Gifts and Entertainment Policy
1. Purpose
This policy (Ref: COMP-CE-004) defines the Bank's rules governing the giving and receiving of gifts, hospitality, and entertainment by employees in the context of their professional duties. It is designed to prevent bribery, corruption, and the appearance of impropriety, and to ensure compliance with the UK Bribery Act 2010, the US Foreign Corrupt Practices Act (FCPA), and applicable anti-bribery legislation in all jurisdictions where the Bank operates.
2. Scope
This policy applies to all employees, officers, directors, and any person acting on behalf of the Bank. It covers gifts, hospitality, and entertainment given to or received from clients, prospective clients, vendors, suppliers, regulators, government officials, and any other external party.
3. Key Definitions
- Gift — Any item of value given or received, including physical items, vouchers, tickets, memberships, discounts, or other benefits.
- Hospitality — Meals, drinks, accommodation, travel, or other entertainment provided in a business context.
- Entertainment — Cultural, sporting, or social events attended in a business capacity.
4. Monetary Thresholds and Approval Requirements
| Value (per item/event) | Requirement |
|---|---|
| Up to EUR 50 | No approval required; must be logged in the Gifts & Entertainment Register within 5 business days |
| EUR 50 – EUR 100 | Line manager approval required; must be logged in the Register |
| EUR 100 – EUR 250 | Pre-approval from line manager and Compliance Department required |
| Above EUR 250 | Pre-approval from Head of Compliance and relevant department head required |
The cumulative value of gifts and entertainment from or to a single counterparty must not exceed EUR 500 in any rolling twelve (12) month period without the express approval of the Head of Compliance.
5. Prohibited Categories
The following are strictly prohibited, regardless of value:
- Cash or cash equivalents — Including gift cards that can be exchanged for cash, cryptocurrency, or bearer instruments.
- Gifts or hospitality to or from government officials or regulators — Unless pre-approved by the Head of Compliance and the Legal Department. Any such engagement must be documented and justified on the basis of a legitimate business purpose.
- Lavish or excessive hospitality — Including luxury travel, accommodation at five-star hotels (unless standard for the event), or entertainment that is disproportionate to the business context.
- Gifts or entertainment provided during a procurement or tender process — To prevent any actual or perceived influence on the outcome.
- Gifts or hospitality that create a sense of obligation — Any gift or hospitality that could reasonably be perceived as intended to influence a business decision.
6. Government Officials and Public Sector
Interactions with government officials, regulators, and public-sector entities are subject to heightened scrutiny. All gifts, hospitality, and entertainment involving government officials must be pre-approved by the Legal Department, regardless of value. The Bank maintains a zero-tolerance approach to any payment or benefit that could constitute a bribe or facilitation payment under applicable law.
7. Gifts & Entertainment Register
The Compliance Department maintains a centralised Gifts & Entertainment Register. All employees are required to log gifts and entertainment (given or received) via the Bank's intranet portal. The Register is reviewed by the Compliance Department on a monthly basis to identify patterns or potential policy violations.
8. Declining and Returning Gifts
Employees must decline or return any gift or hospitality that does not comply with this policy. Where declining would cause offence or is impractical (e.g., perishable items), the item should be accepted, declared, and either donated to charity or shared among the wider team. The receipt must be logged in the Register with the reason for acceptance.
9. Training
All employees must complete gifts and entertainment awareness training as part of the annual Code of Conduct certification. The Compliance Department issues periodic reminders and updates, particularly ahead of seasonal periods (e.g., year-end holidays, major sporting events).
10. Consequences of Non-Compliance
Breaches of this policy may result in disciplinary action, up to and including termination of employment. Serious breaches may be reported to relevant regulatory and law enforcement authorities.
11. Review
This policy is reviewed annually by Legal & Compliance. Next review: Q2 2027.