A Reference Guide for Financial Services Professionals [EUROPEAN EDITION]
Whether it’s Christmastime or mid-summer, the giving of gifts to show appreciation is near universal. Within the Financial Services industry, as in many other professional sectors where gifts could be viewed as inducements, the role of compliance teams is crucial to adhere to the guidance.
This blog will serve as an easy to follow guide. We consider how your employee policies can mitigate risk, how your organisation can comply with FCA regulation and understand how a RegTech software solution can help you stay on top of this aspect of compliance.
Developing Employee policies to prevent conflict of interest & help manage compliance
Complex organisations will often expose their employees to suppliers, clients and customers in their daily operations. Whilst Human Resources teams, robust supervision and regular training can ensure that policies are created, embedded and complied with, the receipt of gifts, entertainment and other gratuities may cause confusion within disparate teams – leading to breaches and incidents: some of which could go unreported.
Whilst some organisations issue a blanket ban on receiving any sort of gift or incentive, the situation with internal conferences, training events and low value promotional items may be less clear.
Whilst the FCA and other regulatory bodies publish broad definitions regarding gifts, inducements and bribery and corruption, defining best practice within your organisation will help support your overall compliance culture.
Considerations when developing your internal policies and procedures:
- Assessing induction and CPD training materials to ensure they’re relevant, easy to interpret into every business division and are up to date.
- Creation of a ‘stop and think’ approach, with easy reference guides and a hotline to compliance teams to check before an action is taken, and how whistleblowing reports relating to this subject are flagged and handled.
- How your compliance function will oversee fundamental changes to third party supplier contracts, procurement or rewards programmes on an ongoing rather than on a piecemeal basis.
- How your disparate teams will monitor, report and demonstrate their compliance activities and how you will ensure a broad view of these activities across the organisation.
- Whether your leadership teams are able to readily interpret compliance to identify trends or take appropriate action.
How can a RegTech Solution help: 365 days a year?
Whether you’re an organisation of 20, 200 or 2000 employees, your disparate teams are unlikely to present consistent data on such a broad area of compliance.
Even if your organisation chooses a strict non-acceptance policy, as we’ve highlighted it’s relatively easy to stray into non-compliance. Instigating a software-based pre-approval process can help identify issues before they arise – giving you time to commence re-training, increase supervision or carry out other mitigating actions to help maintain compliance.
Having a consistent approach across the organisation will also ensure your leadership teams are able to identify concerns, or report on satisfactory compliance to regulators and audit functions.
Removing manual processes will remove the risks associated with maintaining spreadsheets or other logs – especially as records relating to these activities must be retained for five years.