Brad is on the roll of solicitors of England & Wales but does not hold a practising certificate and does not provide legal advice.
Updated June 2026 · England & Wales
Most businesses end up in situations where a supplier sends a Christmas hamper, a client offers tickets to a sporting event, or a potential partner suggests a lunch somewhere expensive. On their own, these gestures are usually harmless. Without a written policy, though, they can drift into territory that puts both the employee and the business at risk under UK anti-bribery legislation.
A gifts and hospitality policy sets out where the lines sit, how staff should behave when something is offered, and what needs to be recorded. In this guide I'll walk through why these policies matter, what to include, and the practical questions employers tend to grapple with when rolling one out across a workforce.
What this document is
A gifts and hospitality policy is an internal document that tells employees how the business expects them to handle offers of gifts, meals, entertainment, travel, and similar favours, whether they're on the giving or receiving end. It typically covers what counts as acceptable, what thresholds trigger a declaration, who needs to approve what, and where everything gets logged.
The policy sits alongside wider anti-bribery and anti-corruption procedures, and for most UK businesses it's a core part of demonstrating the 'adequate procedures' defence under section 7 of the Bribery Act 2010. Without one, a business exposes itself to criminal liability if an employee or associated person pays or accepts a bribe in connection with company activities.
The policy isn't about banning every gesture of goodwill. It's about drawing a sensible line between ordinary business courtesy and conduct that could be seen as buying influence, then giving staff the confidence to know which side of the line they're on.
How to use this document
Set a clear purpose and scope. Open the policy by explaining why the business has it and who it applies to. Typically this covers all employees, contractors, agents, and anyone acting on the company's behalf. Make clear the policy applies to gifts given as well as received, and to hospitality in both directions.
Define the key terms. Staff need to know what counts as a 'gift' and what counts as 'hospitality' before they can follow the rules. Include working definitions, examples of each, and a note that the policy covers cash equivalents such as vouchers, as well as less obvious items like charitable donations made at a client's request.
Set thresholds and approval routes. Decide what value of gift or hospitality can be accepted without approval, what requires line manager sign-off, and what is prohibited outright. Many businesses use a modest monetary threshold for routine items and require written approval above that. Keep the thresholds realistic for your sector.
Explain how to decline or report. Give staff practical wording and steps for refusing a gift politely, especially where a flat refusal might damage a client relationship. Cover what to do if something arrives unexpectedly in the post, and make clear that anything refused or returned should still be logged so there's a record.
Keep a central register and review it. The policy should require all declarable gifts and hospitality, both given and received, to be entered in a central register maintained by a named role such as the compliance lead or HR. Review the register periodically to spot patterns, for example repeated hospitality from a single supplier around contract renewal time.
Q Is a gifts and hospitality policy a legal requirement in the UK?
There's no standalone law that says every business must have one. However, under the Bribery Act 2010 a company can be held liable if someone associated with it pays a bribe, and having a clear written policy is a central part of showing you had adequate procedures in place to prevent that. In practice, most organisations of any size treat it as essential.
Q What value of gift is acceptable to receive from a client or supplier?
There's no fixed legal figure. The test is whether the gift is reasonable, proportionate, and given in good faith rather than to influence a business decision. Many UK businesses set an internal threshold of a modest amount for items that can be kept without approval, with anything above that requiring sign-off. Context matters as much as value.
Q Does the policy need to cover gifts given as well as received?
Yes. The Bribery Act covers both offering and accepting, and section 6 deals specifically with bribing foreign public officials. A policy that only addresses what employees receive leaves a significant gap. Outgoing hospitality, corporate entertaining, and promotional gifts should all fall within scope, with clear rules on when approval is needed.
Q What about gifts around Christmas or religious holidays?
Seasonal gifts are common in many sectors and most policies allow for them, provided they're modest, openly given, and not tied to a specific business decision. The risk tends to rise when gifts are unusually generous, given privately, or arrive during a live tender or contract negotiation. The policy should address this directly.
Q Who should be responsible for enforcing the policy?
Responsibility usually sits with a compliance officer, HR lead, or a named director, depending on the size of the business. That person typically maintains the register, reviews approval requests above the threshold, and handles any concerns raised. Senior leadership should visibly support the policy, as cultural tone from the top tends to drive actual compliance.
Q What happens if an employee breaches the policy?
Breaches should be handled through the normal disciplinary process, with possible outcomes ranging from a warning to dismissal depending on severity. Where conduct crosses into bribery or corruption, the business may also have reporting obligations and the individual may face personal criminal liability under the Bribery Act. The policy should spell this out so expectations are clear.
Gifts and hospitality rules sit at the awkward intersection of culture, commercial relationships, and anti-bribery law, and the right answer often depends on context. An experienced legal adviser can talk through the specifics of what you describe and help you think through how to approach it.
✓Plain-English answers to your specific questions about gifts or hospitality
✓Practical perspective on your situation from an experienced legal adviser
✓Guidance tailored to what you describe about your business or role
✓A clearer sense of what to watch out for in your circumstances
Personal call · For information only · Independent advisers
Written & reviewed by
Brad Askew Solicitor (non-practising)
Brad is on the roll of solicitors of England & Wales but does not hold a practising certificate and does not provide legal advice. LegalDocuments.co.uk is not a law firm and does not provide regulated legal advice.
This article is for general information only. It is a tool to help you find your way — not legal advice, and not a substitute for speaking to a qualified adviser about your situation.
