A business lunch is fine. The problem is when no one can prove that's all it was. Gifts and entertainment are the most common source of inducement breaches in FCA-regulated firms — not because of bad intent, but because policies are vague, thresholds aren't enforced, and records aren't kept. Under COBS 2.3, MiFID II, and the Bribery Act 2010, the FCA expects firms to demonstrate that no gift, hospitality, or inducement has impaired their duty to act in clients' best interests. Clear thresholds, proper approval chains, full documentation, no grey areas.
What's included:
Full regulatory framework: COBS 2.3A, SYSC 10, MiFID II Article 24, Bribery Act 2010 Sections 1/2/6/7, Consumer Duty PRIN 2A, and TCF principles — with Section 7 adequate procedures defence framework
Four-tier value threshold structure: £25, £150, £500, and above £500 — with per-item and annual aggregate limits and pre-approved, approval-required, and prohibited classification across all categories
Absolute prohibitions: cash equivalents, political contributions, procurement-timed benefits, luxury accommodation, premium travel, family member extensions, and Bribery Act bribes
Timing-related prohibitions: active procurement processes, regulatory reviews, and contract negotiations — with red flag indicator matrix and required actions by category
Risk assessment framework for high-risk recipients: regulatory officials, public sector, and key decision-makers — with conflicts of interest identification under COBS 2.3.1R and SYSC 10.1.11R
Third-party and AR compliance obligations under SYSC 8.1.1R and FSMA Section 39 — with contractual requirements including audit rights and termination provisions for non-compliance
Ready-to-use templates: gifts and entertainment pre-approval form with conflict assessment, post-activity reporting template, and product assessment matrix with RAG-rated compliance status + much more
Who is this for?
Compliance Officers, SMF holders, and client-facing staff at FCA-regulated firms who need a complete, board-approved Gifts and Entertainment Policy that satisfies FCA inducement rules, MiFID II, and Bribery Act adequate procedures requirements simultaneously.
How it works
Step 1 — Read it. Every section exists for a reason, grounded in a specific regulatory obligation.
Step 2 — Understand it. Map the content against your current practices. Identify where you're strong and where gaps exist.
Step 3 — Make it yours. Tailor the language to reflect how your organisation actually operates. A policy that sounds like your firm is a policy your people will follow.
Step 4 — Take ownership. Assign clear accountability — Board approval, named SMF holder, designated policy owner. A policy without an owner is a liability, not an asset.
Step 5 — Operationalise it. Embed the policy into your governance calendar, training programme, and annual review cycle. This is where compliance becomes culture.
Or, get this free with RegTechPRO
Access this alongside the full compliance policy library — SM&CR, COBS, AML, Consumer Duty, GDPR, and more — for a fraction of the cost of consultancy.
View RegTechPRO pricing and packages →
A business lunch is fine. The problem is when no one can prove that's all it was. Gifts and entertainment are the most common source of inducement breaches in FCA-regulated firms — not because of bad intent, but because policies are vague, thresholds aren't enforced, and records aren't kept. Under COBS 2.3, MiFID II, and the Bribery Act 2010, the FCA expects firms to demonstrate that no gift, hospitality, or inducement has impaired their duty to act in clients' best interests. Clear thresholds, proper approval chains, full documentation, no grey areas.
What's included:
Full regulatory framework: COBS 2.3A, SYSC 10, MiFID II Article 24, Bribery Act 2010 Sections 1/2/6/7, Consumer Duty PRIN 2A, and TCF principles — with Section 7 adequate procedures defence framework
Four-tier value threshold structure: £25, £150, £500, and above £500 — with per-item and annual aggregate limits and pre-approved, approval-required, and prohibited classification across all categories
Absolute prohibitions: cash equivalents, political contributions, procurement-timed benefits, luxury accommodation, premium travel, family member extensions, and Bribery Act bribes
Timing-related prohibitions: active procurement processes, regulatory reviews, and contract negotiations — with red flag indicator matrix and required actions by category
Risk assessment framework for high-risk recipients: regulatory officials, public sector, and key decision-makers — with conflicts of interest identification under COBS 2.3.1R and SYSC 10.1.11R
Third-party and AR compliance obligations under SYSC 8.1.1R and FSMA Section 39 — with contractual requirements including audit rights and termination provisions for non-compliance
Ready-to-use templates: gifts and entertainment pre-approval form with conflict assessment, post-activity reporting template, and product assessment matrix with RAG-rated compliance status + much more
Who is this for?
Compliance Officers, SMF holders, and client-facing staff at FCA-regulated firms who need a complete, board-approved Gifts and Entertainment Policy that satisfies FCA inducement rules, MiFID II, and Bribery Act adequate procedures requirements simultaneously.
How it works
Step 1 — Read it. Every section exists for a reason, grounded in a specific regulatory obligation.
Step 2 — Understand it. Map the content against your current practices. Identify where you're strong and where gaps exist.
Step 3 — Make it yours. Tailor the language to reflect how your organisation actually operates. A policy that sounds like your firm is a policy your people will follow.
Step 4 — Take ownership. Assign clear accountability — Board approval, named SMF holder, designated policy owner. A policy without an owner is a liability, not an asset.
Step 5 — Operationalise it. Embed the policy into your governance calendar, training programme, and annual review cycle. This is where compliance becomes culture.
Or, get this free with RegTechPRO
Access this alongside the full compliance policy library — SM&CR, COBS, AML, Consumer Duty, GDPR, and more — for a fraction of the cost of consultancy.
View RegTechPRO pricing and packages →
Image 1 of 6
Image 2 of 6
Image 3 of 6
Image 4 of 6
Image 5 of 6
Image 6 of 6
