A round of thanks today to Alexandre Serpa, head of Latin America compliance for Allergan, who just published a nifty visual framework to help compliance officers review questions about gifts and entertainment issues.
Serpa posted the framework on LinkedIn and encouraged people to share, so I’m sharing. He also has a longer discussion of his framework on LinkedIn.
I especially like how Serpa structures his framework as a decision tree of yes/no questions. It’s not a flow chart per se, guiding you along to the “correct” answer—because there is no formula that gives managers the correct answer every time. Rather, the questions help anyone (employee, manager, compliance officer) sharpen his or her thinking on the most pressing issues around gifts and entertainment:
- Who is suggesting the gift or entertainment expenditure, and why?
- Who is receiving the gift or entertainment, and to what end?
- How will that transaction look to others, given the company’s business, regulatory landscape, and public reputation?
An image of Serpa’s framework is below. It also links to a larger image that Serpa has posted online, suitable to be downloaded, printed out, and stapled to break room walls everywhere.
Sharing material like this is what makes the compliance community more effective, so thank you again to Serpa. If anyone out there has comments or something else to share, drop an email to firstname.lastname@example.org any time!