Holiday Cheer or Ethical Fear? How to Manage Corporate Gift-Giving

Corporate gift-giving can spark compliance challenges if not done ethically. Corporate policies must consider variables, such as: What kind of gift? What is its value? What are the cultural expectations around this gift? What is the context in which the gift is exchanged? Can this gift be considered a bribe? Has it been gifted to carry a weight of expectation? Or is it merely a kind acknowledgment of a professional relationship, something sent to brighten up someone’s day and thank them for their hard work? 

Some companies, for instance, have policies where even a perishable gift basket should be reported and shared among a team.

And that gifts or entertainment must not influence or appear to influence someone’s business judgment or impartiality in decision-making.  

Did you know? The Global Anti-Bribery Guidance emphasizes the risks associated with gifts, hospitality, and promotional expenses, highlighting their potential misuse for bribery and corruption. Key legal frameworks like the UK Bribery Act and FCPA strictly regulate such expenditures. Source: Transparency International UK 

Ambiguity around what to do when a gift is given or received to ensure actions remain ethical and in compliance highlights the need for clear, enforceable policies and effective tracking systems.  

Well-intended employees may unintentionally cross boundaries. This may be due to vague or inconsistently applied rules. But this puts their organizations at risk. Without structured systems to oversee these practices, organizations risk policy violations, reputational harm, and even regulatory penalties. 

What Should Companies Do to Ensure Ethical and Compliant Gift-Giving Practices? 

To ensure ethical gift-giving across global operations, companies should implement a policy that emphasizes transparency, appropriateness, and compliance with local laws. Gifts should be modest in value, culturally sensitive, and not intended to influence business decisions or create conflicts of interest.  

Employees must avoid soliciting gifts and should seek guidance when unsure about the appropriateness of giving or receiving gifts.  

Consider choosing gifts that show thoughtfulness, align with the receiving company’s policies, and align with gift-giving norms depending on where the recipient is located. 

Along the way, regular training and clear policy communication are essential to maintaining ethical standards and upholding the company’s integrity. 

How Can SAI360 Help Your Organization Implement Ethical Gift-Giving Policies?

SAI360’s Gifts & Hospitality module addresses these challenges by simplifying the process of managing gift submissions while ensuring compliance. It enables automated workflows to route disclosures for review and approval, reducing administrative burdens and ensuring consistency.  

This module also centralizes data management, storing all submissions in a secure repository and providing visibility into trends and potential risks. Through integrated training, employees gain the tools to navigate these nuanced scenarios confidently, fostering a culture of transparency and ethical compliance. 

Additionally, SAI360 has numerous training courses available to educate teams on ethical gift-giving. These microlearning modules include topics like how to address lavish gifts, when gifts to a public official may be illegal without the sender realizing, how to ethically provide and receive entertainment gifts, the rationale behind gift-giving limitations, and why lavish gifts may influence a business decision. This way, teams can understand the greater implications of the gifts they send and receive so compliance is maintained. A successful holiday season depends on it.

Let’s Start a Conversation 

From gift submission forms to being able to auto-approve gifts to establishing employee gift-giving limits, request a demo here of our Gifts & Hospitality module. And request a demo of our Ethics & Compliance training module here.