1. Where such a comprehensive policy is deemed unnecessary (or where there is a need to give addition or specific advice regarding accepting gifts and/or hospitality) a policy such as the following may be appropriate.

2. The [company] operates under known and advertised terms of business and, unless there are specific reasons and the negotiation has board approval, will not alter such terms.

3. The [company] insists that at all times the highest standards of service are given to every customer and supplier. It expects similar treatment from its suppliers. Accordingly, there should be no need for any marks of appreciation to be either given or received regardless of whether such appreciation is made in money, kind or other items of value.

4. Without exception, gifts of money may not be either given or received and in such event, any employee found culpable of either giving or receiving cash will be regarded as in breach of the [company's] rules in a matter of gross misconduct, and dealt with accordingly. Gross misconduct generally leads to dismissal.

5. Any gifts of appreciable value offered or received, should either be politely but firmly declined when offered, or if this is not possible (that is they are delivered by a courier or equivalent), then returned with a note indicating that it is against company policy for individuals to receive gifts. Appreciable value will be determined annually but currently it is [sum]. Every instance of a gift being declined or returned must be notified to [name].

6. On occasion, to decline or return a gift could cause offence - particularly with foreign [customers]. If this is felt to be the case, then, with the approval of [senior management name] the gift may be retained by the [company] and disposed of as decided by [name]. This may mean allowing the original recipient to retain the item or requiring it to be otherwise disposed of.

7. Whilst [the company] accepts that from time to time it may be conducive to business relationships to accept hospitality from, or provide it for, third parties, this must be confined to a normal business breakfast, lunch or dinner. In the event that entertaining in excess of this guideline is offered or received, this should always be regarded as exceptional and separate notification of each instance is required to be made to [name].

8. Advance approval from [name] must also be sought should it be considered appropriate to offer such entertainment. Again, any breach of this guideline will be regarded as gross misconduct.

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