The Bribery Act does not strictly prohibit gifts and hospitality, but the line between gifts and bribes might not always be clear. As a general rule, anyone working for or with BRE must not use his or her position to solicit any cash, hospitality or gifts from any third party such as a supplier or client for personal benefit.
In some cultures the unsolicited offer of gratuities is standard practice, and refusal to accept could cause offence. In such circumstances it is permitted to accept gifts or hospitality provided they are of token or nominal value. The offer to BRE staff and representatives of any type of gift, hospitality or other gratuity must be recorded, whether it is accepted or not (refer to the Acceptance of Gifts, Hospitality and other Gratuities Procedure in the BRE staff area of this site for further details).
Please note that anyone involved in certification for BRE Global must never accept gifts or hospitality from clients in situations that could threaten or be perceived to threaten impartiality.
Should you wish to offer a gift or hospitality to a third party on behalf of BRE – regardless of whether you purchased it yourself – seek approval first (if you are an employee, from your Line Manager and the Legal department; if you are not an employee, from your main contact person at BRE and BRE’s Legal department) and record such offer in the gifts, gratuities and hospitality register.
You should decline a gift or hospitality:
- when it could reasonably be regarded as likely to create a conflict of interest,
- when it could materially influence a BRE relationship with a third party, and/or
- when it could create a real or perceived obligation to a third party.
If in doubt consult with a representative from the BRE Legal team, Compliance team or Group Board.
Q: At a networking event you are approached by someone representing a company that wants to do business with BRE. While making small talk you mention that you are a big tennis fan. Later in the week that person offers you two tickets to a Wimbledon semi-final.
May you go to the match?
A: Given the value and nature of the gift, and because this person hopes to do business with BRE, it is likely that you would have to politely decline. Because the test of accepting gifts or hospitality is subjective, it is strongly recommended that you discuss this with your Line Manager and Legal and Compliance teams, or the Group Board before deciding. Even if you decline, you should still record the offer in the gifts, gratuities and hospitality register.