Skip to main content

On-demand webinar coming soon...

Blog

Gifts, travel, and entertainment (GT&E) policies

Avoid the pitfalls of a manual GT&E policy and disclosure process with the right tools

Kelly Maxwell
Content Marketing Specialist, OneTrust
June 7, 2022

Green gradient graphic

In sports, sales, and business, you’ll often hear the adage, “The best defense is a good offence.” Although originally attributed to George Washington in 1899, the idea that you can best defend your turf by proactively eliminating a threat’s ability to inflict harm still resonates today. As ethics and compliance professionals, your job is to champion the culture, processes, and policies that prevent wrongdoing and harm from befalling your organization. Just as a pro chess player sees strategic moves before they happen, you can see patterns and threats before they occur.

Your Gifts, Travel, and Entertainment (GT&E) policies, paired with powerful GT&E technology, are some of the best tools for preempting unethical or illegal behavior. Don’t sit idle and allow your policies to stagnate on the shelf, going unread, unfollowed, or unenforced. Learn how to avoid the pitfalls of a manual GT&E policy and disclosure process by unpacking what happens when those policies go wrong, examine past examples of GT&E disasters, and see what happens to your compliance program when you team up with a fully-integrated platform.

Today, we’re looking at all things GT&E and disclosure management and how technology can help you maintain the upper hand.

Request a free Disclosure Management demo today.

When GT&E Goes Wrong

No matter your industry or location, GT&E policy infractions can result in major consequences. Business relationships, especially at the initial stages, often come with demonstrations of goodwill in the form of gifts, travel, or entertainment. While it can be permissible for employees to offer or accept these gestures of goodwill, companies need to ensure that these gestures don’t create conflicts of interest or the appearance of impropriety. When GT&E goes wrong, it can mean that GT&E policy training didn’t stick and the employee is unfamiliar with established disclosure management processes, or it can be because of intentional actions. Before we go into what GT&E looks like when it goes right, we must understand why and how it can go wrong.

The traditional passive GT&E process – using PDFs and manual disclosures – makes it nigh impossible to prevent conflicts of interest disasters like the ones below. The traditional GT&E process usually fails because of the following factors and shortcomings:

  • Reliance on spreadsheets of variable quality
  • Relatively manual processes
  • Little or no manager/management follow-up
  • Vertical authorization and no focus on lateral risks
  • No real-time GT&E insights fueled by relevant data
  • Inconsistent implementation and operation of both inbound (GT&E received) and outbound (GT&E given) processes
  • No broader GT&E infrastructure to support valid GT&E, such as auctioning or donating gifts received for charitable purposes

 

Examples of GT&E Disasters

In 2012, the Securities and Exchange Commission (SEC) and the Criminal Division of the Department of Justice (DOJ) jointly published a resource guide, intended to provide information for businesses and individuals regarding the Foreign Corrupt Practices Act (FCPA). The guide outlines their anti-bribery and accounting provisions, their guiding principles of enforcement, and their penalties, sanctions, and remedies. If your organization wants to avoid reputational damage, investigational exposure, and the costly fines and remediation from the FCPA, take a look at how and why these two example cases failed to properly address and manage their GT&E disclosures.

Lucent

Over the course of three years, Lucent spent more than $10 million on trips for hundreds of Chinese officials to “inspect” their American facilities. On the company dollar, officials visited locales like Hawaii, Las Vegas, the Grand Canyon, and Disney World, even though Lucent operated zero facilities in those locations. Once the company booked the related expenses as business trips, both the DOJ and SEC came knocking. They entered into a non-prosecution agreement with the DOJ and a cease-and-desist order with the SEC.

Diageo

Over the course of four years, Diageo spent approximately $64,184 on pricey gifts for the South Korean military. The spirits brand incorrectly recorded the expenses and the SEC charged them with FCPA violations. To settle their FCPA charges, they were ordered to pay more than $16 million.

Gifts, Travel, and Entertainment Disclosures Done Right

Manual GT&E policies and disclosures are difficult to enforce and maintain, making isolated issues or failures impossible to track down. When done right, your GT&E disclosure management will drive compliance, transparency, and accountability. Move beyond siloed data based on “tick-the-box” disclosure requirements, avoiding process flaws and oversight, by making the case for GT&E technology with automated workflows and advanced analytics. Imagine how aggregated data, coming from disparate sources across your organization, could supercharge your risk visibility. An advanced GT&E platform facilitates data integration, resulting in a more proactive, transparent, and manageable program.

The Benefits of GT&E Technology

Not only will the right GT&E technology integrate with your policy and training platform, ensuring that your employees have the policy information they need at the right time, it can also help drill down to the root cause of underlying issues. Any experienced E&C professional knows how unusual it is to find an isolated GT&E issue, but without the assistance of advanced analytics, you’re better off searching for a literal needle in a haystack.

