A gift or a bribe? Five questions to ask

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With the holiday season in full swing in much of the world, we’re focusing on gifts & hospitality this month. Many companies use a combination of qualitative and quantitative elements to determine whether giving or receiving a gift is acceptable. The qualitative determinations can be tricky, but the following questions can help. Considerations should include:

  • Intention. Is there an expectation of something in return? Is there legitimate business purpose?
  • Timing. Does a gift immediately precede a decision-making process, like a tender bid?
  • Frequency. Are there repeated gifts to or from the same person or personnel in the same agency?
  • Size. Is the gift or hospitality reasonable and appropriate under the circumstances?
  • Perception. Would the gift or hospitality give rise to the appearance of impropriety?

Multinational companies all over the world rely on TRACE to raise the standards of their compliance programs. TRACE supports members’ gifts & hospitality processes with unlimited access to:


  • the TRACEgifts tool, which allows you to track an unlimited number of business interactions, identify red flags, automate and streamline gifts and entertainment processes, search and report on key data, set and enforce hospitality limits, and more;
  • refresher training courses on gifts & hospitality, which can be deployed to employees and third parties along with our comprehensive, multilingual compliance training curriculum, included with membership; and
  • the TRACE Resource Center, which includes gifts & hospitality guidance, training aids, model and sample policies, and country-specific guidelines updated annually by TRACE Partner Firms.

TRACE membership is designed to power your compliance program by giving you unlimited access to tools and resources that support the key components of effective compliance.