dealing with hospitality

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.

With Christmas just around the corner, now is 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 themselves vulnerable to accusations of unlawful conduct.

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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.

Follow these tips when dealing with hospitality in your firm:

  1. Check whether the hospitality meets the 3 criteria - i.e. 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. dealing with hospitalityhave you declared it in your company's Gifts and Hospitality Register and told your manager about it)? Is there any conflict of interest or would there be a perception of one?
  2. Think about the timing and context - before giving and receiving hospitality. What other events are happening around the same time? 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.
  3. Make sure there is fairness (i.e. any hospitality is extended to everyone) - if certain groups are singled out to receive benefits but not others, this suggests impropriety. Offer any benefits universally across the board.
  4. Remember that the host should be present when giving or accepting hospitality - otherwise it is classed as a gift.
  5. Check limits - don't exceed any threshold or limit stated in company policies.
  6. Avoid offering anything of value - such as expensive theatre tickets, or tickets to exclusive events. If you have to do something, stick to something of token value.
  7. Get advice from your manager or Compliance - particularly if you have to accept hospitality to avoid offence or for reasons of cultural etiquette.
Click here to download our free Anti-Bribery Good Practice Guide

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