‘On the twelfth day of Christmas my client gave to me…’
It is common for businesses to give gifts to clients and contacts at this time of year. Whilst the giving and receiving of such gifts is not unlawful, it may become unlawful bribery if done with the intention of improperly influencing a business decision.
Although the Bribery Act came into force in 2011, many organisations still don’t have a policy on gifts and entertainment. It is sensible to do so. The policy should include a financial limit for gifts (both those given and received). It is also important to keep a record of all gifts given or received.
So, if you plan to send a case of wine or a hamper to your clients or contacts this year, make sure you keep a record. If you are planning a more lavish gift, think very carefully about the intention behind the giving of the gift. The same applies to gifts you receive.