Publications in sectors such as pharma and financial services are warning companies to consider the need for hospitality audits as a recent article in the Daily Telegraph newspaper also suggested.
The difficulty stems from the interpretation of the act because an offence (both giver and recipient are liable to prosecution) is committed if "intended to obtain or retain business or a business advantage". One might reasonably assume that all corporate hospitality fits this description so could fall within the bribery definition.
However, a House of Lords clarification (?) says “most routine and inexpensive hospitality would be unlikely to lead to a reasonable expectation of improper conduct”.
I get the feeling that this will hang in the air until there is a relevant prosecution. In the meantime my guess is that the wise will be a little more cautious of the high profile golf resort hotel for their meetings and education events. My advice (as you might guess) is to stick to high quality, good value dedicated venues like Sundial.
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