Every compliance person knows that governing bodies, management and employees are often required to make disclosures at multiple times throughout the year. While disclosures cover various topics, the common objective is to get a promise from someone that something has (or has not) happened.
Disclosures are essential for compliance officers and others to substantiate assurances that they make further up the chain. Think of each disclosure as a piece of evidentiary documentation to justify a larger representation that must be made to a higher function.
For most companies, the most common types of disclosures are:
- disclosures around conflicts of interest, when someone is asked to declare whether they have any actual or potential conflicts of interest (e.g. a family member as a vendor to the company)
- disclosures around sales, when salespeople declare that they have not breached any sales policies – these might cover promises made outside of contracts, side letters, promises of free product, special pricing on future products or issues that may lead to revenue recognition challenges (if, for example, there are deals allowing the return of unsold product)
- finance disclosures from senior executives that, to the best of their knowledge, the company has disclosed all relevant matters in its accounts and that the accounts are accurate, or disclosures about accruals or reserves and the accuracy of valuations
- insider trading disclosures from employees about any investments in companies their employer is associated with or doing business with, primarily to prevent the misuse of any information that the employee may have obtained through their role and ensure that they don’t use that information to profit from their investments
- disclosures around products, associated with things like the confidentiality of new releases or the knowledge of defects or issues experienced by clients.
The above disclosures are sought for various reasons.
The challenge with managing disclosures
Many companies try and manage disclosures using a survey tool that is old and outdated. They may even resort to paper forms or perhaps an email poll. These are not great solutions for collecting information and also not great for storing, tracking and reporting on that information. Many survey tools are also clunky when using a cell phone browser, and many don’t allow ‘passive’ surveys, where the survey might sit for a year or so before needing to be used. There are often challenges following up with respondents.
How can Speeki help?
Speeki is an app-first platform for compliance officers to manage their compliance needs. The Speeki Platform and the Speeki App enable the creation and deployment of disclosure questionnaires. They can handle everything from simple one-question requests to complex multi-question, multi-answer branching-style disclosures. Admins of the Speeki Platform can build and release as many disclosure questionnaires as they want.
Disclosures can be ‘active’ or ‘passive’. Passive disclosure requests must be done quarterly or annually, irrespective of whether respondents have an issue to disclose. Active disclosures are always available for the user to complete when they have an active issue to disclose. Both models are available through the Speeki Platform.
To make disclosures, users simply log into the free and downloadable Speeki App, click on the disclosure they need to complete and hit submit. With the marvel of modern technology, the completed report is sent to Speeki’s case management system, where the admin can review the response and take any required actions.
If you need help with building, launching or disseminating disclosure questionnaires, let us know. The Speeki Platform is a great solution for disclosure release and management and the Speeki team is ready to help.