Gifts, Hospitality, Donations and Similar Benefits for ISO 37001 Anti-Bribery

ISO 37001 Clause 8.7

Procedures preventing gifts, hospitality, donations and similar from being or being perceived as bribery.

ISO 37001 Clause 8.7 - Gifts, Hospitality, Donations and Similar Benefits

Clause 8.7 is short but practical. The organisation must implement procedures designed to prevent the offering, provision or acceptance of gifts, hospitality, donations and similar benefits where the offering, provision or acceptance is or can be perceived as bribery.

What the Procedure Has to Cover

A typical Clause 8.7 procedure covers what counts as a gift or hospitality, what is acceptable and what is not, monetary thresholds for declaration and pre-approval, the rules around hospitality offered by or to public officials (which are usually stricter), the treatment of donations including charitable and political donations, the rules around facilitation payments (usually a flat prohibition), and the requirement for a register of significant gifts and hospitality given and received.

The P-108 Hospitality and Gifts Policy provides a policy template covering these elements. The ER22 Hospitality and Gifts Register and F-Q75 Hospitality and Gifts Register provide register templates for tracking actual gifts and hospitality given and received - the choice between them depends on the organisation preferred format.

The Public Official Dimension

Gifts and hospitality involving public officials are treated more strictly. The Bribery Act 2010 covers bribery of foreign public officials specifically and many countries have their own laws restricting acceptance of gifts by public officials. Hospitality offered to a public official as part of normal business courtesy can still be lawful, but the threshold is lower and the documentation needs to be tighter.

The procedure typically requires pre-approval for any hospitality involving public officials above a low threshold, full documentation in the register, and post-event review where the hospitality could plausibly relate to a decision the official is making about the organisation.

Donations and Sponsorships

Charitable and political donations are within the scope of Clause 8.7. The risk is that donations made at the request of an individual customer, public official or business partner can be effectively a bribe by another route. The procedure typically requires pre-approval for any donation above a set threshold, due diligence on the recipient, and clear documentation that the donation is not contingent on or linked to a specific decision in favour of the organisation.

The two-document approach works well - a policy that sets out the rules, plus a register that tracks the actual gifts and hospitality. The policy gives staff a clear reference. The register gives the auditor and management review the visibility into actual practice.

The mistake is making the policy so cautious that it is not workable, or so loose that it is not protective. A practical policy sets reasonable thresholds, requires pre-approval above those thresholds, and records what actually happens. Staff who feel the rules are reasonable will follow them. Staff who feel the rules are unworkable will route around them.

I look at the gifts and hospitality register against the policy. I check that significant entries are present, that pre-approvals are documented where required, and that the volume looks plausible for the size and nature of the organisation. A register that is empty or that contains only token entries usually means the procedure is not actually operating.

Practical Compliance Guidance

Gifts, hospitality and donations are governed by P-108 with practical tracking through ER22 or F-Q75. The combination provides clear rules and a record of actual practice that is reviewed at management review.

The documents below support the procedures required by Clause 8.7.

alphaZ document	How to use it
ISO 37001 Toolkit	Complete documentation set for ISO 37001:2025 compliance, including the IMS1 Manual, the PP-1-19 Anti-bribery procedure and all supporting registers and forms.
P-108 Hospitality and Gifts Policy	Policy setting out the rules for offering and accepting gifts, hospitality and similar benefits.
ER22 Hospitality and Gifts Register	Register format for tracking gifts and hospitality given and received.
F-Q75 Hospitality and Gifts Register	Alternative form-based register for hospitality and gifts.
PP-1-19 Anti-bribery Procedure	Sets out the procedural detail including approvals, thresholds and the rules for public official interactions.

Note - all the above files can be downloaded with an alphaZ subscription.

Frequently Asked Questions

Does Clause 8.7 require a complete prohibition on gifts and hospitality?

No. The clause requires procedures preventing gifts and hospitality being or being perceived as bribery. Reasonable, transparent business courtesy is acceptable - what is not acceptable is anything that could create or be perceived to create an obligation in favour of the giver. The thresholds and pre-approval requirements provide the framework.

How are facilitation payments handled?

Most organisations operate a flat prohibition on facilitation payments because they are unlawful under the Bribery Act 2010 regardless of whether they are common in the country where they are offered. The PP-1-19 procedure typically states this explicitly and includes the route to take when a facilitation payment is requested.

What thresholds should the policy use for gifts and hospitality?

Thresholds depend on the sector, the country and the nature of the relationships. Many organisations use modest thresholds for routine gifts, with pre-approval required above those thresholds and tighter rules for any gifts or hospitality involving public officials. The policy should set thresholds that match what the organisation actually encounters.

Are charitable donations within scope of Clause 8.7?

Yes. Donations are explicitly listed in the clause heading and have to be covered by the procedures. The risk is that a donation made at the request of a customer or official is effectively a bribe routed through a third party. Due diligence on the recipient and clear documentation that the donation is not contingent on a specific decision are the typical controls.

UK Legislation

The following UK legislation governs the legal context for gifts, hospitality and donations - the Bribery Act 2010 specifically covers bribery of foreign public officials.

Further Resources