Registers, thresholds and approvals

Judgement is necessary but not sufficient. Organisations back it up with process, and the two workhorses are registers and approval thresholds.

The gifts and hospitality register

A register is a central record of gifts and hospitality offered, given, received, and declined. Recording an entry does three things. It creates transparency, which deters improper offers in the first place. It protects you, because a declared gift can hardly be a secret inducement. And it gives the organisation the evidence it needs to show its procedures work, which feeds directly into the adequate procedures defence.

Record entries promptly, and record refusals too. A pattern of declined offers from one supplier tells the organisation something worth knowing.

Thresholds and approvals

Most policies set value thresholds. Below a minimal value, items may not need recording at all. Between the lower and upper thresholds, items must be recorded. Above the upper threshold, items need advance approval from a manager or compliance before they are given or accepted. Check your own policy for the exact figures, and never split a gift into smaller parts to duck under a threshold; that is a transparency failure in itself.

Public officials deserve special mention. Many public bodies restrict what their staff may accept far more tightly than the private sector, sometimes to nothing at all. Before offering even modest hospitality to anyone in the public sector, check the policy and get approval.

When to decline

Decline anything that is cash or a cash equivalent, anything offered around a live decision, anything the giver wants kept quiet, and anything you would struggle to justify to your manager. Decline politely, explain that company policy does not allow it, and record the offer. Most counterparties respect a clear policy; the ones who push against it are telling you something.