When gifts and hospitality are legitimate

The Bribery Act does not ban gifts and hospitality. Reasonable, proportionate hospitality intended to build relationships, present products, or maintain goodwill is a normal and lawful part of business. A working lunch, modest branded merchandise, or tickets to an industry event will rarely raise an eyebrow.

The question is always intention and effect: is this generosity, or is it an attempt to influence a decision improperly? Three tests help you judge.

Proportionality

Is the gift or hospitality reasonable for the relationship and the occasion? A bottle of wine at the end of a project is proportionate. A luxury weekend abroad for a procurement manager is not. The more lavish the offering, the harder it is to explain as anything other than influence.

Timing

Timing can turn an innocent gesture into something toxic. Hospitality offered while a tender is live, a contract is up for renewal, or a decision is pending looks like an attempt to sway that decision, whatever the intention. If in doubt, decline or defer anything offered around a live decision, and be equally careful about what you offer to others at such times.

Transparency

Legitimate hospitality survives daylight. If you would be comfortable with the gift appearing in the company register, being mentioned to your manager, or being reported in the press, it is probably fine. If your instinct is to keep it quiet, treat that instinct as the warning it is.

A useful habit is to reverse the picture: if a competitor learned that your customer's decision-maker had accepted this from you, would they have grounds to complain? If yes, do not offer it, and do not accept its equivalent.

Cash and cash equivalents, such as vouchers or prepaid cards, are never acceptable in either direction, regardless of value.