Gift and Hospitality Policy (UAE)

A Gift and Hospitality Policy in the United Arab Emirates is a formal anti-bribery compliance document that defines acceptable limits for giving and receiving gifts, hospitality, and entertainment in a business context, and establishes the procedures for disclosing and approving gifts that exceed defined thresholds. The policy is a key component of a company's anti-bribery programme under the UAE Penal Code — Federal Decree-Law No. 31 of 2021.

Bribery in the UAE is not limited to cash payments. The UAE Penal Code criminalises any 'advantage' offered, promised, or given with the purpose of improperly influencing the conduct of a government official or a private sector employee. An 'advantage' includes gifts, hospitality, entertainment, favours, employment offers, loans, and any other benefit of value. The criminal standard applies regardless of the value of the benefit — there is no minimum amount below which a benefit cannot legally constitute a bribe. The key question is always whether the benefit was offered or received with an improper purpose.

The practical challenge for UAE companies is that gift-giving is a deeply embedded cultural custom in the UAE and the broader Gulf Cooperation Council region. Exchanging gifts during Ramadan, Eid Al Fitr, Eid Al Adha, and UAE National Day is expected by business contacts. Corporate hospitality — business meals, entertainment at sporting events, and cultural experiences — is a normal part of relationship-building. A Gift and Hospitality Policy allows a company to participate appropriately in these customs while maintaining the controls that prevent gift-giving from crossing into corruption.

For companies with connections to the United Kingdom, the UK Bribery Act 2010 imposes additional extra-territorial obligations. Under the Bribery Act, a UK-connected company that fails to prevent bribery by its associated persons — including UAE employees and agents — faces a strict liability offence, and one of the key defences is demonstrating 'adequate procedures', of which a Gift and Hospitality Policy is a central element. The French Sapin II Law and the US Foreign Corrupt Practices Act (FCPA) impose similar extra-territorial requirements on French and US-connected companies operating in the UAE.

The forms-legal.com Gift and Hospitality Policy (UAE) template provides a practical, clearly structured policy with customisable AED thresholds, absolute prohibitions, gifts register requirements, and compliance officer oversight, available in PDF and Word format.

A Gift and Hospitality Policy is needed for UAE companies in the following circumstances.

Any company that regularly interacts with UAE government authorities — applying for permits, licences, or approvals from the Department of Economic Development, Ministry of Economy, Ministry of Human Resources and Emiratisation (MOHRE), Federal Tax Authority, Dubai Land Department, Securities and Commodities Authority, or similar bodies — faces bribery risk from the giving or receiving of gifts in connection with those interactions. A policy that clearly prohibits gifts to government officials and provides a reporting channel for solicitation approaches is essential.

Companies in commercial sectors where business relationships are cultivated through hospitality — financial services, real estate, construction, hospitality, and professional services — face the greatest practical risk that hospitality expenditure will be characterised as a bribe. Clear hospitality thresholds and approval procedures protect both the company and its employees.

Companies with UK, US, French, or other international connections whose anti-bribery laws apply extra-territorially need a UAE Gift and Hospitality Policy as part of their 'adequate procedures' defence under those laws. UK companies and their UAE subsidiaries and joint ventures are subject to the Bribery Act 2010.

Listed companies on the ADX or DFM are required by the SCA Corporate Governance Code to have anti-corruption frameworks including gift and hospitality policies. The SCA ESG Disclosure Guidance requires disclosure of anti-bribery programme elements.

DNFBPs regulated by the Ministry of Economy for AML purposes should have a Gift and Hospitality Policy as part of their anti-bribery and AML-CTF compliance programme, demonstrating to Ministry inspectors that corruption risk controls are in place.

A complete UAE Gift and Hospitality Policy must contain the following elements to provide effective anti-bribery protection.

Absolute prohibitions: Unambiguous rules that apply regardless of circumstances — zero gifts to government officials or public officers; no cash or cash-equivalent gifts; no gifts during active procurement, negotiation, or tender processes; no gifts intended to influence a business decision. These prohibitions must be stated clearly and prominently so that employees encountering a borderline situation know the rules.

Thresholds for private sector gifts: A specific monetary threshold — stated in AED — below which modest private sector gifts may be accepted without prior approval, and above which disclosure to the Compliance Officer and approval is required. A threshold in the range of AED 150-500 per source per calendar year is typical for UAE companies. The threshold should apply per calendar year, not per occasion, to prevent cumulative gifting from exceeding acceptable levels.

Hospitality thresholds: A separate threshold for hospitality — meals, entertainment, and events — per occasion. Amounts above the threshold require prior approval. Government official hospitality is absolutely prohibited.

Gifts register: A formal register maintained by the Compliance Officer recording all gifts and hospitality above the threshold — date, nature, approximate value, giver/recipient, business relationship, and approval decision. The register is the primary evidence of the company's compliance programme.

Disclosure and approval procedure: A specific, accessible process for employees to disclose gifts received and seek approval for hospitality above threshold, with a specified disclosure timeline — typically five working days.

Non-retaliation: Employees who report a solicitation for a bribe or refuse a gift that violates the policy must be protected from adverse consequences. The forms-legal.com Gift and Hospitality Policy (UAE) template includes all required elements with customisable AED thresholds and a forms-legal.com-branded compliance register reference.

