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Holiday disclosures: Avoid conflicts of interest during gift-giving season 

Apply the fundamentals of disclosure management and mitigate risk

Kelly Maxwell
Content Marketing Specialist, OneTrust
October 18, 2022


With the season of holiday parties and corporate gifting around the corner, autumn and winter are jam-packed with potential conflicts of interest. Are your Gift, Travel, and Entertainment (GT&E) policies ready for the spotlight? Is your Conflict of Interest (COI) management program set up for success?

When festive holidays such as Diwali, Hanukkah, and Christmas include gift exchanges, feasting, and culturally significant celebrations, your disclosure management program is of paramount importance. The Securities and Exchange Commission (SEC) and the Criminal Division of the Department of Justice (DOJ) recognize that small gifts or tokens of esteem or gratitude can be appropriate means for professionals to display respect for each other – when managed appropriately. In their joint Resource Guide to the U.S. Foreign Corrupt Practices Act, they state the importance of a robust conflict of interest management program: “Clear guidelines and processes can be an effective and efficient means for controlling gift-giving, deterring improper gifts, and protecting corporate assets.”

Prepare for the next few busy months and increase your disclosure rates by fortifying and reinforcing your GT&E and COI policies in advance.

Looking to build a successful conflict of interest management program? Learn the fundamentals that will provide you with better insight into areas of risk within your company with this free eBook.

Persona-based, seasonal training

When scrutinizing your GT&E and COI policies, think like a marketer. As an ethics and compliance practitioner, you know the value of targeted awareness campaigns and training messaging. How do your C-Suite executives engage with your training? Will a shift supervisor or a line worker interact with training the same way? And do these various audiences experience holiday-related conflicts of interest differently?

Spend the time to refine the relevant personas and ensure that your messaging is accessible and easily understood by different audiences. Understand how training applies to a persona’s unique roles and responsibilities, and empower them with relevant, customized messaging and training.

Consider supplementing your annual conflicts of interest training with a short burst of seasonal training. A OneTrust Ethics and Compliance Cloud customer calls this “espresso shots of training” – a targeted message that gets straight to the point, delivered right before an employee may encounter a potential conflict of interest.

Engage employees with powerful ethics training, learning, and communications in one centralized platform. Request an Ethics Training demo today.

Refresh your GT&E policies

Your GT&E policies, when paired with powerful disclosure management technology, are the best tools for preempting illegal or unethical behavior. If your GT&E policy is left to stagnate on a dusty shelf, then its impact will stagnate as well. A timely refresh will help ensure your policies are both followed and enforced.

Don’t know what to add or where to begin a policy refresh? Start by understanding what the DOJ expects from a compliant gifts and entertainment policy. Then go on the offensive to mitigate risk, partnering with advanced analytics and automated workflows. You’ll soon be able to examine hotspots or data deserts for any areas in need of focused attention and mitigation, and establish a benchmark that you can use later for comparison. For example, take note of any policy engagement metrics that spike when you run a seasonal awareness campaign.

Save time and alleviate risk with a streamlined approach to gifts and entertainment policy administration. Request an Ethics Policy Management demo today.

Make disclosures easy for employees

To make disclosures painless, establish a compliance contact, ethics liaison, or advisory body to provide guidance and answer inquiries. Your disclosure forms should be easily accessible through an employee portal or another centralized system with independent access for employees. Electronic submission enables efficient record keeping and empowers employees to update their disclosures at any time.

Automate your disclosure management workflow to surface high-risk gifts more quickly

If you’ve already made the switch from paper- or PDF-based disclosure management to a dedicated solution, then you already know how an automated workflow can supercharge your compliance efforts. Automated workflows allow for cost-effective campaign scheduling, risk categorization, customizable workflow rules, configurable templates, dynamic management, and an accessible interface. Sniff out trouble faster by categorizing risk and utilizing custom parameters for automatic notifications.

Gather data to present to the board after the holidays to demonstrate the effectiveness of your work

Once the holidays are over, take some time to examine the results of your holiday disclosure campaign. Presenting to the board of directors is a perfect opportunity to showcase your successes or advocate for impactful improvements. Remember to find the balance between unleashing a tidal wave of metrics and telling a compelling story, highlighting your wins and warts alike. There are many assumptions and misconceptions surrounding conflicts of interest, so prepare to address them in the Q&A following your presentation.

The conflict of interest disclosure process is integral to any ethics and compliance program. Don’t let inefficient or ineffective processes open your company up to risk. Download our 14 Key Requirements to Effective Conflicts of Interest Management eBook today.


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