FCPAméricas Blog
Lunar New Year Gifts: It’s the Week After, Now What?
2.02.2012
Guest Blog Post – Today FCPAméricas features Farzad Barkhordari, the CEO & Founder of Click 4 Compliance, the world’s premier online compliance training company.
There have been many articles and blogs on the importance of communicating limits on gift giving, red envelopes, moon cakes, etc. Some advocate bans, some point out the importance of clearly communicated limits, procedures, logs and other means of tracking recipients, frequency, and values. These are all great ideas, and Click 4 Compliance has blogged about and trained on these exact same ideas.
But now the New Year has passed and we are all back at work. Now what? How about some verification? Did your employees follow the rules? Were the limitations actually followed? Were recipients and values documented as required? Monitoring/auditing adherence to your policies is a critical part of any compliance program, whether Anti-Corruption, or any other subject.
Do an audit, a sample audit, a country-specific audit. For example, check Gifts, Travel & Entertainment in China. This will give you a sense of what is happening across your organization, which is always a good step toward a more robust compliance program.
This blog was originally posted on www.click4compliance.com.
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© 2012 Matteson Ellis Law, PLLC
Post authored by Farzad Barkhordari, FCPAméricas Author
Comments
February 6th, 2012 at 3:15 pm
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