How to write a practical corporate gifting policy
What should a corporate gifting policy actually cover?
Four things: who can give and receive gifts, how much can be spent, who approves each gift and what gets recorded. A policy that states those rules in one page removes the judgement calls that make gifting inconsistent, and it protects the business when a client or an auditor asks how gifts are handled.
Most businesses give gifts long before they write the rules down. A sales manager sends bottles to a client, HR sends notebooks to new starters, and nobody records either. The result is uneven spending, missed tax treatment and a compliance question nobody can answer in writing. A corporate gifting policy fixes that by setting thresholds, an approval chain and a register that anyone can follow. This guide sets out what to include, how to write the thresholds so they match UK tax rules, and how to keep the whole thing to one page. For the programme side, such as which employee moments deserve a gift and how budgets are planned, how to build an employee gifting strategy covers the design work that sits above the policy.
TL;DR
- A practical gifting policy sets scope, spend limits, an approval chain and a gift register in one page.
- Write spend limits against the HMRC trivial benefit exemption of £50 per gift, so most gifts stay tax free by design.
- Cover outbound gifts and inbound gifts such as supplier hospitality, which most policies forget.
- Require evidence for any sustainability claim made about a gift, not just a green label.
Why write the policy down at all
A policy does three jobs that goodwill cannot. It makes gifting consistent, so two employees in equivalent situations receive equivalent treatment whoever their manager is. It makes the spend visible, because finance can see planned gift costs across the year instead of discovering them on expense claims. And it protects recipients, because a gift that arrives with no stated purpose reads as an obligation rather than a thank you.
The written form matters more than the length. A one page policy that managers actually read beats a twelve page document nobody opens. Everything below can fit on one page.
The six sections a one page policy needs
1. Scope
State who the policy covers and in both directions. Most policies only cover gifts the company gives. The rules should also cover gifts received: supplier hospitality, client Christmas hampers, event tickets. If a supplier covers the cost of a team lunch, that is a gift under most policies and it belongs in the register.
2. Spend limits
Set one limit per person per gift and one annual figure. The natural anchor in the UK is the HMRC trivial benefit exemption: a non cash gift costing £50 or less can sit outside tax and reporting, provided it is not contractual and not a reward for performance. Writing the internal limit at or under £50 keeps the ordinary gift tax free by design rather than by exception.
3. Approval chain
Name who approves what. A workable default is a line manager for gifts under £25, a department head for £25 to £50, and finance plus a director for anything above. The chain exists to answer one question before the order is placed: does this gift have a clear business purpose and a named reason.
4. Acceptance rules
State what recipients can accept and what must be declined or declared. A common standard is that gifts from suppliers or prospects above a set value are declared to the line manager and recorded, and anything that could influence a live tender is declined. Publishing the rule removes the awkward conversation at the moment a hamper arrives.
5. The gift register
One record, one owner. The register logs the date, the giver or receiver, the item, the value and the reason. It takes minutes per entry and it is the document that answers the compliance question in one email. A shared spreadsheet is enough at most sizes.
6. Sourcing standards
State what evidence a gift must carry before it can be ordered. This is where the sustainability claim is either defended or invented. Require the same test for every item: a named material, a certification that can be checked, and packaging that matches the claim. Every product sold by the ethical gift box carries verified sourcing evidence, which gives a policy writer a concrete benchmark to copy.
Write the limits against the tax rules
The £50 trivial benefit exemption applies per gift, per person, per tax year, so the condition a policy checks is the value of each individual gift rather than the annual budget. Three rules keep gifts inside it:
- Keep the standard gift limit at or under £50 including packaging.
- Treat a run of gifts to the same person, such as monthly drops, as separate events only when they genuinely are; otherwise aggregate them.
- Pass anything above the limit to finance for a tax decision before it is promised to the recipient.
A concrete example of the failure mode: a marketing lead at a 35 person firm approved a £60 hamper for a departing client contact without checking, and finance had to process it as a taxable benefit weeks after the fact. The policy limit and the approval chain both existed on paper; nobody had connected the purchase order to them.
A worked example
A 40 person engineering consultancy rewrote its gifting approach as a one page policy in an afternoon. Scope covered outbound client gifts and inbound supplier hospitality. The spend limit was set at £50 per gift with a two tier approval chain. A shared register spreadsheet went live with five columns and one owner in operations. The first quarter produced 23 logged gifts, one declined supplier weekend, and zero expense claim surprises. The operations lead described the change simply: before the policy, gifting decisions lived in individual inboxes; after it, they lived in one document anyone could check.
The policy also fixed what was being given. The team replaced ad hoc branded items with a small approved list, and one item on it is the A5 Recycled Kraft Notebook, a kraft cover notebook with 144 pages of 70gsm recycled cream paper, an elastic band and a bookmark ribbon, co-branded with the company logo at no extra cost. At £6.95 it sits far inside the £50 limit for any recipient, it is useful enough to stay on a desk, and the recycled paper claim is stated on the listing rather than implied.
Common mistakes when writing a gifting policy
- Covering only outbound gifts. Supplier hospitality and client hampers received are the side most policies miss, and the side most likely to raise a compliance question.
- No register owner. A register nobody owns stops being updated within a month.
- Limits written without checking the tax rules. A £75 limit hands every gift above £50 to finance as a problem.
- Approval chains with three tiers for a £10 item. Friction kills compliance faster than generosity does; keep small gifts fast.
- Sustainability claims with no evidence rule. If the policy does not say what evidence a claim must carry, the claim will be whatever the supplier says.
FAQ
What should a corporate gifting policy include?
Scope covering gifts given and received, spend limits per gift, an approval chain, acceptance and declaration rules, a gift register with a named owner, and sourcing standards that state what evidence a sustainability claim must carry.
Is there a tax free limit for corporate gifts in the UK?
A non cash gift costing £50 or less can qualify as a trivial benefit when it is not contractual and not a reward for work or performance. The exemption applies per gift and per person, so finance should confirm the treatment before the policy publishes its limits.
Should a gifting policy cover gifts employees receive?
Yes. Supplier hospitality, client hampers and event invitations all belong in the policy, with a declaration threshold and a rule for anything that could influence a live commercial decision.
Who should own the corporate gifting policy?
A single owner in HR, finance or operations should hold the policy and the register, with named approvers at each spend tier. Shared ownership without a named owner is the most common reason a policy goes stale.
How much should a company spend per gift?
Most businesses set an internal limit at or under £50 per gift to stay aligned with the trivial benefit exemption, with tiered approval for anything above it. Useful, durable items in the £5 to £25 range carry most recognition moments without approaching the limit.
How often should a gifting policy be reviewed?
Once a year is enough for most businesses, ideally alongside the budget cycle. The review checks spend against limits, register completeness and whether the approved gift list still suits the recipients.
One last thing
A gifting policy earns its keep the first time somebody answers a supplier gift question from the register instead of from memory. If that document does not exist yet, it is a one hour job to create.
Related guides
- How to build an employee gifting strategy
- What is sustainable corporate gifting?
- What makes promotional merchandise sustainable?
If a gifting policy is on your list before the next budget round, list the recipient groups, the spend limits you plan to set and who will own the register. Contact the ethical gift box with those details, and the team can suggest verified gift options that sit inside the limits and confirm co-branding minimums.