It’s the time of 12 months that distributors attempt to unfold vacation cheer, usually within the type of items and leisure. That means it’s additionally time to overview company insurance policies earlier than accepting even the smallest present, in keeping with attorneys at Fisher-Phillips.

A present or meal may very well be perceived as a bribe and due to this fact necessitate a transparent items and leisure coverage, the agency’s specialists say.

“An effective G&E policy can’t address every possible situation, but a well-drafted policy can promote consistency, encourage ethical business relationships, minimize potential concerns and provide guideposts for your employees — as well as your business partners,” wrote Fisher-Phillips accomplice Melissa A. Dials, within the agency’s Cleveland workplace, and Raymond W. Perez, of counsel within the agency’s Columbus, OH, and Washington, DC, places of work.

The coverage ought to be written to incorporate workers on each rung of the company ladder, in keeping with the attorneys. 

“If top executives are allowed to receive gifts and entertainment that exceed the company limits, it can send the message that the ethical standards apply to all employees except the C-Suite executives,” they wrote. “This hurts morale and can lead employees to assume that it is acceptable to violate other company standards.”

Accepting invites to particular occasions usually is permissible, they mentioned, so long as such occasions “are deemed commercially reasonable and the individuals are representing the company.” Beware, nonetheless, that some occasions could be inappropriate and violate anti-bribery legal guidelines, they added. Therefore, the attorneys mentioned, it’s greatest to ask for approval by the corporate’s authorized or compliance group earlier than accepting.

According to Dials and Perez, a items and leisure coverage ought to cowl:

• Dollar limits,
• Gifts to an worker’s relations and
• Timing — as an illustration, don’t settle for items “during the bidding process, contract negotiations, during vendor evaluations or formal reviews.”

The coverage ought to be included in an organization handbook that’s out there to all workers, the attorneys mentioned.

“It’s also a good practice to send annual reminders (i.e., during the holidays) to business partners regarding the company’s G&E policy and ask for their cooperation,” Dials and Perez suggested.