"To Pre-, or not to Pre-" (from Summer edition, International HR Adviser)

…that is the question! Nearly 18 months on from the initial lockdown, we have realised that the pandemic continues to affect our lives in ways that few would have envisaged. There has been plenty written about the future travel landscape and the emergence of a ‘Work From Anywhere’ mindset. Attitudes towards compliance and duty of care have undoubtedly changed during the pandemic, and the activity surrounding traveller compliance and duty of care processes and technologies suggests that this is a key consideration for organisations preparing for their employees to travel again. The ‘Atlantic Charter’ has grabbed column inches, the emergence of ‘Green lists’ and comment from the recent G7 summit, all points to attempts to have us circling the globe, in some fashion, once again.

‘What’ Versus ‘How’

Companies are turning to new processes to remove the administrative burden of post COVID travel requirements. Newly formed stakeholder groups are exploring technical capabilities, integration possibilities and cultural fit with vendors to select platforms that best support their needs in facilitating travel in a safe and compliant fashion; this is the ‘What’. As an organisation providing technology, we spend a considerable period during our client conversations about the ‘How’. Inevitably with technology, the ‘How’ is typically an infinite list of possibilities bound by the imaginations or political alignment of the humans implementing, creating, and working with the solution. Here, we will split the ‘How’ into two main ways, from which they can be tweaked to further embed them within an organisation’s culture and standard travel practices:

1. The Pre-Booking Assessment

2. The Post-Booking Assessment

Each have their own merits, both fitting into organisation’s existing cultural and technological ecosystems in different ways to achieve relative compliance. Having an implemented solution ‘fit in’ or integrate with the existing ecosystem, is key to satisfy the need for efficient data sharing and to provide the strongest possible User Experience (UX) for your travelling talent pool. Note the use of ‘relative compliance’ above. At this point it is fair to say that if an organisation was to be 100% compliant in all areas of business travel, then that travel would be significantly stifled, and the compliance solution would not likely be accepted by business leaders for fear of revenues or growth opportunities being affected. For mobility professionals who are naturally aligned with tax, immigration, Posted Worker legislation and beyond, compliance is a key part of our working lives; we must be cogent to the wider aims and needs of the business. These aims typically revolve around maximising revenue generating activities. The key here is for the organisation to understand their risk appetite; the balance between the company taking advantage of these international opportunities and the possible penalties associated with compliance failure.

The Pre-Booking Compliance Assessment

The Pre-Booking model involves the individual informing the organisation about an upcoming trip or remote work event prior to them setting off. Typically, it can be done in an app-based platform, using a rules-engine to determine whether certain compliance legislation has been triggered and administration of some sort is required (Posted Worker Declarations, A1 or CoCs, Work Permits and more). It is likely linked to some sort of approval process, with a high degree of travel events automatically approved to allow prompt and effective travel, with a degree of trips pended or denied if the risk to the organisation is deemed too high. The advantage of rules-engines in this scenario is that trip details can be assessed instantly, and not only on a case-by-case basis, but tracking the cumulative effects of that person, or teams of people in a location, all of which will have a bearing on whether supporting documentation is required. The ‘Pre-Booking’ questionnaire needs to be kept as short as possible so it is not a burden on the employee tasked to complete it, and the questionnaire can capture all that is required from the individual to make an accurate compliance assessment. The questionnaire and assessment do not have to solely focus on compliance; typical integrations include security and risk management vendors. Historically, these supporting vendors have gathered data as part of a secondary process, likely calling the traveller to learn about their needs on an upcoming trip, initiated by a separate process owned by a different travel stakeholder. More on these secondary processes to come later, but we want to be capturing all of the necessary information in a single visit of the traveller to the app, portal or platform. A key piece of information here is the ‘Trip Purpose’ – what will your traveller be doing in the country of their choosing? This will impact the result of the compliance assessment and whether action is required. Upon approval, codes can be issued to prove travellers have followed agreed processes, and API integration with travel booking tools mean the traveller may be required to deliver this code upon booking their flight or claiming trip-related expenses. Organisations often have groups of travellers who need to travel at the last minute, for which exceptions can be granted with compliance processes happening in a retroactive fashion if the trip event is deemed risk-worthy.

The Post-Booking Compliance Assessment

It is likely that an organisation is using some sort of travel booking platform. In this model, the existing booking tool is the starting point for any traveller assessment. The trip is booked, and a downstream feed is taken from the booking tool to a compliance and duty of care rules-engine. The traveller has their ticket and is prepared to travel regardless of the outcome of any subsequent assessment. The compliance assessment is monitored by internal or vendor teams, without the traveller engaging directly with the technology platform. Typically, the organisation using this model is looking to perform any compliance administration in a parallel, or retro-active fashion, never prior to the trip booking. Any compliance administration is likely done on behalf of the traveller by an internal team, HR Shared Service centre or vendor ecosystem. The success of this model is dependent upon the quality of the data that emerges out of the travel booking tool. It is standard practise to capture ‘where’ and ‘when’ but rarely do these tools capture ‘Trip Purpose’. If they do capture this it will be scant detail, perhaps 3 or 4 options (meetings internal/ external, conference) which is not enough to accurately assess the necessity of a Posted Worker Declaration, or an A1/CoC and more. Both assessment models rely on a core traveller ‘profile’, often gathered from an integration with an HR Information System. Profile information can include legal and tax residency, nationality etc., which provides further background on the traveller’s personal circumstances, improving the accuracy of the compliance assessment.

