Company Gift Policy Examples and Best Practices

Giving gifts can be a great way to build relationships in your business - whether that’s celebrating a team milestone, thanking a client for their loyalty, or recognising a supplier who went above and beyond.

But if you don’t set some clear ground rules, gifts can quickly create awkwardness or risk. You might start seeing questions like: Is this gift appropriate? Should I accept it? Does this create a conflict of interest? What if two staff members are treated differently?

That’s where a clear company gift policy comes in. In this article, we’ll walk you through practical examples of a company gift policy you can adapt for your workplace, plus best practices for Australian small businesses to help you manage gifts and hospitality confidently.

We’ll keep this grounded in the real-world situations small businesses face - without drowning you in legal jargon.

What Is A Company Gift Policy (And Why Your Small Business Needs One)?

A company gift policy is a workplace policy that sets out what gifts, benefits, hospitality, or “freebies” your team can:

give to customers, suppliers, and other business contacts, and
accept from customers, suppliers, contractors, or other third parties.

It’s not just about stopping wrongdoing. A well-written policy helps you create consistency, avoid uncomfortable situations, and protect your business reputation.

Common Problems A Gift Policy Helps Prevent

Conflicts of interest: A gift (or repeated hospitality) can influence - or appear to influence - business decisions like hiring a supplier or awarding work.
Bribery and corruption risks: Even if no one intended anything improper, gifts can raise questions. This risk is higher if your business deals with government/public sector roles, competitive tendering, or heavily regulated industries.
Employee disputes and unfairness: If gift rules aren’t clear, different teams may behave differently, which can lead to complaints or resentment.
Reputational damage: A “thank you gift” posted online can be misinterpreted by customers, competitors, or regulators.
Tax and record-keeping headaches: Without basic processes, it’s easy to lose track of what was given/received and why (and to keep the right records for your accountant/finance processes).

Even if you’re a small business with a close-knit team, having a policy can reduce the chance of misunderstandings as you grow.

Does A Gift Policy Need To Be “Legal” To Be Useful?

A gift policy doesn’t need to be complicated to be effective. In practice, it works best when it is:

clear and easy to follow,
aligned with your values and the way you operate, and
supported by your other workplace documents (like contracts and conduct policies).

If you’re already using a Staff Handbook, a gift policy usually sits neatly inside it, alongside other workplace expectations.

Key Risks To Manage: Gifts, Conflicts Of Interest, And “Perceived” Influence

When you’re building a policy, the biggest thing to manage is not only actual wrongdoing - it’s also the perception of improper influence.

For example, imagine your operations manager is choosing between two suppliers. One supplier sends them an expensive bottle of spirits each month. Even if the manager insists it doesn’t change their decision, it can look questionable to others (including staff, competitors, and the other supplier).

Gifts Vs Hospitality: Why The Difference Matters

Many small businesses treat “gifts” and “hospitality” as the same thing, but they can raise different issues:

Gifts are typically items or benefits given without the giver being present (e.g. hampers, vouchers, tickets sent to someone).
Hospitality usually involves attending something together (e.g. lunches, events, conferences, entertainment).

Hospitality can sometimes be harder to judge, because it may involve ongoing access and relationship-building. That’s why policies often set different rules for each (for example: lunch is okay within reason, but repeated event tickets might not be).

When Gifts Become A Legal Problem

Most small businesses won’t face major legal issues from occasional low-value gifts. But risk increases when:

the gift is high value, frequent, or secretive,
the recipient is in a decision-making role (procurement, hiring, tendering),
the gift is linked to a contract renewal or negotiation,
your business works with government/public sector bodies, regulated industries, or competitive tender processes, or
the situation creates a workplace dispute or complaint.

Having the policy in place doesn’t guarantee nothing goes wrong - but it gives you a framework for preventing issues and responding consistently if they arise.

Company Gift Policy Examples You Can Use (Templates In Plain English)

Below are practical company gift policy examples you can use as a starting point. These aren’t one-size-fits-all - the best policy is one that fits your industry, your risk level, and your team size.

To keep this readable, we’ve written these in plain English, the way a small business would actually communicate internally.

Example 1: A Simple “Low-Risk” Gift Policy For Small Teams

Who this suits: small service businesses, retail, creative studios, or businesses that rarely deal with tenders/procurement.

