Anti-bribery and corruption—gifts and hospitality policy
Anti-bribery and corruption—gifts and hospitality policy

The following Practice Compliance precedent provides comprehensive and up to date legal information covering:

  • Anti-bribery and corruption—gifts and hospitality policy

From: [Insert name and job title].

We run our business[es] with integrity. All of us must work together to ensure our business[es] remain[s] untainted by bribery and corruption. This policy is integral to that effort and we are all bound by it.

    1. 1

      Introduction

      1. 1.1

        Almost every business involved in the carrying on of a [trade OR profession] provide some form of corporate hospitality to existing or potential business partners or clients.

      1. 1.2

        Gifts and hospitality encompass a range of activity, from providing pens marked with company logos, to providing charter flights to foreign countries or expansive (and expensive) meals and entertainment. We need to ensure that corporate hospitality does not tip over into bribery or corruption.

      1. 1.3

        The problem is that the Bribery Act 2010 itself does not provide any direct assistance on what is acceptable and what is not. So knowing what you can and can’t properly do can therefore be difficult.

      1. 1.4

        You should be aware that bribery and corruption is an area where perception can sometimes be more important than fact. Regardless of whether a gift or hospitality has been offered or accepted with purely innocent motives, if an external observer could put an adverse construction on that gift or hospitality, it puts the business—and the person giving or receiving the gift/hospitality—at risk.

      1. 1.5

        This policy contains controls to minimise this risk but we rely on

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