Gifts & Entertainment

We all know that many years ago it was common practice to use gifts and entertainment to win business and keep clients happy. We also know that those days are long gone. To stay true to our values as an organization, to avoid any appearance of inappropriate behavior, and to comply with legal regulations concerning bribery and corruption, we have to be very careful about the gifts and entertainment that we both give and receive. Wrongdoing in this field can result in severe criminal sanctions and immense reputational damage. It is imperative that you are familiar with our gifts and entertainment policy and conduct yourself properly at all times.

“The company I worked for before lost a number of clients and paid out heavy fines when we were found to have influenced potential clients with cash gifts. I wasn’t involved, but when I realized that we were no longer seen as a company with a reputation for fair dealings, I moved on.”

“When we attend trade shows we offer visitors small gifts like stress balls and pens, but these are just marketing aids. We don’t give gifts to persuade possible clients; we prefer showing what we can do for them.”

“I am proud of my company’s reputation of fair and even dealings. We don’t accept anything of value, including cash, gifts, or holidays, when making business decisions. It keeps the playing field level and all decisions are made based on merit.”

“Two years ago I naively took a gift—we’d come to the end of a long project and we were celebrating—but I should have checked our policy. A gift wouldn’t affect my objectivity, but it was still a breach of compliance regulations. A colleague put me straight and I contacted the Legal department. They were really helpful and I was able to return the gift and avoid disciplinary proceedings. Learning my lesson also meant that I now always refer to our company policy before accepting a gift.”

Violet asks your advice on whether or not she should accept concert tickets offered by a potential business partner. You tell her that there are a few things to consider when deciding if a gift is appropriate.

  •  Is the intent to only build business relations, or is it to influence my objectivity?
  •  Is the gift something I need or would like to own?
  •  Am I sure that the gift is legal both in my country and in the country of the other party?
  •  Would I be embarrassed if anyone found out that I had taken the gift?
  •  Have I checked our gifts and entertainment policy?

Accepting an inappropriate gift could impact on the entire company. Don’t accept gifts that will influence your objectivity. Ask yourself if you would be embarrassed if someone found out about the gift. And always clarify whether you are entitled to receive gifts on behalf of the company before accepting even the smallest gift. You can find out who to contact to see if you can accept a gift here.

Eric has been invited to visit a facility abroad. The supplier has offered to pay for his travel and expenses. When he receives the itinerary, he notices that the hotel is a luxury resort, and it also includes two extra nights for Eric over a weekend, as well as a free round of golf at the resort.

  •  Consult the Legal department before undertaking the trip to determine if it is permissible, and to determine what expenses he can allow the supplier to pay for.
  •  Do nothing and just go on the trip. Eric didn’t ask for the extra days; they were offered as a goodwill gesture.
  • Refuse to visit the facility as it could look like the supplier is trying to influence Eric’s decision with gifts and entertainment.

The supplier is almost certainly trying to influence Eric’s decision by offering to pay for his travel and expenses, accommodating him in a luxury resort, and paying for two extra nights. Even if the supplier proves to be the best choice partner, it might seem like Eric is giving them favorable treatment as a result of this hospitality. This may tarnish Eric’s company’s reputation and may also be illegal. Although Eric may undertake the trip, he needs to discuss it with the Legal department first to see if the supplier can pay his basic travel expenses, and not the extra days.

  •  Ensure that it’s OK for you to receive gifts or hospitality on behalf of the company.
  •  Be aware that others may use gifts in an effort to influence your objectivity.
  •  Remember to ask yourself if you would be embarrassed if anyone found out about this gift.
Download our Anti Bribery and Corruption booklet.
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