Add-on · Growth and Scale
Record every gift, meal and invitation your people give or receive, check it against your own policy, and route it to the right approver — next to the events and guests it came from.
Included in Scale. An add-on on Growth: $59 a month or $590 a year.
On Growth our team switches the add-on on for you: ask from Help → Send feedback inside Convenio, or at info@faccilis.com.
Direction, type (gift, meal, event hospitality, travel, accommodation, other), counterparty, extra beneficiaries, date, value and currency, and a business reason. Received items also record what happened to them: kept, returned, donated, shared with the team or declined.
The same contacts you invite to events, with their organisation and country.
Once submitted, an entry can't be edited or deleted. Corrections are amendments, and the history stays visible. Late declarations are marked as late.
A threshold for each direction, one for second-level approval and a separate one for public officials.
Cumulative value and number of entries over 12 months, and types of gift you don't allow.
Mark countries as high-risk or banned. Convenio doesn't supply a list.
Only people with the Compliance role can change the policy, and each entry records the version it was assessed against.
The defaults are a starting point, not legal advice.
Entries below your threshold, with no red flag, are approved automatically. Above it, a team lead of the person declaring approves first; above the second threshold, or with a red flag, someone with the Compliance role decides. Nobody approves their own entry: without another Compliance user, the entry waits.
Red flags never block an entry. The register has to hold what shouldn't have happened too.
Each counterparty carries a status — not assessed, not a public official, or one of six public categories — with the public body, its country, the source and a review date. Compliance and company admins assess it; anyone else who sees the contact can only propose it.
Set it on the event, and change it for a single guest.
Add a public official as a guest, and Convenio offers to pre-approve the hospitality there and then.
Entries for the guests who attended are created for you, proposed, or left to you — your company's choice.
With the filters on screen, who exported it and when, the policy version and both approval levels.
If the add-on stops or you change plan, Compliance and admins can still read and export the register. Nothing is deleted.
Ten years from the date of the entry by default, then the personal details are anonymised; amounts, dates, organisation and approvals remain.
A 231 organisational model needs evidence that gifts and hospitality, above all towards public officials, are controlled and visible to the supervisory body. Convenio keeps who declared, who approved and under which policy, and exports the register for any period.
The AFA expects a gifts policy, first- and second-level controls with evidence, and an assessment of third parties. Convenio records the level that approved each entry, keeps every version of the policy, and keeps a status, source and review date for each counterparty.
Adequate procedures mean proportionate rules, monitoring and periodic review, with particular care for foreign public officials. Convenio tracks value and frequency per counterparty over 12 months, flags public officials, and flags status reviews that are overdue.
Create your company on the free plan, move to Growth or Scale when you are ready, and keep your first register next to your first event.
Convenio helps you keep the evidence; it does not guarantee compliance with any law or regulation.
