Give the Gift of a Good Gift-Giving Policy

Mitigate risks related to gifts and entertainment with a clear gift policy and ongoing communication that reinforces key messages in an engaging way

With the gift-giving season ‘round the corner, is your team clear on your organization’s gifts and entertainment policy? Are they accepting or giving gifts that could be considered inappropriate? The lines on acceptable gifts aren’t always clear, and no matter how well-meaning or well-intentioned a gift, even the perception of impropriety or conflict of interest can be just as harmful as a batch of curdled egg nog.

To mitigate risks related to gifts and entertainment, a clear gift policy with ongoing communication that reinforces key messages in an engaging way will help employees remember the rules, use good judgement, and avoid any appearance of misconduct.

See Also: Communicating Through the Chaos: New Videos to Engage Employees on Ethics and Compliance

So before your employees dig into that gourmet gift basket of imported French cheeses or send that special client a bouquet of season tickets, here are a few things they should remember to have a merry and compliant holiday season.

Not in the (gift)cards

A good gifts and entertainment policy should provide clear direction and require employees to demonstrate the highest standards of ethics and unbiased professionalism in relation to existing and potential vendors, suppliers, and customers. Giving a prospect the impression of trying to buy their business looks worse than you do.

What’s extravagant?

Some corporations allow for non-cash gifts….as long as they fall under a certain dollar value per year. What constitutes an “extravagant” gift can sometimes be difficult to judge. Always consider the appropriateness of the gift you are about to give or receive. When in doubt, best to review the policy and ask your ethics and compliance department for guidance. As a general rule, live elephants or a life-sized wax figure of LeBron James err on the side of “too much.”

It’s about time

Timing plays an important part in assessing whether a gift breaches company policy or not. Giving or receiving a gift during an ongoing tender or before signing a contract gives the impression that a business decision was influenced by the gift. Kick back that kickback and ask your compliance department for help on next steps.

Cultural differences make no difference

Gift-giving in an international context can be complicated. While gift-giving is acceptable in some cultures, many corporations forbid giving or receiving gifts, as this gesture may be considered bribery and an illegal act in some countries. If returning a gift will offend cultural norms, check with your compliance department for the best course of action, and keep yourself out of legal trouble.