Gifts & Entertainment Policy Template

The 50-page Gifts, Entertainment & Inducements Policy is an FCA-aligned guide for managing gifts and hospitality to prevent bribery and conflicts of interest. Built on COBS 2.3, SYSC 10, and the 2025 FCA updates, it ensures ethical conduct and compliance in the financial services sector.

It outlines the processes for approving, recording, and monitoring gifts, along with customisable templates such as gift registers and approval forms. Supporting SMCR accountability, audits, and FCA regulations, it promotes transparency and integrity across operations.

Includes:

• Regulatory Background (FCA, COBS, MiFID II, Bribery Act 2010)

• Alignment with TCF & Consumer Duty

• FCA’s Stance on Inducements

• COBS 2.3 – Inducements

• SYSC 10 – Conflicts of Interest

• Bribery Act 2010 & Anti-Corruption Measures

• Impact of MiFID II on Inducements

• FCA Expectations for Investment Firms

• What Constitutes an Inducement?

• Definitions of Gifts, Entertainment, and Hospitality

• Acceptable vs. Unacceptable Inducements

• Monetary vs. Non-Monetary Benefits

• General Principles for Giving and Receiving Gifts

•  Acceptable and Prohibited Inducements

• Guidelines on Receiving Gifts & Hospitality

• Monetary Limits and Thresholds

• Responsibilities of Employees and Senior Management

• Gifts & Hospitality Register

• Conflicts of Interest & Inducements

• Acceptable Inducements & Exceptions

• Prohibited Practices & Non-Compliance

• Client Disclosure Requirements

• Transparency in Inducements

• Pre-Transaction & Ongoing Disclosures

• FCA Reporting Obligations

• Responsibilities & Governance

• Whistleblowing & Reporting Concerns

• Gift & Hospitality Approval Form

• Inbound Gifts & Hospitality Form

• Outbound Gifts & Hospitality Form