When leadership calls for GT&E reporting, the right GT&E technology can generate custom reports filtered by individual, team, function, country, and company. Beyond reporting to the board, the benefits of applying advanced analytics include:

  • Observe problems and inconsistencies sooner and avoid surprises with at-a-glance analytics
  • Leverage the wealth of data at your disposal to build predictive models, moving from a reactive strategy to a proactive one
  • Enhance your reporting capabilities with richer and more structured data, collecting more insights over time
  • Conserve the resources, energy, and time of your E&C department by implementing automations, including deadlines, exemptions, and follow-up notifications
  • Request verifications and supporting documentation within a single platform
  • Define routing rules, approval workflows, and escalation procedures, enabling fully-configured processes after an employee hits “submit”

Disclosure management doesn’t need to be an uphill battle. The status quo falls short, and a passive PDF on your website is no longer enough to prevent exposure to risk. Go on the offensive and mitigate risk with a fully integrated platform, empowering your E&C department to catch issues before they spiral out of control. OneTrust’s industry-leading Disclosures Manager streamlines the GT&E disclosure management process, reducing friction for administrators and employees alike.

Request a free Disclosure Management demo today.


You may also like

Webinar

Supplier Sustainability & Responsibility

Modern slavery: Identifying exploitation and managing forced labor risks

In this webinar, OneTrust and Andrew Wallis, CEO at Unseen, will discuss the scale and impact of modern slavery on businesses' global supply chains.

March 14, 2024

Learn more

eBook

Ethics Program Management

Business messaging apps: A guide to corporate compliance

How can your business use third-party messaging apps while staying compliant? Dive into key usage considerations based on the DOJ’s 2023 guidance.

February 13, 2024

Learn more

Infographic

Third-Party Risk

4 top-of-mind challenges for CISOs in 2024

What key challenges do CISOs face going into the new year? Download this infographic to hear what experts from industries across the board have to say.

January 30, 2024

Learn more

Webinar

Third-Party Due Diligence

Best practices for conducting third-party due diligence for ethics & compliance​

Join this webinar for best practices for conducting third-party due diligence for ethics and compliance.

January 11, 2024

Learn more

Webinar

Ethics Program Management

Ethics Exchange: Third-party applications and ephemeral apps

Learn practical advice on how to navigate the risks of ephemeral apps and employee privacy in BYOD world.

December 05, 2023

Learn more

Webinar

Speak-Up Program Management

Navigating the EU Whistleblower Protection Directive: New rules, new risks

Join our expert-led webinar where we explore the EU Whistleblower Protection Directive and practical steps towards compliance. 

November 02, 2023

Learn more

Webinar

Ethics Program Management

Ethics Exchange: Risk assessments

Join our risk assessments experts as we discuss best practices, program templates, and how provide an assessment that provides the best value for your organization.

October 25, 2023

Learn more

Webinar

Ethics Program Management

Ethics Exchange: Investigations

Join our live webinar and learn how to conduct comprehensive ethics investigations that are trustworthy and efficient.

September 07, 2023

Learn more

Webinar

Third-Party Due Diligence

Driving excellence in third-party risk management: An in-depth look at different due diligence approaches

Join our in-depth webinar and learn how to define third-party due dilligence levels and when to apply them during your vendor management lifecycle.

July 20, 2023

Learn more

Webinar

Third-Party Due Diligence

A shortcut to third party due diligence fundamentals

In this webinar, we examine the scope of third-party due dilligence, best practices, and industry trends driving greater scrutiny on third parties.

July 13, 2023

Learn more

Webinar

Third-Party Due Diligence

Sanctions and export controls: Ensuring compliance

Watch our live expert webinar on understanding global sanctions and export controls and how to reduce your organiztion's risk exposure and ensure compliance.

June 29, 2023

Learn more

Video

Third-Party Risk

Third-party management demo

See how OneTrust's third-party management solution can help scale your third-party lifecycle and evaluate vendors with real-time risk intelligence.

June 27, 2023

Learn more

Webinar

Third-Party Risk

Unpacking the third-party risk regulatory landscape in the Nordic region and beyond

In this live webinar, our expert panel discuss emerging third-party risk regulatory trends in the Nordic region and show how OneTrust can help your business stay complaint.

May 30, 2023

Learn more

eBook

Third-Party Due Diligence

The global regulations driving third-party due diligence

Download our eBook learn how to start building a robust third-party due dilligence (TPDD) strategy that protects your brand and minimizes risk.