Team members may accept small gifts that are occasional and clearly a genuine token of appreciation.
Gifts must not be requested or encouraged.
Cash gifts are not permitted.
If a gift could reasonably be seen as influencing a decision, it must be declined.
If a team member is unsure, they must speak to their manager before accepting.

This version is often enough to set the right tone without adding admin burdens.

Example 2: A “Gift Value Threshold” Policy (With Manager Approval)

Who this suits: growing businesses with more staff, regular suppliers, or recurring B2B deals.

Gifts with a value under $50 may be accepted if they are occasional and reasonable.
Gifts with a value between $50 and $200 may only be accepted with written manager approval.
Gifts above $200 must be declined, returned, or shared with the team (as decided by management).
All accepted gifts above $50 must be recorded in the business gift register.

The numbers aren’t “set by law” - you can adjust thresholds to suit your business. The key is setting a sensible line and creating a consistent approval pathway.

Example 3: A “No Gifts During Tendering Or Supplier Selection” Rule

Who this suits: businesses that run competitive procurement, tenders, or formal supplier onboarding.

No gifts or hospitality may be accepted from any party involved in an open tender, quote process, or supplier evaluation.
This restriction applies from the start of the process until the final decision is documented.
Any attempted gifts or hospitality offers must be disclosed to management.

This can be especially useful if your customers are corporates who expect you to have strong governance (even if you’re still a small business internally).

Example 4: A Policy For Gifts Given By Your Business (To Clients Or Suppliers)

Who this suits: businesses that run promotions, client appreciation programs, referral thank-you gifts, or end-of-year gifting.

All client/supplier gifts must be appropriate, legal, and aligned with our brand and values.
Gifts must not be offered in exchange for a specific decision (e.g. awarding work, approving invoices, providing favourable reviews).
Any gift over $150 requires management approval before it is sent.
Gifts must be recorded where required for accounting and transparency.

This is also where you may want to align your policy with your marketing and customer communications, so gifting doesn’t accidentally create misleading expectations.

Example 5: A “Gift Register” Policy (Disclosure And Transparency)

Who this suits: regulated industries, NDIS providers, construction businesses, professional services, or any business that wants stronger governance.

All gifts and hospitality accepted above $50 must be recorded in the gift register within 5 business days.
The register must include: date, giver, recipient, estimated value, and reason for the gift/hospitality.
Management may review the register at any time.
Failure to disclose a gift may result in disciplinary action.

A register isn’t about “policing” your team - it’s about protecting them and your business through transparency.

Example 6: A “No Cash Or Gift Cards” Policy

Who this suits: most businesses, especially where staff make purchasing or supplier decisions.

Cash gifts are not permitted under any circumstances.
Gift cards/vouchers must be declined unless they are low value and clearly part of a public promotion (and management approves).

Cash and cash-like gifts tend to create the highest risk because they are harder to justify and easier to misuse.

Example 7: A Policy Covering Cultural Events And Seasonal Gifting

Who this suits: businesses with diverse teams and clients, and businesses that receive end-of-year gifts.

We recognise that gift giving may form part of cultural or seasonal celebrations.
Where refusing a gift may cause offence, team members should accept the gift on behalf of the business and notify their manager.
Management will decide whether the gift is shared with the team, returned, or otherwise handled appropriately.

This helps your team navigate sensitive situations respectfully while still managing risk.

Best Practices When Creating Your Company Gift Policy

Once you’ve chosen the style of policy you want, there are a few best practices that will make it easier to implement and enforce.

1. Define What Counts As A “Gift” Or “Benefit”

Be specific. Your policy should cover things like:

physical gifts (bottles of wine, hampers, merchandise),
discounts that aren’t available to the public,
free services or “mates rates”,
tickets to events, entertainment, travel, or accommodation,
meals and hospitality, and
prizes or rewards linked to business relationships.

Most confusion happens when the policy only talks about “gifts” but doesn’t mention hospitality or benefits.

2. Set A Clear Approval Process

If someone needs approval, make it easy:

Who approves? (Direct manager? Director? Office manager?)
How do they request approval? (Email? Slack message? Form?)
What info do they provide? (Estimated value, who it’s from, why it’s offered)

If your process is too heavy, people won’t follow it - even if they have good intentions.

