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 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.
The introduction 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.
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.
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’ interactive and completely customisable course, Anti-Bribery: Know Your Deal. The course drops users into immersive scenarios to test their knowledge, understanding and ability to uncover risks of bribery in their working life. You can demo the course by clicking on the button below.