May 30, 2023

Learn more

Webinar

Third-Party Due Diligence

Ethics live Demo: Third Party Due Diligence webinar

Learn how OneTrust's Third-Party Due Dilligence, backed by Dow Jones, can help provide your business the data it needs to find trustworthy third parties and mitigate risk.

May 18, 2023

Learn more

In-Person Event

Ethics & Compliance

Ethics Exchange: Practical deep dive for third-party due diligence

Organizations are accountable for third-party actions, so they need robust due diligence to protect their reputation. Learn more at our ethics exchange event.

May 11, 2023

Learn more

Checklist

Ethics Program Management

Policy on development and administration of policies template

Get a head start on your ethics program and create a policy on development and administration of policies with our customizable template.

May 10, 2023

Learn more

Webinar

Third-Party Due Diligence

Maturing your third-party due diligence program: Process, data & technology

Experts at OneTrust and Dow Jones discuss third-party due diligence, covering industry trends, challenges, and how to streamline the process with technology.

April 27, 2023 1 min read

Learn more

Webinar

Ethics & Compliance

Unpacking the global third-party due diligence regulatory landscape

Learn how a strategic plan for compliance can help companies eliminate human rights and environmental violations and avoid costly consequences.

March 06, 2023

Learn more

Webinar

Ethics & Compliance

Third party due diligence – A practical deep dive

In this session, we'll look into the scope of third-party due diligence and a deep dive into practical implementation aspects and best practices for organizations.

December 13, 2022

Learn more

Report

Trust Intelligence

Trending toward trust

The "Trending toward trust" report from OneTrust highlights seven key trends that organizations need to know.

December 12, 2022

Learn more

Webinar

Ethics & Compliance

The number one metric for effective compliance programs: Continuous improvement

Join our webinar to learn how to develop and/or maintain a High-Quality E&C Program and what role data analytics play in improving your compliance program.

November 27, 2022

Learn more

Webinar

Ethics & Compliance

Best practices for conducting third-party due diligence for ethics & compliance

In this session, we'll explore the scope of third-party due diligence and best practices, such as industry trends driving greater scrutiny on third parties.

November 16, 2022

Learn more

Webinar

Ethics Program Management

Live demo: Conflicts of interest management webinar

Learn how to develop a holistic disclosure program, how to make it part of your risk assessment, and how to use it to meet regulatory obligations.

November 01, 2022

Learn more

Checklist

Ethics & Compliance

The CECO’s third party checklist

Use this checklist to ensure that your ethics and compliance program is effectively managing third parties across the entire relationship lifecycle.

October 28, 2022

Learn more

eBook

ESG & Sustainability

The CECO’s guide to managing third parties eBook

Download this eBook to learn the six steps in the lifecycle of risk-based third-party due diligence, compliance terms, and conditions, payment terms, etc.

October 27, 2022

Learn more

White Paper

Ethics & Compliance

Central vs. local intake and case management under the EU Whistleblowing Directive white paper

Download this white paper to learn the specific intake and case management requirements for local subsidiaries and offices across Europe.

October 25, 2022

Learn more

Webinar

Ethics & Compliance

The role of disclosures in risk assessment and management

In this webinar, we’ll discuss developing a holistic disclosure program, making it part of your risk assessment, and using it to meet regulatory obligations.

October 04, 2022

Learn more

White Paper

Ethics & Compliance

What CCOs need to know about the DOJ compliance certification requirement white paper

Download our white paper to learn how the DOJ’s new policy will empower CCOs, and discover what opportunities this new policy presents for your program.

September 01, 2022

Learn more

Webinar

Ethics & Compliance

How to transform your ethics management program through effective employee engagement

In this webinar, we’ll discuss how to develop a successful ethics management program and how to promote trust by developing awareness.

July 28, 2022

Learn more

White Paper

Ethics & Compliance

DOJ’s 2020 update to the evaluation of corporate compliance programs

This white paper explores the 2020 DOJ Compliance Guidance Update and where it takes corporate compliance programs this year and beyond.

July 15, 2022

Learn more

Checklist

Ethics & Compliance

DOJ self-assessment checklist

This enhanced DOJ guidance sets out a baseline, or the minimum standards, to demonstrate an effective ethics & compliance (E&C) program.

July 08, 2022

Learn more

Webinar

Ethics & Compliance

Conflicts of interest and disclosures

Join this roundtable with your peers and experts in ethics and compliance to discuss how to build a successful conflict of interest management program.

July 08, 2022

Learn more

Webinar

Ethics & Compliance

Effective policy governance and distribution

Join this roundtable to discuss how to create effective policies, run effective campaigns and report on each policy’s performance and influence. 

