Question:

What consequences do you have for out-of-compliance transactions?

Consequences of Misuse: Depending on the severity of misuse, the following additional consequences may apply:(i)PCard limits will be reduced.(ii)PCard will be revoked;
)Disciplinary action against the Cardholder and/or their Delegates and Approvers may occur. Disciplinary action may include employment termination;(v)Criminal prosecution

The information is compiled into an audit control report that is published for viewing by senior management.

Card removal and disciplinary steps which vary depending on level of out of compliance

lost of card

When the transactions are not verified by the deadline, the PCard is suspended until the verification is completed.

We do not allow out of compliance transactions

card is suspended until transactions cleared

Point them back to the policy. Warning and documented in audit process.

Depending on the type of out of compliance/violation to the program policies.
Warning 1st
Retraining
30/60/90 Day Suspension
Revocation of the P-Card

n/a

1st offense – Violation Notice, copied to Approver
2nd offense – Refresher Training
3rd offense – 30-day suspension
4th offense – 90-day suspension
5th offense – account revocation

if the purchase was out-of-compliance, the employee will pay for the transaction.

1st - Warning
2nd - 30-day suspension
3rd - 60-day suspension
4 or more - permanent revocation

repay unallowable transactions such as seat upgrades etc.

Depending on severity and frequency. If first time, email notification to employee and manager on policy expectation. If repeated offenses and/or high dollar amounts of personal charges, card is closed. Activity can be escalated to HR, Internal Audit and Senior Leadership for further action including termination of both employee and manager.

If the cardholder does not adhere to the notifications within the 14 days, the cardholder and their management receive am email from the Corporate Card Administrator stating that their card will be suspended until all transactions are reconciled.

We ask for reimbursements from the employee in these cases, or if they become a consistent use of the card, we will close their card.

Reporting to BU heads

1st - Warning
2nd - 30-day suspension
3rd - 60-day suspension
4 or more - permanent revocation

Loss of card use privledges

We have a point system

None

Card could be suspended until past due report submitted - multiple infractions, possible cancellation of card

Card suspension if after a reminder and a late notice the issue is not resolved. The card will remain suspended until corrections have been made.

non-payment

infractions, supervisor meetings, HR meetings

If compliance is not met on a quarterly basis, all cards under the same company unit are suspended until compliance is met.

Warning after 30 day (1 reporting period). Card suspension (2nd reporting period) with required Corrective Action Plan to restore card.

Three strike-policy for those who don't respond.
1 - Warning with offer to retrain
2 - Warning with mandatory training
3 - Suspension of PCard (normally 30 days, but can be longer depending on infraction.)

card suspension for failure to submit reports timely up to termination for misuse of card.

First offense - written warning
Second offense - card suspension for 30 days
Third offense - permanent loss of card privileges.

suspend card

Email x 2 and then suspension of card

Audit emails are sent to cardholders and managers. After 5 non-compliance audit emails, the card is suspended.

Audit