SAI Global Compliance Survey of Gift Policies Finds Most Organizations Mandate Employee Reporting

Exceptions to Gift Policies Seldom if Ever Granted

Nearly three-fourths (72 percent) of North American-based organizations require employees to report on gifts offered or received from clients and vendors, and many outline acceptable and unacceptable gifts. More than a quarter (26 percent) of organizations never grant exceptions to their gift-giving and -receiving policies, while 52 percent of organizations rarely do so, according to the 2013 SAI Global Snapshot on Gift Giving and Receiving, a survey of 299 North American corporate compliance officers and ethics professionals.

“The holiday season brings increased risks associated with the giving and receiving of gifts to the forefront,” said Tim Whipple, President of SAI Global Compliance. “Clearly, many organizations are taking a hard-line stance on exceptions that could give rise to these risks and they are also utilizing registries to improve visibility and establish a comprehensive record to help mitigate the risks.”

Additional survey findings reveal that while 54 percent of organizations don’t set a limit on the frequency with which employees can give or receive gifts, many policies do spell out which gifts are acceptable. Promotional items, such as pens and calendars, are always acceptable in 48 percent of organizations, followed by food, which is always acceptable in 22 percent of organizations.

Other “always” acceptable items included flowers (21 percent), meals (17 percent) and desk/office accessories (16 percent). Most of these aforementioned items were also typically acceptable “under certain conditions.”

According to respondents, several items are overwhelmingly never acceptable, including:

  • Gift cards, certificates or cash equivalents (65 percent)
  • Trips and travel (60 percent)
  • Electronics and cameras (57 percent)
  • Crystal (56 percent)
  • Wine and spirits (50 percent)

SAI Global Compliance, the world’s leading provider of governance, risk and compliance (GRC) products, services and technology, commissioned the survey in December to coincide with the holiday season.  Complete findings from the survey as well as additional resources can be found on the SAI Global Compliance Conflicts-of-Interest Resource Center at:

“Now is the perfect time to remind employees about organizational gift-giving and -receiving policies,” said Whipple. “As we enter a new year, we recommend organizations review their policies to ensure they clearly correspond to their organizational values and pertinent compliance obligations.”

When looking at the specific limits on gift values employees can give without approval, 35 percent of organizations capped the amount at “modest,” or at less than $25. Ten percent had a cap at less than $50 and 12 percent of organizations capped the amount at less than $100 value. In some organizations (20 percent), gifts are never allowed, while 14 percent of organizations require specific approval.

For limits on the value of gifts employees can receive without specific approval, the findings showed 38 percent of organizations capped the amount at “modest” or at less than $25. Thirteen percent have a less than $50 value and 18 percent of organizations cap the value at less than $100. Employees are not allowed to receive gifts in 17 percent of the organizations.

Nearly all of the organizations use a variety of channels and training methods to educate employees on gift-giving and -receiving policies. The most commonly used methods to share these policies include:

  • Internal code of conduct or employee handbook (78 percent)
  • Stand-alone policy (55 percent)
  • Online (45 percent)
  • As part of travel and entertainment policy (29 percent)

Nearly two out of three (64 percent) organizations provide annual updates or reminders to employees on gifting policies. Ethics professionals report doing this through:

  • Training courses (74 percent)
  • Periodic reminders or ongoing communications (72 percent)
  • Employee handbook (71 percent)

About the 2013 SAI Global Snapshot on Gift Giving and Receiving

SAI Global Compliance commissioned a blind survey of chief compliance officers and ethics professionals in December 2013.  Respondents to the online survey included a total of 299 executives. Of that group, 31 percent reported their organizations have more than $3 billion in sales and 53 percent had 5,000 or more employees. The plurality, 40 percent, was from public companies and the industries represented included health care, financial services, insurance, health insurance, manufacturing and more.

More details on the 2013 SAI Global Snapshot on Gift Giving and Receiving can be found at:

About SAI Global Compliance

SAI Global Compliance provides a full range of governance, risk and compliance (GRC) software applications, learning and awareness solutions and advisory services. With more than 25 years of experience and offices worldwide, we combine deep expertise with practical technology solutions to help thousands of organizations reduce risk, enhance compliance, streamline governance and make better decisions. For more information about our solutions and services, visit

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