July 08, 2022

Learn more

Webinar

Ethics & Compliance

GDPR and the EU Whistleblower Protection Directive webinar

Join this webinar to learn how to review your whistleblowing processes to comply with the EU Whistleblower Protection Directive, the GDPR and others.

July 06, 2022

Learn more

Webinar

Ethics & Compliance

Hotline reporting under the EU Whistleblower Protection Directive: Unseen consequences, issues & practicalities

While there have been many articles and discussions around the EU Whistleblower Protection Directive, several significant issues have largely gone unnoticed. 

July 06, 2022

Learn more

Webinar

Ethics & Compliance

A hotline innovation masterclass: communications, awareness & confidentiality

Learn how to effectively train and raise awareness on your hotline and how to share information on the Directive so that your company remains compliant.

July 06, 2022

Learn more

Webinar

Ethics & Compliance

Evaluating hotline vendor compliance with the EU Whistleblower Protection Directive

Join us to learn how to choose a hotline vendor, and we also cover the onboarding and implementation process so that you can meet the Directive's deadline.

July 06, 2022

Learn more

Interactive Tool

Ethics & Compliance

Compliance KPIs worksheet interactive tool

Use this worksheet to understand what data you currently have, what you're lacking that may be important, and what certain data points may indicate.

July 05, 2022

Learn more

Webinar

Ethics & Compliance

Whistleblower retaliation under the EU Whistleblower Protection Directive: the reverse burden of proof

Learn how to implement anti-retaliation measures, and how to detect retaliation throughout the whistleblowing process using some new and novel techniques.

July 05, 2022

Learn more

eBook

Ethics & Compliance

14 key requirements to effective conflicts of interest management

Read this eBook to learn the key requirements that are fundamental to building a successful conflict of interest management program.

June 30, 2022

Learn more

Checklist

Ethics & Compliance

Annual compliance program checklist

Download our annual review compliance checklist to evaluate your E&C compliance program, identify key gaps, and prepare for the future.

June 30, 2022

Learn more

Webinar

Trust Intelligence

Become a trusted brand: 7 ways to promote your security, privacy, ethics and ESG programs

We discuss key points, such as choosing which certifications count the most to your business and how to save time when answering questionnaires.

June 20, 2022

Learn more

Checklist

Ethics & Compliance

Anti-retaliation checklist for compliance programs

Use these 19 questions to take a holistic look at how your program can improve training, investigations, policies, & more to prevent retaliation before it occurs.

June 17, 2022

Learn more

Checklist

Ethics & Compliance

EU Whistleblower Directive checklist

Assess your company's EU Whistleblower Directive compliance with this interactive checklist. 

June 16, 2022

Learn more

eBook

Ethics & Compliance

Ultimate guide to the EU Whistleblower Protection Directive

Download our free eBook on the EU Whistleblower Protection Directive learn its key requirements, who's protected, and answers to common questions. 

June 07, 2022

Learn more

Webinar

Privacy & Data Governance

7 ways trusted brands promote their security, privacy, ethics, and ESG programs

Watch this free webinar and learn 7 ways trusted brands promote their security, privacy, ethics, and ESG programs.

May 17, 2022

Learn more

eBook

Ethics & Compliance

The secret to effective policy management

Download this eBook and discover how a centralized policy management system helps drive compliance and ethics policy effectiveness. 

May 11, 2022

Learn more

eBook

Ethics & Compliance

How to build a speak-up culture

Download this step-by-step guide on building a speak-up culture and improve reporting rates. 

April 25, 2022

Learn more

eBook

Ethics & Compliance

Quick guide to the EU Whistleblower Directive

Use this guide to learn how the new EU Whistleblower Directive will be enforced, who is subject to it, and how to comply with it.

April 20, 2022

Learn more

Infographic

Ethics & Compliance

Infographic: The impact of an effective helpline on speak-up culture

Download this infographic and learn how an effective helpline is key to building a speak-up culture. 

April 08, 2022

Learn more

Interactive Tool

Ethics & Compliance

A simple conflict of interest disclosure form template

Download and customize this conflict of interest disclosure template to begin collecting voluntary disclosures at your organization.

April 05, 2022

Learn more

Webinar

Third-Party Due Diligence

7 best practices for conducting third-party due diligence for ethics & compliance

Watch this webinar and learn the seven best practices for third-party due diligence. 

January 03, 2022

Learn more

Webinar

Privacy & Data Governance

Data breach vs. ethics breach: How to prepare for both

In this webinar, we review case studies and tips from recent breaches and analyze which situations qualify as an "ethics breach."

July 07, 2021

Learn more

eBook

Ethics & Compliance

Creating an effective code of conduct

In this eBook, learn how to create an effective code of conduct with six key steps. 

June 01, 2002

Learn more