“DON’T HAVE ANY FUN! IT’S AGAINST THE POLICY!”  This message is what many employees hear when they read the annual reminder about the gifts and hospitality policy that comes out this time of year. 

It can be a struggle to craft the proper email or video message.  After all, your desire is to help the employees not to get into trouble, but if your tone is off, or your message doesn’t do its job, you may be seen as a Grinch.  Here’s how to make sure your message hits the sweet spot (complete with handy checklist!):

Open Festively

Open your message by saying something positive about the holidays.  This will show that you are part of the fun and are in the spirit of celebration.  Try something like, “It’s that wonderful time of year when everyone is showing their gratitude for a job well done and good relationships;” or “Everyone loves a holiday luncheon and a chance to show appreciation for the good work that has been done throughout the year.”  Once you’ve shown that you understand the reason for the season, and can relate to it, only then should you begin to talk about policy.

Go Positive – what can they do?

Far too many compliance messages highlight what can’t be done.  Instead of being a downer, start with what can be done.  Let’s say you have a gift giving and receiving limit of $100.  Instead of saying, “Any gift over $100 must be immediately reported to Compliance,” you could try, “Feel free to give and receive gifts up to the $100 limit.” 

If your policy allows for employees but not their spouses / partners to attend holiday meals and outings, you can say, “We encourage your participation in business-related holiday events and meals, and remind you that partners and spouses can accompany you, but only if you are individually paying their way.” 

Start with what they can do, so they can plan around it.

Be Specific with the Details

Instead of simply saying, “Refer to the policy…,” tell them what they need to know within the body of the email.  If you have a gift limit, state it.  If the gift limit is different in different countries, state the limit in the currency of the countries in which the majority of your employees work, then embed a link to the list of the other currencies within the email.

Make sure you separate gifts and hospitality.  Many compliance officers say the phrase so often that it sounds like one word – giftsNhospitality.  Most employees don’t deal with gift giving or receiving throughout the year, so speaking separately about gifts makes sense. 

If you have a gifts and hospitality ledger, tell the employee when and how they need to fill it out, and embed a link within the email.

Be sure to tell them what to do if they’re in an awkward situation.  What’s the protocol if they receive a gift that’s over the limit and they are uncomfortable refusing?  What should they do if they’re asked to contribute more than they are comfortable with to a charity fundraiser sponsored by an important client?  Pro-actively give advice on how to handle common tricky situations.

Where do they go from here?

Be explicit about where to find help.  Tell the employees where to go.  This may include how to email you, how to report an issue via the whistle-blower hotline, where to find the policies and ledgers, and how to find the compliance-related area of the internet.  Let there be no question as to where to find help.

Close it with Cheer

Keep your tone happy and light in the closing.  Remind the employees that you’re there to help.  If appropriate, try reminding them how grateful you are for them and/or the company that you work for. 

By keeping all of these elements in mind, you’ll have a highly successful gifts and hospitality message.  Remember, even Santa keeps a checklist – so to ensure you have the best message possible, use this handy checklist to stay on the nice list (DOWNLOAD FOR PRINTING HERE):

Checklist for the Perfect Holiday Gift and Hospitality Message:

o   Spending limits for gift giving

o   Spending limits for gift receiving

o   Spending limits and acceptable locations for hosting meals and events

o   Spending limits and acceptable locations for accepting meals and events

o   When to report meals and gifts (ledgers or portal with a link)

o   When pre-approval needs to be sought for meals and events

o   When pre-approval needs to be sought for gift giving or receiving

o   Receiving a gift that is over the policy limit

o   Receiving a meal or event invitation that is over the policy limit

o   Receiving or wishing to offer gifts or hospitality to prohibited individuals, such as:

o   Email address for compliance officer

o   Whistle-blower hotline

o   Policy portal or link to policy

o   Intranet page or section devoted to policies and/or compliance