Gifts and Hospitality: Anti-Bribery Practice

Most exposure is ordinary — festive gifts, vendor meals, and “relationship building” without records.

Registers beat memory

If hospitality is allowed within limits, recording should be easy and expected. Policies fail when the only option is a heavy form nobody completes — or no register at all.

Practical controls

  • Clear value thresholds (and what counts toward the threshold)
  • Approval route above threshold
  • Gift / hospitality register discipline
  • Vendor communication of your policy during supplier onboarding

Manager judgement moments

  • Festive hampers to a decision-maker during a tender window
  • Repeated vendor meals that look like a pattern, not a one-off courtesy
  • “Personal gift” delivered to a home address to avoid the office register

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General workplace guidance for awareness. Not legal advice. Confirm obligations with qualified counsel and your internal policy.