Compliance Risks at Christmas

Posted by

Matt Green

on 12 Dec 2022

While there are compliance risks all year round, some become more prominent during the festive season. Find out which and how to tackle them.

It's always nice to get your presents all in one go, right? That's why we've created this one-stop shop of all things compliance related at Christmas, with a bit of festive fun thrown in!

Bribery & Corruption

Corporate gift-giving peaks at Christmas. It's tricky knowing where goodwill ends, and bribery starts. Even a pizza voucher or a pamper gift package for a 'virtual Christmas party' could fall foul of anti-bribery rules. Take a look at your gift threshold and keep a record in the Gifts and Hospitality Register. Check out 10 tips to keep you both festive and legal and festive desk aid!

Christmas Corporate Gifts Checklist

Corporate Social Responsibility

Given the historical and religious connections to charity and virtue, Christmas is a peak time for corporate donations. In Victorian times, the concept became permanently embedded in the public consciousness through the redemption of Scrooge. If you're donating to a good cause, be sure to conduct appropriate due diligence first to check the charity is legit, you know exactly who is behind it, and how your donation will be used. If you don't then a PR coup could easily become a social media disaster.

Digital Communications

We will address information security a little further on. Here we address GDPR and marketing. It is all too tempting to take the brakes off and email the whole planet with your festive messages, and squeeze the final drops of revenue out of your database. Don't do it, just don't - rules are rules!

On a similar theme, whether it's selfies at the Christmas party or overexuberant colleagues, provide regular reminders of the rules and rein in (do you like the pun?) those grandiose claims on social media - if you don't have a code of conduct, might be time for one?

Free GDPR Personal Data Awareness Poster

Equality & Diversity

You may wonder why this is particularly relevant at Christmas. Well, Christmas is the time that many get pay reviews and bonuses. And it is also a key time for social activities. Whatever you're planning, make sure social events are inclusive - remember, not everyone wants to drink alcohol or eat meat! And, always treat everyone fairly - your rules need to be exactly the same for those who are single, married or same-sex couples! Be wary of social exclusion.

Free Equality Training for Managers

Financial Crime

It's unlikely that you'll be giving employees rare wine or diamonds nowadays. However, you must still exercise care that gifts to employees, especially if they are of a significant monetary value, do not expose your company to the risk of failing to prevent the facilitation of tax evasion.

The same goes for payments to suppliers in kind or in foreign jurisdiction. You can't claim ignorance as a defence; you need to show that you've taken reasonable steps to avoid facilitating the tax evasion. To help, we've created a five-step checklist.

Free MLRO Responsibilities Checklist


Christmas is such a high-risk period for fraud. Action Fraud reported that online shoppers lost £15.3m to fraudsters during last year's festive period. Identity fraud is at its highest level ever. Remember, scams can just as easily dupe your employees.

Here's our 12 tips for how to protect yourself from seasonal fraud.

Free Identity Fraud Training Presentation

Health & Safety

Every year retailers are urged to prioritise customer and worker safety rather than profit and avoid overstocking in the run-up to Christmas. To help, we have eight tips for Christmas fire safety. Also, there is an upsurge in deliveries at this time of year, so you need to make sure lifting and handling rules are followed. Plus an unseen risk is that of mental health crises, with all the added work and home pressures at this time of year, so remember to #bekind.

Free Workplace Stress Training Presentation

Information Security

Remote working amplifies data security risks. From using personal devices and public WiFi to things as simple as making sure you are not overheard. Concentration levels drop, corners are cut - all creating further risk. With more of us potentially shopping online this year due to the pandemic, we may be more vulnerable than ever to phishing attempts - read our top tips to protect your team. Remember, that lower staffing levels may also affect the speed with which you can deal with breaches too.

Free Cyber Security Training Presentation

Modern Slavery

Christmas is often a time for pampering and "me time" - for trips and meals out, visits to nail bars, etc. You may encounter modern slavery in your everyday life, without noticing it. From hand car washes to nail bars, salons, food services, restaurant kitchens and takeaway restaurants. Homeless people may be especially vulnerable to criminal gangs. Christmas is a difficult time to say no, and an easy time to forget. As more and more companies use ethical credentials to stand apart from their competitors, maybe it's time to learn how to  #SpotTheSigns.

Free Modern Slavery Awareness Poster

Risk Management

The current situation of keeping on top of where everyone is working is beginning to feel like the Hokey Cokey. Whilst most have developed a routine for hybrid working, old habits can creep back in after any absence. A reminder of the rules may be necessary after the Christmas break to reacquaint the team with expectations. 

Free Return to Work Compliance Checklist

Vulnerable customers & employees

Be proactive with customers, who may be experiencing heightened stress due to changing circumstances or the pandemic, putting them at risk of significant harm. Early intervention and support can limit the impact. 

It's been quite a year and we all want to enjoy some much-needed downtime. Don't add to the pressure by sending emails over the break - it can wait. Protecting your team from burnout is more important, so they are ready for new challenges in 2023.

Free Vulnerable Customers Checklist

And finally, some Christmas fun!

Did you remember that Christmas was supposed to be fun? We did, which is why we now have a new gamified learning hub. You'll find Christmas games with compliance and learning themes. If you prove your compliance credentials, you may just win a prize. All comply with our anti-bribery policy, of course - you'd expected nothing less!

Gamified Learning Brochure

More on Compliance at Christmas

We have companion articles on a number of Christmas compliance risks, including BriberyFraud and Fire Safety plus our handy Christmas Gifts Checklist.

And for some festive cheer check out our Gamified Learning Hub. There you'll find our famous Christmas Compliance Challenge plus a festive crossword and word search.

If you prove your compliance credentials, you may just win a prize. All comply with our anti-bribery policy, of course - you'd expected nothing less!

If you've any questions or concerns about compliance or e-learning, please get in touch.

We're happy to help!

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