3. Make The Policy Consistent With Your Employment Framework

A gift policy usually works best when it’s backed by other workplace documents, including your Employment Contract and any code of conduct expectations you set in writing.

If you have contractors (not employees), you might also want to ensure your contractor terms align with the same expectations, especially if they interact with your clients and suppliers.

4. Include Realistic Examples (The Kind Your Team Actually Encounters)

Instead of only writing “gifts must not be accepted”, include short examples like:

“A client sends a $30 hamper at the end of the year - this can be accepted.”
“A supplier offers premium sports tickets during a contract renewal - this must be declined.”
“A customer offers cash as a tip - this must be declined.”

Examples reduce guesswork and help your policy feel practical, not theoretical.

5. Decide What Happens When A Gift Can’t Be Refused

Sometimes a gift arrives by courier, or refusing would damage an important relationship. Your policy can say what to do, such as:

notify management,
log it in the gift register, and
share it with the team or donate it (depending on your approach).

This gives your staff a safe option without encouraging secret gifting.

6. Train Your Team (Even If It’s Just 10 Minutes At A Team Meeting)

A policy doesn’t help if no one remembers it exists.

A short, practical run-through - especially for new hires or staff in customer-facing roles - can go a long way.

How To Put Your Gift Policy Into Practice (Without Creating A Bureaucracy)

Small businesses often avoid workplace policies because they don’t want to “feel corporate”. That’s completely understandable.

The goal isn’t bureaucracy - it’s clarity. Here are simple ways to implement your gift policy without adding too much friction.

Keep A Simple Gift Register (Even A Spreadsheet)

If your policy includes disclosure, you can maintain a basic register that captures:

date received/given,
who it was from/to,
what it was,
estimated value, and
what decision was made (accepted/shared/returned).

This is often enough to protect your business if questions come up later.

Align Your Gift Policy With Other Business Policies

If you already have policies about privacy, IT use, or workplace conduct, the gift policy should “fit” alongside them.

For example, if your business collects customer data as part of promotions or giveaways, make sure your customer-facing documents (including your Privacy Policy) line up with how you run competitions, marketing, and gift-based campaigns.

Use Consistent Documentation When You’re Giving Gifts As Part Of Promotions

If you gift products, run giveaways, or offer “free bonuses” as part of a marketing offer, you’ll also want to think about consumer law risk.

What you advertise matters. Your pricing and gift claims should be accurate, and your terms should be clear, so customers aren’t misled. Depending on how you run the promotion, there may also be specific rules around trade promotions (including permit requirements in some states/territories) and terms you should publish so customers understand how it works.

If your gifting is linked to sales or product promotions, it can help to sanity-check your approach against the Australian Consumer Law (ACL) and ensure your standard terms don’t create compliance issues. If you’re unsure, it’s worth getting advice specific to your promotion (and separately, tax advice from your accountant on how gifts should be treated in your records).

Don’t Forget About Business Relationships And Authority

Gifts can sometimes intersect with who has authority to bind the business, approve purchases, or negotiate deals.

If you have staff who sign supplier documents, approve expenses, or make commitments on behalf of your business, make sure your internal delegations and processes are clear. Depending on your structure, you might also need other governance documents in place (particularly if you operate as a company).

For example, many companies adopt a Company Constitution to clarify internal governance rules - while your gift policy deals with the “day-to-day” behavioural expectations.

Key Takeaways

A company gift policy gives your small business clear rules for giving and receiving gifts and hospitality, reducing conflicts of interest and awkward situations.
The most useful company gift policy examples are practical: set clear value thresholds, approval steps, and rules for higher-risk situations like supplier selection or tendering.
Transparency is often the simplest protection - a basic gift register and disclosure expectations can prevent bigger problems later.
Your gift policy should align with your broader workplace framework, including your Employment Contract and staff handbook, so expectations are consistent.
If you use gifts as part of marketing or promotions, make sure your customer messaging and terms stay compliant with Australian Consumer Law and your Privacy Policy obligations (and check whether trade promotion rules apply to your specific campaign).

If you’d like help putting together a company gift policy (or updating your employment documents and workplace policies more broadly), you can reach us at 1800 730 617 or team@sprintlaw.com.au for a free, no-obligations chat.

Company Gift Policy Examples And Best Practices In Australia