# Corporate Gifts and Hospitality Policy
Date: 19 October 2026
Parties and reference: Cedar Analytics Ltd, 6 Foundry Yard, Birmingham B1 2PX. Policy EXAMPLE-GH-01, version 1. Owner: Compliance Manager Priya Shah. Approved by director Owen Clarke.
## 1. Scope and non-negotiable rules
Effective 19 October 2026, this policy applies to directors, employees, temporary staff and agents acting for the company, whether giving or receiving benefits. Never offer, request or accept an inducement for improper performance. Cash, cash-equivalent vouchers, facilitation payments and concealed benefits to relatives are prohibited. Genuine proportionate business hospitality may be acceptable, but intention, timing and context matter. Compliance with an internal value limit does not make a bribe lawful under the Bribery Act 2010 or another applicable law.
## 2. Internal thresholds and prior approval
Record every offered or received gift or hospitality benefit, including a declined offer. Up to £25 per person requires a legitimate purpose and line-manager notification; above £25 and up to £100 requires the manager's prior written approval; above £100 requires prior Compliance Manager approval. Aggregate benefits from the same counterparty over a rolling 12 months and do not split events to evade approval. Estimate fair market value including VAT, travel and guests. If uncertain, pause and seek advice rather than treating silence as approval.
## 3. High-risk situations and examples
No gifts or hospitality may be given to or accepted from a counterparty during a live tender or contract-award decision. Any proposed public-official hospitality requires Compliance review regardless of value and must comply with the official's own rules; payments to obtain an improper advantage are prohibited. A £15 working lunch outside a tender still needs a business purpose and register entry. Two £60 dinners from one supplier total £120 and require Compliance approval before the second dinner. A £20 voucher is prohibited even though below the ordinary gift threshold.
## 4. Register, refusal and reporting
Within five working days record the date, giver, recipient, organisation, purpose, value, approval and decision in the restricted gifts register. If refusal is culturally difficult, notify Compliance immediately and arrange return, company retention or a documented charitable disposal without personal benefit. Report pressure, concealment or suspected bribery to compliance@cedaranalytics.example.com or directly to the director if Compliance is implicated. Do not promise absolute anonymity; disclose only as necessary. Good-faith concerns must not attract retaliation, and statutory whistleblowing protections are not limited by this policy.
## 5. Oversight, records and accountability
Compliance reviews the register quarterly, trains new starters and assesses agent and overseas risks before engagement. Gift-register entries are normally retained for six years, subject to a documented lawful need, access controls and the privacy notice; investigation holds may extend retention. Suspected breaches are investigated fairly and may lead to proportionate disciplinary or contractual action, not automatic dismissal. The board reviews the policy by 19 October 2027 and after significant incidents. Approved and signed: Owen Clarke, director, 19 October 2026; staff acknowledgement confirms receipt, not waiver of rights.