Gifts, Hospitality & Entertainment Policy

Gifts, hospitality, and entertainment are common in business relationships but can sometimes lead to compliance violations, conflicts of interest, and corruption risks. This course provides an in-depth understanding of the legal and ethical aspects of corporate gifting and hospitality, helping organizations balance business courtesies with regulatory compliance. It covers best practices for policy creation, enforcement, and monitoring to mitigate bribery risks and ensure ethical decision-making.

• To educate participants on acceptable vs. prohibited gifts and hospitality.
• To help businesses develop a compliance-friendly GHE policy.
• To ensure alignment with global anti-bribery laws (FCPA, UK Bribery Act, PCA 1988).
• To discuss corporate governance measures for ethical gifting.

• Define Gifts, Hospitality & Entertainment (GHE) Policy and its significance in business ethics.
• Explain regulatory frameworks governing corporate gifting and entertainment.
• Identify high-risk situations that may lead to bribery allegations.
• Provide best practices for implementing a compliant GHE policy.
• Offer real-world case studies on how businesses manage gifts and hospitality.

Module 1: Introduction to Gifts, Hospitality & Entertainment (GHE)

• Definition and significance of GHE in business relationships.
• Differentiating legitimate business courtesies from bribery and conflicts of interest.
• The role of corporate compliance and ethics in GHE policies.

Module 2: Risks & Red Flags in Corporate Gifting

• When can a gift be considered a bribe?
• Identifying high-risk business sectors for unethical gifting practices.
• Red flags in supplier, vendor, and government-related transactions.

Module 3: Legal Frameworks Governing GHE Policies

• Prevention of Corruption Act, 1988 (India) – Restrictions on gifting public officials.
• Foreign Corrupt Practices Act (FCPA, USA) – Guidelines on gifts and entertainment.
• UK Bribery Act, 2010 – Strict anti-bribery provisions.
• OECD Guidelines & Global Anti-Bribery Laws.

Module 4: Developing a Corporate GHE Policy

• Key components of a compliant gift & hospitality policy.
• Establishing monetary thresholds for gift acceptance.
• Transparency in gift approvals, reporting, and documentation.
• How to conduct a risk assessment for business entertainment.

Module 5: Implementation & Monitoring of GHE Policies

• Training employees on ethical gifting and hospitality.
• Internal controls and approval processes for gift acceptance.
• Third-party due diligence to ensure compliance.
• Role of whistleblower mechanisms in reporting violations.

Module 6: Case Studies & Best Practices

• Analysis of corporate scandals involving improper gifts and entertainment.
• Best practices from companies with strong compliance frameworks.
• Practical exercises on reviewing and implementing a GHE policy.

• Corporate compliance officers and ethics managers.
• Business executives and sales professionals managing client relations.
• Legal professionals and risk management consultants.
• Procurement officers and vendor management teams.
• HR and corporate governance specialists.