Corporate gift-giving peaks at Christmas. It's tricky to know where bribery starts and goodwill ends. Here are some tips to help you stay legal and festive.
Key takeaways
- Gifts must have a legitimate business purpose and never appear to influence decisions.
- Keep gifts modest, proportionate, and within company value limits.
- Maintain transparency by declaring gifts in the Gifts & Hospitality register.
- Be mindful of timing and perception, especially around tenders or contracts and seek advice when unsure.
Many high-profile employers have come across as heavy-handed with their attitude to Christmas gifts. Remember the council ban on presents for hard-working bin-men a few years ago?
"Refuse collectors have been told not to accept alcohol and tips from residents over the festive period. They were asked to sign anti-bribery agreements preventing them accepting such gifts although sweets and biscuits are allowed. One resident complained the rules were mean-spirited and petty - 'Why would anyone want to bribe a binman anyway?'"
During the season of goodwill, there is no need for such draconian measures. Following our tips will help to ensure that any gifts you give or receive are on the right side of the law.
Christmas corporate gifts compliance
1. Confirm you have a legitimate business purpose
You should only give corporate gifts if there is a legitimate business purpose. Examples of legitimate gift-giving include those associated with building goodwill or enhancing relationships with customers or suppliers.
2. Ensure that your corporate gift is proportionate
Is the value of the gift reasonable, or could it be seen as lavish? Even if the value falls below that in your company policy, it may be disproportionate if you have little working contact.
3. Be entirely transparent with corporate gift-giving
It is important to inform your manager about the gift and declare it in your company's gifts and hospitality register. If you haven't, people are bound to ask, why not? You should always fully disclose the details of corporate gift-giving to avoid any suspicion of bribery.
4. Consider the timing and context
Are relevant events happening around the same time? For example, are there job vacancies, a tendering process, or contract negotiations? If so, the gift may be seen as an attempt to influence decisions unduly. Be mindful and aware of this before giving a gift.
5. Check your company's limits on the value of gifts
Don't exceed any threshold or limit stated in your company policy. Jewellery, theatre tickets or expensive wines are bound to seem extravagant, so it's best to stick to something of token or novelty value. Don't try to get around the rules by offering or accepting vouchers instead!
6. Implement annual corporate gift limits
It's wise to place an annual cap on the number of gifts that can be given to a single client or received by a particular employee each year. If that limit has been reached, maybe you should skip any festive gift-giving this year.
7. Think about the risk to your reputation
Reputational damage to a company is just as bad as financial, if not worse. Decisions around corporate gift-giving could negatively affect your reputation. If you think that such a gift may end up being perceived in a bad light, it probably isn't worth the risk.
8. Seek advice if you have any gift-giving doubts
Contact your compliance team or manager if you are unsure. For instance, you may have to accept gifts to avoid offending customers or suppliers. Such gifts could be donated to charity instead. You should also get prior approval before giving any gifts to senior executives, government officials or compliance officers.
9. Use your common sense with corporate gifting
Many gifts are perfectly reasonable and legitimate, especially around the festive season. But err on the side of caution, as authorities don't go easy on bribery suspects just because it's Christmas. If you still have doubts after seeking advice, it is best not to engage in corporate gifting.
10. Learn how to decline festive corporate gifts graciously
Use role-play to practise declining gifts and hospitality graciously. Don't agree just because you don't know what to say to avoid causing offence. It is perfectly acceptable to refuse a gift and save yourself from being accused of involvement in bribery.
Gifts and hospitality FAQs
Do gifts need to be recorded?
Yes. Most organisations require all gifts and hospitality to be declared in a register for transparency.
Can I accept hospitality such as meals or event tickets?
Often yes, if it's reasonable, related to business, and not excessive,but it still may need to be logged or approved.
What if declining a gift would offend the giver?
Explain that company policy requires you to decline or declare it. Offer an alternative (e.g., donating it to charity) if permitted.
Is giving gifts to public officials allowed?
Usually highly restricted or prohibited, due to bribery risks and stricter regulations.
More on Compliance at Christmas
Discover our broad range of e-learning content designed to help organisations meet fundamental gifts and hospitality compliance requirements. We have a Bribery Prevention training package that contains relevant training content for your compliance training programme. These online courses include:
- Anti-bribery Training Course
- Bribery Prevention Training Course
- Gifts and Hospitality Training Course
If you would like to access leading insights and compliance tips, you can browse our free resources by topic to find guides, modules, compliance bites and more.
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Emmeline is an experienced digital editor and content marketing executive. She has a demonstrated history of working in both the education management and software industries. Emmeline has a degree in business science and her skillset includes Search Engine Optimisation (SEO) and digital marketing analytics. She is passionate about education and utilising her skills to encourage greater access to e-learning.
