Where the line sits.
WHY IT IS DIFFICULT
Gifts and hospitality are normal in business and in social life, and the boundary is contextual.
WHAT MAKES SOMETHING ACCEPTABLE
It is modest It is transparent It is not intended to influence a specific decision It would not embarrass either party if known It is not given at a decision point
WHY TIMING MATTERS
A gift during a tender is different from the same gift afterwards.
WHAT TO ESTABLISH
Limits, above which approval is required.
WHAT TO PROHIBIT
Cash and cash equivalents, always Anything to public officials, without specific approval Anything during a live procurement Anything offered in exchange for a decision
WHY CASH ABSOLUTELY
There is no innocent explanation.
WHAT TO ESTABLISH ABOUT RECEIVING
The same limits, applied to your own staff.
WHY
Your staff being influenced is the same problem in reverse.
WHAT TO RECORD
Gifts and hospitality given and received, above a threshold.
WHY A REGISTER
Transparency is what distinguishes hospitality from inducement.
WHAT TO ESTABLISH ABOUT CUSTOMARY OCCASIONS
What is appropriate at festive periods and ceremonies.
WHY IT DESERVES ADDRESSING
Refusing customary courtesy causes offence, and blanket prohibition is impractical.
WHAT TO APPLY
Modesty, transparency and consistency.
WHAT TO ESTABLISH
That anything received is declared.
WHAT TO DO ABOUT SOMETHING INAPPROPRIATE
Decline politely, explaining the policy.
WHY EXPLAIN
It attributes the refusal to the rule rather than to distrust.
WHAT TO DO IF DECLINING WOULD CAUSE SERIOUS OFFENCE
Accept, declare it, and deal with it per policy.
