A "Gift" means anything given to or received from a third party from which the recipient can derive benefit; there is no minimum value.

Examples include, but are not limited to, cash, cash equivalents (such as gift cards, gift vouchers or discounts), hampers or festival treats, employment (including internship opportunities), travel, and event tickets without a host (e.g. you are given tickets to a concert without a third party host attending for corporate relationship building purposes).

You do not need to log free or low value branded items from conferences or suppliers e.g. pens, USB sticks etc.

"Hospitality" has a broad definition and is always accompanied (i.e. hosted by or provided to a third party) and is for the purpose of corporate relationship building.

Examples include, but are not limited to, meals (e.g. breakfast, lunch or dinner), events/entertainment (e.g. tickets to a sporting event, a concert or a conference), drinks, accommodation, related travel or any other similar situation.

"Public Official" means any officer (whether elected or appointed) or employee of a government department who holds a legislative, judicial or administrative position of any kind, including on a non-permanent basis; any person who performs public functions in any branch of national, local or municipal/regional government; any person who exercises a public function for any public agency or enterprise or private entity controlled by a state, such as officers working in state-owned enterprises or media; any official or agent of a public international organisation, such as the United Nations or the World Bank; civil servants and military personnel; and the term also includes close relatives (i.e. spouse, civil partner, child or stepchild under the age of 18 years, and any relative who has shared the same household for at least one year) of a Public Official.

Yes, you must log any Gifts and Hospitality that you have declined or offered to someone else and they have declined. The fact that someone has offered something can constitute a bribe even if it is rejected by the recipient and it is important that our record-keeping is robust.

It is sometimes hard to navigate what is acceptable and what is not in different cultures and countries but our Policy must always be adhered to, without exception.

If you are offered or given Gifts or Hospitality that you cannot return or where refusal would cause offence and you know or suspect it breaches this Policy, you must let Group Compliance know immediately. Group Compliance can help you navigate any areas you are unsure of as well as provide local guidance specific to the country you work in – please always ask for help if you have any queries or concerns.

Yes, in the interests of strengthening business relationships this is acceptable so long as the value is reasonable and proportionate. However, you must ensure there are no commercial or contractual negotiations taking place and also be careful not to discuss any confidential business information with the other customers.