Gift and Hospitality Threshold Checker
Check a proposed gift or hospitality against your thresholds, the recipient cumulative limit, public official rules and tender timing, and see whether it needs approval, refusal or only a register entry.
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Value is the least important factor
Anti-bribery regimes do not turn on a number. The UK Bribery Act creates an offence where an advantage is intended to induce improper performance, and a modest gift offered a week before a contract award can meet that test while an expensive one at a long-standing annual event does not. Organisations set monetary thresholds because a rule that says "use judgement" produces no records, but the threshold is an administrative trigger for review, not a definition of what is permitted.
Cumulative value is where thresholds are defeated
A policy with a fifty pound limit and no aggregation permits fifty pounds every week to the same person, which is two and a half thousand pounds a year from one supplier to one decision-maker. Splitting a large benefit into small ones is the most common way a threshold is circumvented, usually without anybody intending to circumvent anything. Tracking the running total per recipient per year is what makes the threshold mean something.
Public officials and facilitation payments are different in kind
The Bribery Act creates a separate offence of bribing a foreign public official with no requirement to show improper performance, and the FCPA has no de minimis exception. Facilitation payments, small sums to speed a routine action to which you are already entitled, are illegal under the Bribery Act with no exception at all. A policy that treats officials on the same scale as commercial counterparties has not reflected the law it exists to implement.
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Frequently Asked Questions
Is there a legal value threshold for a gift?
No. The UK Bribery Act turns on whether an advantage was intended to induce improper performance, not on an amount. Monetary thresholds are administrative triggers for review, not definitions of what is permitted.
Why track cumulative value?
Because a fifty pound limit with no aggregation permits fifty pounds a week to the same person. Splitting a large benefit into small ones is the most common way a threshold is defeated, usually without anyone intending to.
Are facilitation payments allowed?
Not under the UK Bribery Act, which provides no exception. The FCPA has a narrow exception for routine governmental action, but relying on it is risky and most global policies prohibit them outright.
Why do public officials get different treatment?
Because bribing a foreign public official is a separate Bribery Act offence that does not require proof of improper performance, and the FCPA has no de minimis exception. The same scale as commercial counterparties does not reflect the law.
Does timing matter?
A great deal. The same hospitality is read differently during a live tender than outside one, and proximity to a decision is one of the factors that turns a courtesy into an inducement.
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How to Use
Enter the gift details to see whether it can be accepted or offered.
Disclaimer: This tool is provided "as is" without warranty of any kind. Results are for educational and utility purposes.
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