Supplier gifts and hospitality: UK bribery rules
Check supplier gifts and hospitality before accepting, use an independent approver and record offers, including refusals. Refuse facilitation payments and escalate requests without disguising them as expenses. Agree these controls with your sourcing partner, including Cambridge China Bridge.
Separate legal obligations from company controls
UK government guidance states that offering, promising, giving, requesting, agreeing, receiving or accepting bribes is illegal. Treat benefits offered to procurement staff as a concern to assess before accepting, especially when supplier selection, inspection acceptance or payment approval is pending.
The approval steps below are suggested company controls. Make them proportionate to your risks: government guidance recommends proportionate procedures. A factory's ethical audit does not replace your own approval process. Use our ethical audit guide for the separate task of checking audit scope and corrective actions.
Assess the offer before accepting
Ask who is paying, who benefits, the business purpose, the estimated value and whether an order decision is pending. Assess repeated offers together. Meals, accommodation, travel, entertainment and benefits for relatives should enter the same review process as physical gifts. Watch for secrecy, personal account payments or an expectation of favourable treatment.
As a company rule, decline cash, personal commissions and offers tied to awarding business or overlooking defects. For a factory visit, propose paying your own travel and accommodation. Record product samples against the specification and evaluation purpose; avoid treating goods supplied for personal use as evaluation samples.
Set an independent approval route
Name an approver who does not receive the benefit, and a substitute when that person is unavailable. Set your own approval limits and escalation triggers in writing. Require approval before acceptance, with the purpose, attendees, estimated value, supplier relationship and reason for the decision recorded. Make conflict disclosure part of the request.
Brief buyers, visiting staff and people acting for you on the same controls. Agree with your sourcing partner how offers and concerns reach your UK team. Keep hospitality approval separate from supplier selection, quality acceptance and payment release. Our order and payment approval guide helps organise those decisions.
Refuse facilitation payment requests
Government guidance describes facilitation payments as payments to induce officials to perform routine functions they are otherwise obligated to perform, and states that these are bribes. Do not agree to an unofficial payment to get routine paperwork or clearance completed. A request passed through an agent still needs scrutiny.
Ask for the fee's written basis, the charging organisation, an invoice and the official payment route. Send the documents to your compliance or legal adviser before authorising payment; a receipt alone does not resolve the concern. Say: “I cannot authorise an unofficial payment. Please provide the documented charge for our review.” If threatened, prioritise personal safety and report the circumstances as soon as safe.
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Record concerns and follow them through
Keep a register of offers accepted, declined or returned. Record the date, people and organisations involved, benefit or payment requested, estimated value, business context, approval decision and supporting messages. For concerns, preserve the original request and note what was said or done. Describe observed facts without presenting suspicion as a proven offence.
Report promptly through your compliance contact, with an alternative route if that person is involved. Assign an owner to review the concern and record the outcome and any changes to supplier access or approvals. UK government guidance says to contact the police first if you suspect someone has broken the law. Cambridge China Bridge has its own staff in China; agree how on-site concerns will reach your UK decision-maker.
Frequently asked questions
Can I accept a meal from a Chinese supplier?
Submit the purpose, attendees, estimated value and any pending buying decision to your independent approver. Follow your company policy and record the outcome. Decline if the supplier expects favourable treatment.
What gift value should trigger approval?
Set limits in your own policy according to risk. Include escalation triggers for repeated offers, personal benefits and pending supplier decisions. Assess the circumstances as well as the value.
Can an agent pay a facilitation payment for us?
Do not authorise an agent to make it. Government guidance states that payments to induce officials to perform routine functions they are otherwise obligated to perform are bribes. Escalate the request.
Should we record a gift we refused?
Yes, as a company control. Record who offered it, what it was, the buying context, your response and any messages. Repeated refused offers may reveal a concern that an accepted-gifts register would miss.