Can a dinner with an internal colleague trigger gifts and entertainments policy concerns?
Yes. Often, organisations are structured amongst first and second lines as a means of risk management and control. If second line personnel, such as risk and compliance personnel, are perceived as being unduly influenced by first line personnel, particularly in areas where the latter stand to benefit personally, there may be a perception of impropriety attached. Conscious organisations use compliance management applications like Affinisio(GNE) for gift and entertainment management and pre-clearance.
