Tips for creating and implementing a global gifts and hospitality policy

This column explores how to create a robust policy for a multi-cultural, multi-industry organization. The insights are based on the recent launch of a “global/umbrella” gifts and hospitality policy by FUJIFILM Holdings America Corporation, which was created for our 23 subsidiaries in the U.S., Canada, Brazil, and Colombia, and is also applicable to some subsidiaries in India, Europe, Australia, and Singapore. Making matters more complex, these multiple subsidiaries span diverse industries, including life sciences, advanced materials, cameras, ink/graphics, medical devices, and more.

Creating an overarching policy that works for everyone sounds daunting, but it’s doable and necessary. Begin by keeping the goal in mind: To mitigate risk yet allow for reasonable business practices—all while considering the nuances and customs of various industries and cultures.

Research and planning

Don’t underestimate the importance of research and planning. Give yourself plenty of time for due diligence, between 12 and 18 months for large, complex organizations. The following five action steps will help set the stage for successfully drafting and launching an effective policy.

• Involve key stakeholders. It’s important to get insights from internal experts and ensure everyone feels heard. This can be challenging when there are numerous subsidiaries, each with its own human resources (HR) leader and compliance officer (COs), as was the case at Fujifilm. We ascertained that it would be inefficient to involve 40+ additional people from our subsidiaries in the initial stages. Instead, five COs and five HR leaders from the subsidiaries with the largest employee populations were invited to contribute to the planning process. At the same time, other subsidiary COs were assured that once a draft of the policy was created, they’d have a chance to review it and offer comments and requests for changes. Ultimately, all stakeholders had a voice in the final policy.
• Survey subsidiaries. Before establishing a “global” policy, determine what gift and hospitality policies are already in place. Subsidiaries—especially in different countries—may already have established varying monetary thresholds. Some may have very low thresholds, and others none. For example, in countries like Japan, gift giving is common, and it’s impolite to refuse gifts. Get the full picture so you are in a good position for establishing an umbrella policy that works for all.
• Benchmark competitive companies. Explore thresholds other companies use. Multi-industry companies should do broad benchmarking across various industries. Fujifilm ultimately determined its threshold after both surveying its own subsidiaries and benchmarking large organizations.
• Plan the approval/reporting mechanism. Ultimately, employees will need to seek exceptions to the policy or pre-approvals, as well as disclose certain gifts received. Before the policy is launched, work with your internal or vendor IT group to create a user-friendly approval and reporting system. The reporting mechanism fosters transparency and provides an audit trail that compliance officers can review.
• Check local regulations. It’s vital to check local regulations for a global gifts and hospitality policy to prevent bribery, corruption, and severe fines because laws vary drastically by country, especially as it concerns government officials. You also want to respect local customs, as a globally uniform limit often fails to capture local nuances, potentially causing unintentional violations or alienating partners. Ignoring local rules exposes companies to legal penalties, reputational damage, and operational disruption, requiring a nuanced, jurisdiction-specific approach to balance global ethics with local realities.

Drafting and roll-out

After thorough research and planning, you’re ready to draft and launch your policy. Here are some best practices for ensuring clear communication and smooth roll-out.

• Define scope and purpose. In the written policy, clearly state why a gift and hospitality policy is necessary—for example, “to mitigate potential issues, such as bribery, conflicts of interest, and undue influence.” Specify which employees, subsidiaries, and regions/countries the policy applies to, including third parties.
• Set a threshold and address cultural differences. Employees want clarity on what is and what is not an acceptable gift or hospitality. One effective approach: Take all cultural nuances into consideration, but provide flexibility on the threshold by location. At Fujifilm, we considered all our subsidiaries’ existing thresholds, and then we benchmarked with major organizations. Ultimately, we arrived at a $100 threshold. However, our subsidiary COs in Brazil and Colombia told us that $100 was “too generous,” based on local customs and the current exchange rates. So, we established a clear rule: Any given subsidiary is at liberty to keep its own specific threshold, provided it is lower than $100. In other words, a subsidiary’s threshold can be stricter but not more generous than that of the overarching global policy.
• State the principles. It’s nearly impossible to put a monetary figure on hospitality because there are so many types—conferences, meals, special events, etc. Instead, in your written policy, communicate what is and what is not acceptable through a clear list of principles. For example, in the case of Fujifilm, gifts and hospitality may be permissible if they: “Be rare, transparent, modest, compliant, voluntary, relevant and appropriate.” Also, whatever your principles, the meaning of each must be clearly and concisely explained or defined in the policy.
• Establish an exception request process. Clearly communicate the various circumstances when an employee must seek an exception, and how an employee goes about doing so. For example, Fujifilm’s policy spells out five scenarios in which an employee must seek approval from their manager and subsidiary CO via an Exception Request Form before accepting or offering the hospitality.
• Make provisions for government officials and healthcare professionals. Relationships with government officials and healthcare professionals, like clinicians, introduce additional risks. Include a distinct section outlining stricter rules for these groups or develop a separate policy.
• Include an FAQ section. In the written policy, include an appendix of frequently asked questions that help clarify gray areas. You can gather these inquiries from employees and/or COs from your various subsidiaries who had questions before there was an official policy.
• Communicate the policy and provide training. Ensure that leadership at all subsidiaries is informed pre-launch. Provide subsidiary COs with the written policy, a walk-through, and training to get their support in roll out/enforcement. Offer a PowerPoint presentation and materials for their use with employees. Announce the new policy and its rationale to employees using all possible communication channels—emails, blog posts, Intranet, etc. Finally, provide online training and require employees to acknowledge receipt of the written policy and completion of the training.
• Enforce the policy and track effectiveness. Implement a system for reporting gifts/hospitality not in compliance with the policy. You might also require employees involved in the RFP process to disclose any gifts from bidders. Anyone who doesn’t comply with the policy should be subject to investigation and discipline. Enforcement and reporting will help you track how well the policy is working.

In business, appropriate gifts and hospitality can strengthen relationships and encourage new partnerships. The intention of a gift and hospitality policy is to fortify an ethical workplace and ensure that all decisions are made in the best interest of the organization. In some cases, a gift or hospitality experience can cloud one’s judgment. But with the right policy in place, there is clarity and transparency, which means less likelihood of exposure to risk.