Does your organisation have an up-to-date gifts and corporate hospitality policy in place? Are you able to easily register any gifts you receive or give? Having an up-to-date gifts and corporate hospitality policy in place will help you comply with your responsibilities under the Bribery Act and other anti-corruption legislation.
What is a corporate gifts and hospitality policy?
A corporate gifts and hospitality policy sets out an organisation’s policy with regard to when and whether employees are allowed to accept gifts both within and outside of the work premises. In the case of a gift that an employee is allowed to receive, the policy sets parameters for the acceptable value and type of gift that is permissible to receive. The policy also defines under what circumstances an employee may receive a gift.
What should be included in a gifts and corporate hospitality policy?
The purpose of such a policy is to ensure that your organisation and its employees comply with the anti-bribery and corruption policy, bribery laws and best practice in combating corruption in all of the countries and business areas in which you operate. The policy should complement your organisation’s bribery and corruption policy. Here is some guidance on what the policy should include.
Learn more about VinciWorks’ gifts & hospitality solution here
Introduction
The introduction to the gifts and corporate hospitality policy should give a clear definition of what bribery is: an offer, promise, financial or other reward to a person with public or private responsibilities as an inducement or reward for doing something (or not, as the case may be) improperly, i.e. in bad faith or in breach of trust. Explain that one way in which bribes could be paid or received is via gifts or corporate hospitality.
Implementation
How, and to what extent will the policy be applied and who has the ultimate responsibility for ensuring that the business adheres to the policy? This section should also make clear the company’s policy on expenditure and that all expenditure must be recorded.
Suspicions of bribery
Any suspicion that an individual is offering or asking for a bribe must be reported to a designated person in the organisation. In the policy, it should be made clear what is be considered suspicious activity according to the Bribery Act 2010.
Reporting procedure
What is your company’s reporting procedure? A form should be provided for staff to complete should they have any concerns. You must also state in the policy who is responsible for processing suspicions and judging whether or not a Subject Access Request needs to be made to the National Crime Agency.
VinciWorks’ anti-bribery e-learning course
VinciWorks’ suite of anti-bribery courses brings together gamified learning, personalised content, short bursts of information and refresher training. Our course builders make delivering the most relevant content to each employee easy, while real-life scenarios make the training engaging for the user. You can demo the course by clicking on the button below.