Completing the Gift and Hospitality Policy for a UAE company begins with entering the company's full registered name, emirate, and effective date.

Set the gift threshold for private sector gifts. Enter the maximum value of a gift that may be accepted from any single private sector source per calendar year without prior approval. Typical values range from AED 150 to AED 500. Consider the company's industry, the nature of its customer and supplier relationships, and whether the company has international partners whose own anti-bribery frameworks — such as the UK Bribery Act 2010 — impose strict standards. A lower threshold provides greater protection but requires more administrative disclosure activity. The threshold should apply per source per calendar year, not per individual gift or occasion.

Set the hospitality threshold. Enter the maximum value of hospitality — a business meal, entertainment event, or similar experience — per occasion that may be offered or accepted without prior approval. Typical values range from AED 300 to AED 750 per occasion. Apply the absolute prohibition on hospitality for government officials regardless of this threshold.

Designate the Compliance Officer. Enter the name and title of the person who will receive gift disclosures, maintain the gifts register, make approval decisions, and report on gift and hospitality activity to senior management. This should be a senior person with adequate authority and access to senior management.

After completing the wizard, obtain board or general manager approval for the policy. Distribute the policy to all employees, contractors, and agents — particularly those who interact with government authorities or who manage procurement, sales, and business development. Provide training on the policy, with specific scenarios illustrating what is and is not permitted. Establish the gifts and hospitality register as an accessible document that the Compliance Officer updates promptly. Review the policy annually to ensure thresholds remain appropriate.

Legal requirements for a UAE Gift and Hospitality Policy arise primarily from the UAE Penal Code, Federal Decree-Law No. 31 of 2021.

Articles 234 to 241 of the Penal Code address bribery of public officials. Article 234 provides that a public official who solicits or accepts a gift, benefit, or promise in connection with their functions faces imprisonment of up to ten years. Article 239 provides that a person who offers or promises a bribe to a public official faces imprisonment of up to five years. 'Public official' is broadly defined to include employees of the UAE federal government, emirate governments, government-owned entities, and regulatory authorities. There is no minimum value threshold — any gift offered in connection with an official's functions can constitute a bribe. Articles 236 and 237 address private sector bribery — offering or accepting a benefit to induce a private sector employee to breach their duties — with imprisonment and fines.

The Anti-Money Laundering Law, Federal Decree-Law No. 20 of 2018, designates bribery as a predicate offence for money laundering. Companies that benefit from bribery may face AML liability in addition to the underlying bribery offence.

For listed companies, the SCA Corporate Governance Code requires anti-bribery controls including gift and hospitality policies. The DIFC Regulatory Law and the ADGM Financial Services and Markets Regulations require financial services firms in those zones to have anti-corruption frameworks. The UK Bribery Act 2010 requires 'adequate procedures' from UK-connected companies, of which a Gift and Hospitality Policy is one key element.

For companies that are DNFBPs supervised by the Ministry of Economy for AML purposes, a Gift and Hospitality Policy that addresses the risk of improper benefits being offered in connection with AML-CTF regulated activities — such as real estate transactions, corporate service provision, or audit and accounting — demonstrates the compliance culture that Ministry inspectors look for. The UAE's National Anti-Money Laundering Committee standards expect DNFBPs to have documented anti-corruption controls as part of their AML-CTF programme.

Common mistakes in UAE Gift and Hospitality Policies include the following.

Setting the gift threshold too high — or failing to set a threshold at all — provides employees with no meaningful guidance on what is acceptable and leaves the company exposed to cumulative gifting patterns that collectively amount to improper inducement. A threshold of AED 1,000 per gift in an industry where a single vendor relationship generates millions of dirhams in annual business provides essentially no protection. The threshold must be set at a level that reflects the company's actual risk profile and the nature of its counterparty relationships.

Failing to apply an absolute prohibition on gifts to government officials is the most dangerous gap. Some policies permit 'nominal' or 'token' gifts to officials, creating confusion and legal risk. UAE government entities — including the Ministry of Economy, the Department of Economic Development, MOHRE, the Federal Tax Authority, the Dubai Land Department, and the Securities and Commodities Authority — typically have their own internal codes of conduct prohibiting officials from accepting any gift, and offering a gift to an official, even a small one, creates legal risk for both the giver and the recipient under Articles 234 to 239 of the UAE Penal Code Federal Decree-Law No. 31 of 2021. The prohibition must be absolute and clearly communicated to all employees who interact with government authorities.

Omitting hospitality from the policy scope — addressing only physical gifts but not business meals, entertainment events, cultural activities, or sponsored travel — leaves a significant gap. In practice, lavish hospitality is a more frequent vehicle for improper inducement than physical gifts in the UAE, particularly in financial services, construction, and real estate. A business meal at a high-end Dubai restaurant for AED 2,000 per head, sponsored by a vendor during an active procurement process, creates exactly the bribery risk that the policy must prevent. The policy must address hospitality with the same rigour as gifts.

Having a gifts register but not actually maintaining it means the register provides no compliance value. A register that is not updated when gifts are received or given, contains incomplete information, or is never reviewed by senior management is evidence of compliance theatre. The Compliance Officer must maintain the register as a live, accurate record, follow up on overdue disclosures, and report the register's contents to senior management at least annually. The register is primary evidence of the company's compliance programme if it is ever reviewed by a regulator or in a legal dispute.