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Football is a gift

Have you ever been involved in, or consulted on, the drafting of a gifts-and-entertainment-policy for your company?

If so, was it a long-winded process?  Did one person suggest 5 (Euros, Dollars, Pounds, etc) was the limit? Did another person go for 30? Did someone say ‘a pen and nothing more’? Did someone else try to twist their arm saying ‘what about calendars, they are so common’? Did someone interject with ‘but what about calendars that sell on ebay for a couple of 100’?

Your discussions might have been even deeper. Someone might have suggested that a 30 (Euro) limit means different things, whether you are in Bangkok or in Zuerich. Someone very clever might suggest linking the limit to the average salary in that country. Bingo.

Whatever your discussions, you might have left feeling you really worked hard for this, when the policy is finally implemented.  So, how would you suddenly feel, if someone at the company gets approval for a football weekend in London that pretty much everyone you know is dying to attend.  Just to be clear, flight, hotel and ticket, all sponsered by a business partner.

Would you dig that policy out again and think: Was it worth it, all the effort distinguishing between gifts costing 5 or 6 bobs?  At the very least, you might feel like a Michelin star chef who has just laid out a six course menu, only for the guest to say: can you please wrap it all into one take-away foil …  I, for once, have heard this a few times, – not the take-away instructions, but the arguments in an organisation that ‘big trips for the big dudes at the top’ are cited as the reason why people at the organisation may say they doubt the ‘comparatively small’ rules (bottle of wine, etc) they get trained in are worth the paper they are written on.

I was reminded of such discussions when I read this: Someone in the Munich town administration, which has a gift limit of 15 Euros, is said to have gotten permission to go on a Champions League Weekend in London, all courtesy of the famous Munich football club.

It reminded me how important it is in those initial discussions on the proposed policy to focus on the big events that our people may get invited to that they might feel they can’t turn down (“If we don’t attend, we lose out”). Discuss this, not just the 5 Euro pen. Test whether your own people will be in a position to say: thank you, we’ll be there, but we’ll pay ourselves. And if they can’t and there’s a feeling you have to oblige, then don’t publish the 5 Euro policy. Oh, ah, I hear you say, but we have to, so that we come across as ‘tough’ and there’s also the law to consider. Oh, well, then scrap the big invites. But we can’t. Well, then, … But, ..

As you can see, we are in the middle of a big workshop here that addresses business practices more generally and a professional appearance (… just think: what if that official travelling to London was, in other occasions, also in charge of decisions that the football club did not like so much.)  Who knows, maybe a certain level of ‘representing’ that the company needs to be doing at certain events can be agreed on (- and who pays for it- ), in which case pens and VIP lounges can live happily side-by-side.

The story strikes me as a good argument for your own organisation to do more than just outsource the drafting of a policy, but to workshop it through the habits of the different departments in your organisation. All the best with that! Let me know how it is going.

 

(Picture from fotolia. all rights reserved.)

About

Marianne Klausberger is an English lawyer specialising in Compliance topics within German-speaking regions. During her career in private practice in London she focused on dispute resolution and company investigations in, as memories of snow storm, broken air con and varying passport offices tell her, drastically different locations, and gathered experience presenting evidence to the authorities in Washington. After moving in-house, she spent almost three years leading the development of Compliance methodologies in a global chemicals and pharmaceuticals company. She continues to work with companies on such topics on a freelance basis. Approaches to designing the company’s Compliance ‘foundation’ differ widely, yet the hurdles encountered in the implementation show similar patterns. Looking at such obstacles soon becomes the focus of a project. The know-how on FCPA, UK Bribery Act, etc might be there, but it needs to be carried into the organisation; or, wants to be grasped in German, when authorities in the UK or the US may seem far away. A realistic approach remains important to her, – as her t-shirt says: “[I am] easily influenced”, and – probably – so are most of us.

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