Satisfying The Needs Of The Travel And Compliance Stakeholder Team

The benefits of a strong and diverse compliance and duty of care stakeholder group have been explored previously when implementing a technology solution. Colleagues are coming together, crossing corridors to share experiences across the verticals of Travel, Security, IT, Tax, Finance, Mobility and beyond. The different voices present in this group will likely lead to one of the Assessment models being preferred over another. Assuming for a moment that an organisation’s culture may afford the stakeholder team the privilege of mandating change to the travelling and remote population, and both Assessment options are a possibility, we typically see 2 major patterns: 1. Compliance-aligned roles to side with a Pre-Booking Assessment process. 2. Travel-aligned roles to side with a PostBooking Assessment model. A common stumbling block during a decisionmaking phase is the internal alignment of the stakeholders. Upon learning about the options that technology can bring, teams can encounter unforeseen delays in vendor selection processes as they decide internally which model may best suit the organisation. Speaking candidly, if an organisation has no history of pre-travel, compliance, or duty of care assessment practises, the first step for that traveller in a trip event is likely to be the travel booking tool. In this scenario, the most common option is to side with a Post-Booking Assessment due to the inferred reduction in change management processes by having the travel booking tool remain the first port of call for the traveller. If you happen to be caught in this environment, the organisation is culturally open for change and you are advocating for change, do ask your stakeholder group about the effects of the last 18 months on compliance legislation. We have seen the Posted Worker Directive transposed into law in the summer of 2020, not only for European travellers, but more commonly those inbound from the rest of the world. Authorities know that corporations, and their travellers and remote workforce, are a source of revenue to replace cash spent during the COVID crisis.

The ‘Secondary Process’

We have explored the Post-Booking Assessment and highlighted the need for the travel booking tool to capture all detail about the trip including the ‘Trip Purpose’ to make this model in a seamless fashion. Experience suggests that travel booking tools are relatively inflexible and are unlikely to capture the necessary level of detail required to complete the compliance assessment. Where this detail cannot be captured, a secondary process is required. Secondary processes are complex because they require an additional step to be taken by the traveller. We have their attention at the time of trip booking, they step away after booking and then receive notification that more information is required – namely the trip purpose. This secondary contact could come via email or phone, but in the User Experience Age we expect a level of systems integration that makes such contact redundant. If your organisation is most suited to a Post-Booking model, ask your travel booking tool to capture ‘Trip Purpose’ in detail, beyond the typical ‘internal, external, conference’ list.?

There Is A Future In Self-Service

An additional complexity is that organisations are now looking to implement a partial, or fully self-service approach to document administration. Culturally, this approach aligns well with the Pre-Booking Assessment, and places more responsibility on the traveller to ensure their administration is complete prior to travel. Total Self-Service remains a future pipe dream given the complex nature of the compliance landscape, especially the lack of standardisation around documentation and application processes. It is the hope of many that these authorities standardise in future to create more self-service possibilities, reducing the burden on stakeholder teams, and/or reducing vendor costs. Now, a partial self-service approach is possible. Documentation typically requires a mix of personal information and companyowned information. Why not capture the personal, or traveller-known details whilst we have their attention immediately after they submit their Pre-Booking Assessment questionnaire? This means that a form can be partially completed and passed on to internal specialists who can complete the businessowned information and the portal or manual application process. The compliance process is complete, and efficiencies are created, with downstream costs reduced.

The First Step In The Travel Process

Articles from the Business Travel sector show an appetite for organisations to streamline booking tools from multiple regional vendors to single global platforms in the wake of COVID as organisations strive for cleaner data on the whereabouts of their talent. This change will likely take time as organisations often utilise multiple vendors across the globe. In this search for a single provider, platforms may be offered by a ‘brand’, regional differences in technology may not result in a truly standardised global booking process. This presents difficulties for organisations wanting to implement the ‘Post-Booking Assessment’ model as multiple data feeds are required to deliver information into the chosen rules-engine. Whilst integration via API to and from multiple sources is entirely possible, the question of appetite, resource and political alignment raise their head, not to mention the need to standardise the data gathered from the traveller at the numerous global booking tool platforms. Here, the Pre-Booking Assessment can greatly simplify matters. All employees, regardless of location, start the travel process in the same, specifically designed compliance and duty of care approval platform. It is from here that approval for the trip can be granted, and the downstream trip booking completed at the various local levels. Integration of the aforementioned ‘approval codes’ can be completed either upon implementation, or later, when resource allows; it isn’t imperative to the successful running of the model. A typical objection to the Pre-Booking model is that is requires the travellers to engage with an efficient, yet new process. Business travellers are remarkably adept to change, a fact sometimes overlooked by stakeholder groups when implementing change management processes. Travellers readily accepted the liquids ban, the shoe searches and emergence of ‘self-service’ app-driven approaches to business travel. Who could have envisaged an elite business traveller tagging their own bag and lifting it onto the conveyer as they checked in?

To Conclude

It is a common event in our tech-compliance ‘world’ to have the discussion played out in this article with our prospective and customer clients. Both are valid operational models, and both are far more robust from a compliance and duty of care viewpoint than backdated travel booking reports that may only be reviewed on a quarterly, or exceptional-scenario basis, such as when the COVID-travel restrictions first darkened our doors in Q1, 2020. Ultimately, you and your colleagues in the compliance and travel stakeholder teams will know which model suits best your employees, corporate culture, and your risk appetite. When you come together to assess these models, be safe in the knowledge that by implementing one of these two solutions you will be attempting to meet the needs of the global compliance landscape, whilst ensuring free-flowing travel (to varying degrees, as you require), protecting the reputation of your organisation and offering your talent a feeling of safety and security when travelling in a post-COVID world.?