Compliance
Every declaration is decided, not just recorded
A declaration is worth having only if somebody reads it. This area routes every gift, hospitality, donation and conflict of interest past a line manager and then past compliance, and what comes out the other end is a register with a decision and a decider against every row.
What happens to a request
- Anyone
Declares it
What was given, offered or requested, its value, the business reason, and who the counterparty is — the organisation and the individual.
- Line manager
Assesses it
The first read is by somebody who knows the relationship and the context, before it reaches anyone whose job is policy.
- Compliance
Decides
Approved onto the register, sent back for more, declined with the action taken recorded, or escalated to an investigation.
- Compliance
Investigates, where it comes to that
An investigation is its own state with its own closure, so a declaration that turned into something is not filed as an ordinary approval.
The two questions that matter, every time
Is a public official involved, and are we tendering, negotiating or renewing with them? They are asked on every declaration rather than remembered by whoever is reviewing.
Cumulative value, not one lunch
The form asks what else has come from the same counterparty in the last twelve months, because the thing a threshold misses is four meals under it.
Declining is a decision, not a deletion
A declined declaration stays on the record with the action taken against it — returned, refused, donated to charity. The awkward ones are the ones an auditor asks about.
Entirely internal
This area is private and no third party takes part. Nobody outside your organisation sees a declaration, including the counterparty it names.
It is a register you can show somebody
Every value keeps its history and every approval its approver, so the register is not a spreadsheet that reflects today — it is what was decided, by whom, and when. Copy it and change the thresholds, the declaration types and the two-stage review to whatever your policy actually says.
Start with it