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Gifts and hospitality

We always check before giving or receiving any gift or hospitality

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What it's all about

Is it a Gift? Or is it a Bribe? 

Exchanging gifts and hospitality are part of normal business, just as they are in ordinary life, and can build goodwill. But the problem is that unless we’re careful, they could look like a bribe – even if they’re not meant to be. 

Gifts and hospitality can be used to try to improperly influence others. Sometimes they are intended to make someone feel that they ‘owe’ whoever gave the gift or provided the hospitality. They can even be a form of payment given to someone as a reward if they make a business decision in your favour. 

Used like that, gifts and hospitality are a form of corruption and not acceptable. That’s why it’s so important to follow the rules.

If a gift or hospitality that you’ve given or received could be interpreted as an attempt at bribery, you can get into a great deal of trouble, and involve your colleagues and Serco in charges of corruption. 

It doesn’t matter what your intentions were – what matters is how things appear.

That’s why we have clear procedures we all need to follow, and why we must all register any gift or hospitality we offer or receive at

If in doubt, we always check it and record it.

“If it could look like a bribe, that’s how it will look to the newspapers or the police.”

What we all need to know and do

  • We have clearly defined limits on what gifts we can give or receive. As a minimum, all gifts or hospitality with a value over £100 must have management approval and must be registered. However, this limit may be less depending on your local procedures.

  • We never give or receive anything that is outside these limits unless it has the proper approval, or that could be regarded as trying to exert improper influence. 

  • Particular care needs to taken if offering things of value to government employees or public officials as regulations and local laws can be strict – always check.
  • We must follow our reporting process in these cases and register gifts and hospitality we give or receive at Don’t delay – always do it straight away.

  • You should consider sharing the gift with colleagues or donating to a charity.

  • If you return a gift, do so immediately, along with a written explanation. (See below for tips on how to say no to an inappropriate gift.)

  • There are some types of gifts that are never acceptable. Never accept or offer securities, personal cheques or payments to or for the benefit of individuals.  This also includes cash unless it’s been approved by your Divisional CEO.

  • If you are involved in procurement activities you need to be particularly careful when considering any offer of hospitality and should accept gifts unless they are an advertising or promotional item of nominal value.
  • For advice on whether a gift or hospitality is acceptable speak to your manager or divisional Ethics and Compliance Lead.

 Making the right judgement

  • Even when your intentions are innocent, it may not seem so to others. So when you give or receive any gift or any form of hospitality, take the time to check through these questions to be absolutely sure it’s okay:

    • Why is this being offered? Is it appropriate? Does it violate any laws, regulations or Serco policy?

    • Is it the local custom?

    • What's the background? Do I or the person making this offer feel obliged to make it or accept it? Is something expected in return? Might I or the intended recipient feel under undue obligation?

    • Is it really an integral and logical part of the business relationship? What could be the outcome for Serco or the person receiving it if the offer is accepted or declined? If I accept or give this, would it be easy to justify to the media or to family or friends?

    • Is there any involvement with government officials (including employees at state owned or controlled companies, and members of government sponsored institutions)? 

    • Could this be thought of as an attempt to improperly influence a business decision?

  • Take particular care if anything of value is offered when we are negotiating or considering contracts, and the recipient could influence the outcome, either directly or indirectly. 

How to say no to an inappropriate gift

It can be hard to tell someone that you can’t accept their gift or offer of hospitality. They may take offence – particularly in some cultures where gifts are sometimes seen as a mark of respect. They may try to get you to change your mind or even refuse to take the gift back. Here are some tips to help you refuse and avoid being pressurised.

Always be polite and respectful:

  • Thank the person, acknowledge their generosity, express regret - and let them know at once that you cannot accept their gift or offer.

Depersonalise - say things like:

  • “Serco’s policy is very strict …”  “Regrettably my company will not allow … “


  • Serco’s policy on gifts and hospitality is very strict and makes it impossible for you to accept.

  • Regrettably my company will not allow anyone to accept gifts / hospitality beyond a certain value at any time.

If you’re not sure if you can accept the gift:

  • Let the person know at once that Serco has strict limits on what you can accept, so you will have to check before you can accept.

Don’t be pressurised:

  • If the person takes offence or will not accept your refusal and won’t take their gift back, remain polite, but be firm. Explain that in that case you will have to tell your manager that you have been offered / received a gift that company policy will not allow you to accept, and the matter is then likely to be investigated.

  • Let your manager know straight away, and record what has taken place.

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I just forgot. That’s all. It was the week before Christmas, and I was on my way out for a meeting when it came - a case of whisky. 

I don’t even drink it – never have. So I just thought, “Someone will like that. Meantime, better put it on the gifts and hospitality register.’ But like I said, I was on my way out, so I left the case in the store-room - and completely forgot about it. 

At the time we were inviting possible suppliers to bid for some new business. I’d worked with one of them before and knew they were excellent. But we made sure the selection process was conducted properly and was absolutely fair. 

New Year came, and the supplier I knew was chosen. Everyone was happy. Then someone went looking for something in the store cupboard, and found the whisky. Only it wasn’t any old whisky. This was the real stuff, every bottle worth close on $100 – and there were twelve of them in the case – over a thousand dollars in all!

