Gifts, Hospitality, Entertainment, Donations and Other Benefits - Overview

This section provides guidance in relation to the requirement that an 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 for Organisations). 

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, guidance and personnel training to deal appropriately with these Benefits (see above Guidance).
  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.
  4. The organisation should document and implement these policies and procedures.
  5. The organisation should monitor and periodically audit that these policies and procedures are being correctly followed.

Updated on 10th April 2020