This gift decision tree can help you decide whether or not to offer or accept a corporate gift. If in doubt, please contact [insert name]. Notes Note 1—Secret gifts Any gifts, given or received, must be dealt with openly, not secretly. Note 2—Gifts to individuals We regard any gift given or received in the name of an individual rather than the organisation’s name inappropriate. Note 3—Cash Any gift that is in cash, cash equivalent (eg American Express or Visa gift cards) or securities is forbidden. Note 4—Quid pro quo Gifts offered or received where there

Almost every business engages in some form of hospitality with existing or potential business partners or clients. Gifts and hospitality encompass a range of activity from providing pens marked with company logos, to charter flights to foreign countries or expansive (and expensive) meals and entertainment. While the provision of gifts and hospitality is not, of itself, a problem, it can be used as a bribe in contravention of the Bribery Act 2010 (BA 2010) so you need to ensure your organisation has procedures in place to ensure any gifts and hospitality are proper and legitimate. BA 2010 itself does not provide any direct exemptions or assistance on what is acceptable and what isn't. Knowing what you can and can't properly do can therefore be difficult. This Practice Note sets out the potential offences you can commit if you get it wrong, summarises government guidance, and covers issues of policy and procedures. Offences Any of the potential offences under BA 2010 can be committed in connection with the provision or receipt of gifts and/or hospitality,

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 form is integral to that effort. See further [insert, eg our Gifts and hospitality policy]. This form must be used in every case when a gift or hospitality is received or given [over

1 Introduction 1.1 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. 1.2 Almost every business engages in some form of corporate hospitality to existing or potential business partners or clients. 1.3 Gifts and hospitality encompass a range of activities, 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. 1.4 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. 1.5 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

Please click for the register. Please note that this register has been prepared in Excel and it therefore cannot be downloaded to Word. You should consider how gifts and hospitality details should be recorded centrally. For most organisations, it is not practical to have a process for managerial approval of every single gift made and

This hospitality decision tree can help you decide whether or not to offer corporate hospitality. If in doubt, please contact [insert name]. Notes Note 1—Government officials For government officials, local laws impose even stricter legal hospitality-giving limits—see our Gifts and hospitality—government officials policy, which you can find [insert where staff can find the policy]. Note 2—Decision making It is important that the offer of hospitality should not be capable of raising the inference that it was intended to have a direct impact on the recipient’s decision making. If

This table sets out limits to the value of permissible gifts/hospitality by country. If you need information relating to a country not listed here, please contact [insert name]. All amounts are per person, per event or per item. The following table contains details of acceptable values for gifts and hospitality given or received in countries we commonly do business with: As at [insert date] European Union EUR USA USD Australia AUD China CHY [ [Insert

1 Introduction 1.1 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. 1.2 This FAQ document, which is integral to that effort, guides us on how we can best achieve our business goals in a way that is consistent with our commitment to counter bribery and corruption. 2 What type of anti-bribery due diligence is required when making an acquisition? 2.1 The due diligence to be conducted for acquisition targets is similar to that required for agents and intermediaries. However, due diligence concerning an acquisition target requires more in-depth analysis than due diligence of an agent or intermediary often does. This is because an acquiring party can be held accountable for past breaches and other wrongdoing of a target if it has not adequately investigated the possibility of such behaviour and not included proper representations, warranties and indemnities in relevant contracts. 2.2 Conducting

Question Correct answer 1. How many new offences does the Bribery Act 2010 create? (b) Four 2. What is the ‘bribing another person’ offence? (c) Offering or giving something to someone else in return for them doing something for you improperly 3. Would you be committing an offence if you were to accept a large

How to use this test These questions are designed to test your understanding after your attendance at our training on avoiding bribery and corruption. After you have completed this test, please return it to [insert name]. General Name of person completing test [Insert name] Role [Insert role] Date [Insert date] Multiple choice questions Circle the correct answer. Question Multiple choice answers 1. How many offences does the Bribery Act 2010 contain? (a) Three(b) Four(c) Ten 2. What is the ‘bribing another person’ offence? (a) Trying to bribe an individual with the intention of influencing that individual

The Ministry of Justice (MoJ) guidance on the procedures commercial organisations should put in place to prevent bribery is crafted around six principles. The principles are not prescriptive; they are intended to be flexible and outcome-focused. Bribery prevention procedures should be proportionate to the risk of bribery faced by the organisation. It follows that the procedures put in place to implement an organisation’s bribery prevention policies should be designed to: • mitigate identified risks, and • prevent deliberate unethical conduct on the part of associated persons An important aspect of those procedures is the communication of your policies and procedures to staff (of all levels), and training in their application. This is reinforced by MoJ principle 5—Communication (including training). This Practice Note discusses some of the ways you can train staff and raise awareness about anti-bribery and corruption issues. Top-level commitment One of the key messages running through MoJ guidance on anti-bribery and corruption procedures is top-level commitment. Effective leadership in bribery prevention will take a variety of forms appropriate for

1 Bribery Laws means the Bribery Act 2010 [and associated guidance published by the Secretary of State for Justice under the Bribery Act 2010] [and all other applicable UK legislation, statutory instruments and regulations in relation to bribery or corruption] [and any similar or equivalent legislation in any other relevant jurisdiction [including [specify]] ]. 2 Each Party shall comply with applicable Bribery Laws [and all Internal Bribery Policies relating to prevention of bribery and corruption], and each shall [use all reasonable endeavours to] ensure that: 2.1 all of that Party’s personnel; 2.2 all