And who were they from? The supplier of course. With a message: “Happy Christmas. We look forward to continuing our relationship in the future.” 

Of course I hadn’t registered it as a gift. I explained what happened, was duly warned, felt like an idiot - and for a week or so that seemed to be that. 

Then one of the other suppliers heard about the whisky – and everything kicked off.

A couple of the tabloids got hold of the story and decided they’d do a feature. Guess what they called it? ‘Whisky Galore! What really oils the wheels of business.’

I never realised how such a small thing could cause so much damage. A couple of our clients have even stopped doing business with us, so it looks like there are going to be job losses.

And all because I just forgot to register that wretched case. 

Even when your intentions are innocent, it may not seem so to others.

We must follow our reporting process and register gifts and hospitality we give or receive at

Don’t delay – always do it straight away

Harry: Hi Kiran, I wonder if I can ask for some advice. The team met a very important and powerful customer yesterday. He’s well known for being difficult and having an explosive temper. 

Kiran: Ah, yes, I know who you mean. So how did that all go? Any casualties?

Harry: No, it went really well. We were there a long time discussing his needs and by the time we left he was clearly very pleased. He even shook my hand, smiled at me and said, ‘Thank you.’ 

Kiran: Wow! You must have made a real impression on him! 

Harry: Er, it seems like I did. 

Kiran: Oh. I think I’m about to find out why that’s a problem. 

Harry: Before I went home, I wrote a quick report, and sent the customer a short note thanking him for “his time and generosity, which we really do appreciate.” This morning, when I got to the office, there was a package waiting for me. When I opened it, there was a gold Rolex watch inside. 

Kiran: Oops.

Harry: Nothing else, no note – just the watch in its plush green box. It must be worth a small fortune!

Kiran: Double oops. 

Harry: Exactly! I’ve been staring at it for the last hour. Of course there’s absolutely no way I can accept it. 

Kiran: No. 

Harry: But without a note how can I even begin to ask, ‘Did you, by any chance, send me a Rolex?’ And as for explaining that I’m going to have to refuse – I’ve already sent him a note saying we appreciate his generosity!  I just don’t see any way of not seriously upsetting him – and this is not a relationship we can afford to mess up. What am I going to do? 

Kiran: Um … 

Exchanging gifts and hospitality are part of normal business, just as they are in ordinary life, and can build goodwill. 

But the problem is that unless we’re careful, they could look like a bribe – even if they’re not meant to be.

When I first got here, people told me that giving gifts is seen as a natural expression of hospitality and goodwill – a part of the culture.

It can be a minefield, and you have to think carefully. If you refuse a gift it’s easy to find you’ve insulted someone without intending to. And if you accept it, you may discover someone thinks you are now in their debt.  

But what no one told me about is what to do if someone important is actually expecting something from you. 

I’ve been in post here for nearly nine months, and thought I’d pretty much got used to things. Then this morning an appointment comes up on the calendar to meet a high up official about the annual renewal of a government contract we’d been servicing for the last eight years.  

I got the team to give me a quick update on how things were going, and then asked for a little bit of information on the official. Suddenly people weren’t looking at me anymore.

‘What is it?’ I asked. 

 More glances, and then Sara told me. ‘It’s a bit awkward,’ she said. ‘Without meaning to, we’ve got ourselves into a bit of a situation with this particular individual.’ 

‘What sort of “situation”?’  

‘Er … Well, when we first got the contract, your predecessor gave him a rather um … conspicuous gift.’

‘Okay - so how conspicuous?’

‘A new golf course had just opened out of town, and they agreed to play a game together. So your predecessor thought it would be nice to give him a …‘ She turned to her colleague, ‘What was it?’

‘A Titleist putter,’ her colleague said. 

 ‘A what?’ I asked.

‘It’s a golf club. The one you use to get the ball into the hole on the green. Titleist is one of the very best makes. And it was supposed to be engraved with the customer’s name. Except it seems there was mistake.’

‘What kind of mistake?’

‘It didn’t end up being just the one putter. It ended up being an entire set of clubs. Each one engraved.’ 

‘How much were they?’



By the time we found out what had happened, it was too late - the set had already been delivered. And of course the official was absolutely delighted.’

‘I bet he was.’

‘During their game of golf, the official kept on thanking him for such an impressive gift. As they were parting at the end of the game, he said, ‘Well, I look forward to your gift next time!” And that has produced something of a … tradition.’

‘A tradition?’

‘Yes. Every time we see this particular customer, he expects us to surprise him. We try and keep the gift modest, but it is hard when you have set high expectations. And we just don’t know how to make it stop.’ 

I can see how some people may see this as pretty comical – but for us it’s really serious. Clearly no one meant to get us into this situation, but if it were ever to get out what’s been going on, it could do us so much damage. Not just in this country – but to our reputation in other markets. 

Only how do I get out of this? I have to tell the client we have to stop. But how? What do I say? … 

We have clearly defined rules on what gifts we can give or receive. 

We never give or receive anything that is outside these rules, or that could be regarded as trying to exert improper influence.

Always get approval for and record on any gift or hospitality over £100.

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