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Bribery Act: Hospitality rules

With the Bribery Act coming into force in June, will you still be allowed to buy lunch for potential clients

Can you still provide hospitality under the new Bribery Act rules?

Again, the answer here is “yes”.

The Bribery Act guidance states:

The Government does not intend that genuine hospitality or similar business expenditure that is reasonable and proportionate be caught by the Act, so you can continue to provide bona fide hospitality, promotional or other business expenditure.

However, where so-called “hospitality” is actually a cover for bribing someone, you could be in stickier territory. The authorities could look at things such as “the level of hospitality offered, the way in which it was provided and the level of influence the person receiving it had on the business decision in question”.

Specific examples that the Bribery Act guidance mentions are okay include:

  • providing tickets to sporting events
  • taking clients to dinner
  • offering gifts to clients as a reflection of your good relations
  • paying for reasonable travel expenses in order to demonstrate your goods or services

So rest assured: hospitality or promotional expenditure which is “proportionate and reasonable” is very unlikely to fall under the Bribery Act rules.

Now, who wants to take me out to lunch?

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