval system upload an approval from the technology?
- How will finance conduct spot-checks of the approvals?
- How do you want to handle the situation where an approver is on leave or vacation? Can a delegate step in? How?
CATEGORY 4. Linking to CRM/ERP
- Do you currently have an expense-claim system?
- Do you intend to link the expense system to your gifts, travel and entertainment tool, whether by a hardlink or a softlink (upload of documents)?
- Is the technology going to be used by all company employees and link to a HR system or an active directory?
- Do you want single-sign-on technology, alleviating the need for people to remember multiple logins across the network?
CATEGORY 5. Monitoring and reviews
- What should the monitoring of the system be? How will you check for spikes or trends in the information submitted around the world?
- Do you want reporting issued by the tool and emailed to you on a regular basis?
- How often do you want to hold a meeting with the vendor to discuss the system and any programme enhancements?