Essential Requirements For Corporate Gifts & Entertainment Policies

During the holiday season, many businesses will present gifts to clients, consultants, service providers and others with whom they do business. While such a practice is customary and often expected, businesses have to be careful that such gift-giving does not trigger anti-corruption violations, such as those found in the Corruption of Foreign Officials Act ("CFPOA") in Canada or the Bribery Act in the United Kingdom (the "Bribery Act"), which prohibits bribes for improper acts virtually anywhere in the world between third parties that have some connection to the United Kingdom. It is therefore essential businesses ensure that they have a clear gifts and entertainment policy in place as part of a comprehensive and well-enforced anti-corruption compliance program.