Gifts and Entertainment Review: A Quarterly Register That Adds Up by Counterparty

Declarations that look fine one at a time

Most gifts and entertainment declarations are small and routine. The review gets hard where items interact: three lunches from the same broker that pass the quarterly limit together, a gift from a counterparty that is in a live tender, an item above the limit whose pre-approval sits in a department head's mailbox. The policy is clear on each of these. Applying it across a whole quarter of declarations is where things slip.

Declarations sit in a Notion register. Pre-approvals are emails in Outlook, tender windows are on the procurement team's Google Calendar, staff send questions to the compliance inbox in Gmail, and the policy lives in Google Drive. A late value correction, or a counterparty reclassified as a public official, changes the status and the hold reason, and those changes rarely reach every place they should.

Who works in the room

The compliance team keeps one room for the register. Nova is the default agent, so a question about a declaration's status goes to it. Myco owns the counterparty totals and the audit extract, so a question about either reaches Myco without anyone naming it. When Nova changes a status, it hands the affected counterparty to Myco in the thread, so the totals and the department pages stay in step. Every agent turn that uses a tool keeps a step-by-step run history, which is what internal audit asks to see.

Inside a quarterly review

Withdrawn declarations are out of scope at every step. The room guidelines say so, and the agents leave those rows exactly as they are.

Corrections that ripple through the register

A value correction looks like one number. A dinner first declared per head is restated as a total for the table, and the new figure pushes that counterparty past the quarterly limit. Nova re-runs the declaration and proposes a new hold reason, and Myco updates the counterparty's total along with every other item that now counts toward it. Fin drafts a reply on the employee's own Gmail thread with the assessed value in dollars, and a compliance officer sends it.

A reclassification reaches further. When a counterparty is reclassified as a public official, the lower limit for that type applies to every item from it this quarter, not just the one that prompted the change. Nova lists each affected declaration with its old and new status, Myco rebuilds the totals, and nothing moves in Notion until the compliance officer approves.

What the checks catch

• Withdrawn declarations edited along with live ones because they share a counterparty
• A gift that clears on value but comes from a counterparty inside a live tender window
• Counterparty totals that pass the limit only when several small items are added together
• A value correction that changes the status but leaves the old hold reason or the old total in place
• A closeout with four department pages because one department had nothing escalated

What stays with people

• Setting the final status of every declaration in Notion
• Sending every reply to staff, which Fin prepares as a draft in Gmail or Outlook
• Reading a committee memo where the wording leaves room for doubt
• Signing the five department pages at closeout

Integrations in this workflow

Kylon is not a compliance case system and it does not replace one. It connects to the register, the mailboxes and the calendar the team already keeps, and holds the review between them.

• Gmail
• Google Calendar
• Google Drive
• Notion
• Outlook
• Slack

• Notion holds the declarations register and the department closeout pages
• Outlook holds the pre-approval emails from department heads
• Google Calendar carries the tender windows that procurement keeps current
• Gmail is the compliance inbox for staff questions, answered through drafts a person sends
• Google Drive keeps the policy, the committee memos and the audit extract
• Slack is where procurement posts tender changes and department heads answer quick questions

Where to start

Take one quarter's register. Connect Notion, give Nova a lasting grant to read the pre-approval mailbox, approved by the mailbox owner, and put one rule in the room guidelines: agents propose a status and a reason for every declaration, and a compliance officer approves before anything changes in Notion.

“The totals move whenever a value moves, so the hold reason and the number always agree.”

Set it up with your agent

Open a new Room, add your agent and paste this prompt. It connects the tools, builds the App with you and asks for your rules one step at a time, and nothing goes out until a person approves it.