1
Define scope and effective date
Enter the organization's legal name, list any entities or locations covered, name any spend categories explicitly excluded (e.g., payroll, capital leases), and set the effective date.
π‘ Review existing finance policies before finalizing scope β gaps between the purchasing policy and the expense reimbursement policy are where unauthorized spend hides.
2
Assign roles and backup approvers
Name the policy owner (typically the CFO or procurement manager), list each approver role by title, and designate a backup for each so the process does not stall when someone is out.
π‘ Use role titles, not personal names β policies should survive staff turnover without requiring a revision.
3
Set your approval thresholds
Define three to five spending tiers and assign a minimum approver level to each. Add explicit anti-splitting language prohibiting the division of a single purchase into smaller transactions to circumvent a higher tier.
π‘ Benchmark tiers against your typical transaction sizes β if 80% of purchases fall below Tier 1, the threshold is too high to provide meaningful control.
4
Establish competitive bidding thresholds
Set the dollar amount that triggers the three-quote requirement and the higher amount that requires a formal RFP. Specify how quotes must be documented and how long records must be retained.
π‘ Set the three-quote threshold at roughly 5β10% of your annual operating budget β low enough to catch meaningful spend, high enough that staff aren't gathering quotes for a $200 office supply order.
5
Draft sole-source and emergency criteria
List the specific, narrow grounds that justify bypassing competition and name the form and approver required. Exclude 'time pressure due to late planning' as a valid justification.
π‘ Require the sole-source form to be submitted before the PO is issued β not after. Retroactive justifications signal a process that exists on paper only.
6
Define vendor onboarding requirements
List the documents a new vendor must provide (W-9, proof of insurance, bank details) and the threshold above which enhanced due diligence applies. State that no PO may be issued to a vendor not on the approved list.
π‘ Build a simple approved vendor list in a shared spreadsheet or your accounting system β it reduces onboarding delays and gives auditors a clean record.
7
Set ethics and gift thresholds
Enter the maximum gift or entertainment value employees may accept from vendors, name the disclosure procedure for conflicts of interest, and identify the HR or compliance contact who receives disclosures.
π‘ A $0 threshold sounds principled but creates compliance fatigue β a $25β$50 incidental threshold is widely used and easier to enforce consistently.
8
Distribute and acknowledge
Send the finalized policy to all staff with purchasing or approval responsibilities and collect a signed acknowledgment. Store signed copies in your HR or compliance system.
π‘ Schedule a calendar reminder to review the policy annually β approval thresholds that made sense at 20 employees are often too restrictive or too permissive at 100.