The giving and receiving of gifts in the corporate world can often play an important role in helping to build business relationships.
However, organisations must be aware that there is a very fine line between a simple gift or hospitality gesture and an act of bribery.
Key takeaways
- Only give or accept corporate gifts when there is a clear, legitimate business purpose; not to influence decisions or gain favour.
- Keep gifts and hospitality modest and reasonable — avoid expensive or lavish gifts; aim for token‑value items when possible.
- Make sure there are clear, communicated rules (limits, thresholds, approval procedures) and record all gifts and hospitality in a register for transparency.
- Always consider timing, context, and potential reputational or conflict‑of‑interest risks before accepting or giving gifts and, if in doubt, seek guidance or decline.
Major holidays like Christmas and Easter are a prime time for firms to fall into the trap of accepting a gift that was given to them for dishonest and unethical means, leaving them vulnerable to accusations of unlawful conduct.
So, in order to get this right, businesses and employees need to understand when a gift is appropriate or inappropriate, and whether it was given out of honest goodwill, for something in return or to influence your decision in some way.
Top tips for managing corporate gifts and hospitality
1. Use common sense with corporate gifts
Some gifts and hospitality are perfectly reasonable and legitimate - for example, providing refreshments, a meal or overnight accommodation to interview candidates.
But it is best to avoid gifts like expensive tickets or access to exclusive events. If you have to give a gift, stick to something of token value.
2. Set and communicate clear limits
Ensure that you set a company policy with clearly defined rules and that it is communicated to all employees. Then, the thresholds and limits are clear, whether in terms of single occasions, ongoing periods of time, or relationships.
3. Think about the timing and context
Consider what other events are happening around the same time a gift is given or received. For example, are there job vacancies, a tendering process, or contract negotiations? If so, any hospitality may be seen as an attempt to unduly influence the outcome.
4. Encourage employees to use three key criteria to judge
By applying these tests, they can quickly decide what is acceptable:
- Is there a legitimate business purpose,
- is it proportionate (i.e. is it reasonable or would it be seen as unduly lavish?),
- and is it transparent (i.e. declared in your Gifts & Hospitality Register)?
Finally, are there any conflicts of interest, or would there be a perception of one?
5. Encourage transparency with corporate gifting
Making information regarding gifts and hospitality publicly available can reduce the number of submissions that are declined. This way, your company's corporate gifting is completely visible to everyone.
6. Build a formal oversight process
Ensure that gifts and hospitality are declared in a Gifts & Hospitality Register (such as the number and value of gifts, whether it was accepted or declined, who the donor and beneficiary were, etc.).
The register can be as simple as a spreadsheet for small businesses, whereas larger organisations tend to use RegTech tools.
Check your register regularly to ensure that limits and thresholds are being kept up-to-date and complied with.
7. Think about reputational risk
Even when the individual or total value of gifts is not high, there may be a perception of wrongdoing or impropriety, which can damage your company's reputation. Often, large volumes of small gifts can easily go under the radar.
8. When in doubt, seek advice before proceeding
Ask your manager, finance or compliance team if you are ever in any doubt. Particularly if you feel obliged to accept hospitality or a gift to avoid offence or for cultural etiquette reasons.
Gifts and hospitality FAQs
Can I accept gifts from family or friends if they work for a client or supplier?
Policies often focus on business relationships, but there can be grey areas when personal and professional lines blur. Clarifying rules for personal connections can prevent conflicts.
Are there rules for virtual or digital gifts?
With the rise of online vouchers, e-gift cards, or digital subscriptions, policies may need to explicitly cover these, since they can have a similar influence as physical gifts.
How do I handle gifts received accidentally or by mistake?
Procedures for returning or reporting misdelivered gifts are often overlooked. Clear guidance prevents unintentional policy breaches.
How are small promotional items (pens, mugs, branded stationery) treated?
There can be confusion between token promotional items versus gifts that could influence business decisions. Policies often need to clarify thresholds.
Want to learn more about anti-bribery compliance?
Our Essentials library contains e-learning content designed to help organisations meet fundamental compliance requirements and features courses that help your staff understand anti-bribery compliance. If you are looking for focused training, our Bribery Prevention Training Package offers a complete solution for your compliance programme. Courses in our training package include:
- Anti-bribery Training Course
- Bribery Prevention Training Course
- Gifts and Hospitality Training Course
If you’d like to access leading insights and compliance tips, you can browse our free resources by topic to find guides, modules, compliance bites and more.
Written by: Lynne Callister
Lynne is an instructional designer with over 20 years' storyboarding experience. Her current areas of interest are mobile learning and exploring how cognitive theories of learning can create better learner experiences.
