Gifts and Hospitality Register (Offered, Received, Declined, Approvals and Thresholds)

About the Gifts and Hospitality Register (Offered, Received, Declined, Approvals and Thresholds)

A gifts and hospitality register is one of the everyday controls of an anti-bribery policy: every gift, meal, ticket or trip offered to your staff, or offered by them, with its value, the giver or recipient, the business reason, the outcome and who approved it. The Ministry of Justice’s Bribery Act guidance says reasonable and proportionate hospitality is a normal part of business, that it can still be used as a bribe, that the more lavish it is the more it suggests an intention to influence, and that each organisation sets its own standards — including approval by senior management above set limits and clearing hospitality for public officials with their public body.

Set your thresholds — record from, approval from, decline from, and what counts as a repeat giver — and the register checks every entry against them, flags gifts from parties in a live tender, cash and public officials, and totals by giver and by member of staff. Everything stays in this browser. Without a pass the register and its checks work in full, and its pages show as images marked “not for use” with your entries readable; a Premium pass unlocks the clean pages, the PDF, Excel, CSV, printing and the text.

Setting the thresholds

The law sets no amounts: the thresholds are your organisation’s policy. The register takes a value to record from, a value above which a senior manager approves (as the Ministry of Justice’s case study suggests for expenditure over set limits), a top limit above which an offer is declined or returned, and bans on cash and cash equivalents and on anything accepted while the giver is in a tender or a contract decision with you. Leave a threshold empty to switch it off. A repeat giver is counted over the 12 months up to each entry, by the organisation’s name (company suffixes such as Ltd or Inc are ignored).

Public officials and the Bribery Act

The Bribery Act 2010 makes it an offence to offer or accept a bribe (sections 1 and 2), to bribe a foreign public official (section 6), and, for a commercial organisation, to fail to prevent bribery by a person associated with it (section 7), with a defence of adequate procedures. The guidance treats routine courtesies in line with the norms of an industry as unlikely to raise an inference of bribery, and suggests that hospitality for public officials be cleared with their public body so it is clear who and what it is for. The register flags every entry with a public official for that reason.

The reports

• The register: every entry in date order with its value, outcome, approval and flags.
• To review: entries outside the policy, needing approval, repeat givers and public officials.
• By giver or recipient and by member of staff: entries and values, to spot a pattern.
• Excel and CSV: one row per entry with every field, the approval need and the 12-month totals with the same party.

Limitations

• The register applies the thresholds you set; it does not judge whether a gift is proper.
• Values are in the register’s one currency: convert gifts in other currencies before entering them.
• Up to 500 entries a register and 10 registers in this browser; start a new register each year, and save a backup before clearing the browser’s data.
• Names are compared as typed, without company suffixes: use one spelling for each organisation.

Privacy

On this device; its files download once

Everything happens in your browser. Your registers are kept in this browser’s storage on this device and are never uploaded; a backup is a file you save yourself.

How to check that nothing is uploaded