Gifts, Hospitality, Entertainment,

Donations and other Benefits


This section provides guidance in relation to the requirement that the organisation should implement controls which minimise the risk of corruption in relation to gifts, hospitality, entertainment, donations and other benefits (“Benefits”) (measure 9 of the Anti-Corruption Programme). 


In particular, the organisation should:

  • adopt a policy which prohibits the offer, giving or receipt of Benefits where the offer, giving or receipt is, or could reasonably be perceived to be, for the purpose of corruption; and
  • implement procedures which minimise the risk of breach of this policy.


This guidance distinguishes between the following five categories of benefit, and provides guidance on separate web-pages in respect of each category.  Click on the relevant link to access the web-page.

Sample Benefits Policy

Two sample benefits policies can be accessed on the following link.  These comprise a simple short form policy for small organisations and a more comprehensive policy for larger organisations.

Implementation checklist for Measure 9


  1. The organisation should assess what types of Benefit are applicable to the organisation, and the corruption risks they pose (see above Guidance).

  2. The organisation should create or enhance the necessary policies, procedures and guidance to deal appropriately with these Benefits.

  3. The organisation should appoint an appropriate manager(s) to assume responsibility for oversight over the Benefits, and for ensuring that all relevant personnel are aware of and comply with the relevant policies and procedures.  This manager could be the compliance manager, HR manager or other appropriate person.


Most recent update on 17th February 2016

Page first published on 1st May 2008


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