Functional Safeguards - Sales
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- Set clear sales policies, covering discounts, sales commissions and the appointment of sales agents.
- Set out the approval authorities and procedures for decisions and exceptions.
- Separate sales duties as far as practicable, such as sales, payment collection, sales record keeping and commission calculation.
- Where appropriate, provide potential customers with clear information on prices, promotions, stock availability and credit policy.
- Prohibit staff from offering rebates or kickbacks to customers’ employees. Pay a sales commission to an agent who sources or purchases goods for a customer only after confirming that the customer permits such payment.
- Tell staff that customer data may only be used for company business. Restrict access on a need-to-know basis and maintain access controls and audit trails.
- Use computer systems to manage sales transactions, prices, discounts and sales commissions.
- Provide customers with a channel, such as a customer service hotline, to make enquiries or complaints about sales, invoices and payments.
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- Where practicable, enhance the transparency of the company’s policy, appointment criteria and conditions for distribution agents.
- Require the appointment of distribution agents to be approved by designated senior staff.
- Include an anti-bribery clause in the appointment terms. The clause should prohibit the offer, solicitation or acceptance of bribes in connection with the sale of goods.
- Set a fair policy for supplying goods, especially goods in high demand, to distribution agents.
- Review the performance of distribution agents when considering renewal of their appointments.
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- Set out the discounts or other benefits that sales staff at different levels may offer for each type of product
- For each sales promotion, set the eligibility criteria and conditions, give clear instructions to sales staff, and inform customers of the arrangements.
- Keep complete records of sales transactions, including the date, goods sold, customer details, price, discount, outlet, responsible staff member and invoice or receipt number.
- Require outdoor sales staff to keep activity logs showing the customers contacted or visited and the results.
- Control stocks of promotional items and reconcile issue records with sales records, either randomly or in full.
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- Separate the duties of receiving and recording payments, calculating receipts, making bank deposits, reconciling bank statements and keeping accounts, as far as practicable.
- Where practicable, place cash collection points, such as cashier counters, in visible areas for monitoring.
- Allow only one cashier to operate a cash register at a time. Require cash to be counted when cashier duties are handed over.
- Conduct surprise checks of cash on hand, such as cash in the cash register.
- Number sales receipts consecutively and include sufficient transaction details, such as the goods sold, price, discounts and promotional gifts. Use computer-printed receipts where practicable.
- Remind sales staff not to overstate or understate the sales amount.
- Deposit all cash and cheque receipts into the bank daily.
- Regularly reconcile accounting records, such as payments received, accounts receivable and commissions paid, with sales records and bank statements.
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- Require managers and supervisors to closely monitor sales activities and conduct spot checks on sales transactions, records and invoices.
- Assign a staff member or unit independent of the sales function to conduct random checks with customers on prices, discounts, promotions, benefits and payments.
- Prepare regular sales reports for management review, including the performance of different products, outlets and sales staff, and the sales commissions paid.
- Prepare exception reports on unusual sales transactions, such as excessive discounts, long-overdue payments and written-off accounts, and investigate any unusual patterns.