Anti-Bribery Policy
Three factors decide whether a gift is acceptable: intention, value, and timing.
Last updated: 28 July 2026The three-factor test
Whether a gift is acceptable depends on three critical factors: intention, value, and timing.
Intention
A gift intended to thank a customer or build goodwill is usually fine. A gift intended to sway a business decision in the giver's favor is prohibited.
Value
There is no fixed universal limit — modest items are typically appropriate, but an expensive vintage champagne warrants closer scrutiny and disclosure.
Timing
A modest gift during seasonal holidays rarely raises concern, but the exact same gift offered during an active tender or bidding process looks very different.
Gift vs. bribe
Giving a gift is a normal way to show appreciation and strengthen a relationship, but the line between a legitimate gift and a bribe can be hard to judge. Both can take the form of cash, physical items, event tickets, or entertainment like dinners and concerts.
Legitimate Gift
Given transparently without expecting anything in return. Its sole purpose is to express appreciation, mark a customary occasion, or strengthen a working relationship.
Prohibited Bribe
Given or offered with the expectation of improper influence, preferential treatment, or a business advantage. Bribery is never limited to cash changing hands.
What counts as an offence
Two conditions typically need to be present:
- The gift is given or offered to influence an official's action or decision.
- The purpose is to obtain or retain a business advantage.
Gifting laws by country
Anti-bribery rules and monetary thresholds for gifts to officials vary significantly by jurisdiction. Use the explorer below to search statutes or filter by region:
United Arab Emirates (UAE)
Penal Code (Decree-Law No. 31/2021) & HR Law No. 49/2023
Public officials are strictly prohibited from soliciting or accepting gifts or hospitality that could influence official duties or create a conflict of interest; federal employees may generally only accept promotional items of nominal value as permitted by institutional regulations.
Australia
Asia-PacificCriminal Code Act 1995 (Cth, Section 141.1)
Offering or providing any benefit to a Commonwealth public official with the intention of influencing their duties is a criminal offence; public officials must generally refuse gifts that could give rise to a real or apparent conflict of interest.
Bangladesh
Asia-PacificPenal Code 1860 & Conduct Rules 1979
Public servants are barred from accepting gifts without government sanction, except customary gifts of trifling value (foreign-government gifts up to Tk 500 / ~USD 4.50 may be retained without surrender).
Brazil
AmericasClean Company Act (Law No. 12,846/2013)
Promising, offering, or giving any undue advantage to a public official is strictly prohibited; the Federal Public Official Code of Conduct (Decree No. 4,081/2001) establishes a de minimis ceiling of 100 BRL (~USD 18) for institutional gifts.
Cambodia
Asia-PacificAnti-Corruption Law (2010, Art. 57–58)
Offering or giving any gift, favor, or advantage to a public official to perform or refrain from their duties constitutes criminal bribery; no statutory de minimis exception exists.
Canada
AmericasCriminal Code (s. 121) & Conflict of Interest Act
Public office holders are prohibited from accepting any gift or advantage that might reasonably be seen to have been given to influence them; gifts exceeding 200 CAD (~USD 145) must be publicly declared.
China
Asia-PacificCriminal Law (Art. 389–390) & AUCL
Offering money or property to state functionaries is a criminal offence; administrative regulations prohibit officials from accepting gifts that could affect impartial official duties, with gifts exceeding 200 RMB (~USD 28) generally deemed inappropriate.
France
EuropeSapin II Law (No. 2016-1691) & Penal Code
Offering any advantage to a public official to act or refrain from acting is corruption; customary business gifts are scrutinized under strict ethical rules and typically should not exceed 150 EUR (~USD 160) per calendar year.
Germany
EuropeGerman Criminal Code (StGB §§ 331–334)
Federal officials are forbidden from accepting gifts, rewards, or favors in relation to official duties without prior official consent; customary promotional items are generally restricted to a de minimis value of 25 EUR (~USD 27).
Hong Kong
Asia-PacificPrevention of Bribery Ordinance (POBO, Cap. 201)
It is an offence to offer an advantage to a public servant without lawful authority; public servants cannot solicit or accept gifts without explicit permission from the Chief Executive.
India
Asia-PacificPrevention of Corruption Act, 1988 (2018 adv.)
Public servants are prohibited from accepting lavish hospitality or gifts from parties with official dealings; gifts on traditional occasions must not exceed 5,000 INR (~USD 60) for Group A/B officers without formal report.
Indonesia
Asia-PacificAnti-Corruption Law (No. 31/1999 & No. 20/2001)
Any gratification given to a civil servant or state official is presumed a bribe if related to their position; recipients must report any gratification to the Corruption Eradication Commission (KPK) within 30 working days to avoid criminal penalties.
Japan
Asia-PacificNational Public Service Ethics Act (1999)
Bribing a public official is illegal; officials at the rank of Assistant Director and above must disclose any gift, hospitality, or remuneration exceeding 5,000 JPY (~USD 35).
Malaysia
Asia-PacificMACC Act 2009 (Section 17A)
Giving or receiving any gratification to influence official acts is an offence; public officers must refuse gifts unless difficult to decline, in which case formal departmental approval is required.
Mexico
AmericasFederal Penal Code (Art. 222) & GLAR (Art. 52)
Public officials are strictly prohibited from soliciting, demanding, or receiving gifts, favors, or services from persons or entities whose commercial activities they regulate or supervise.
Myanmar
Asia-PacificAnti-Corruption Law (2013) & Guideline 1/2016
Public officials are prohibited from accepting gifts; customary gifts up to 25,000 MMK (~USD 12) may be accepted from friends or relatives, but gifts from entities with business ties are strictly forbidden.
New Zealand
Asia-PacificCrimes Act 1961 (s. 99–105) & PSC Standards
Bribing an official is a serious offence; public servants must not accept gifts or hospitality that could compromise their integrity, create an obligation, or exceed nominal agency disclosure thresholds.
Nigeria
AfricaICPC Act 2000 & 5th Schedule of Constitution
Public officers are prohibited from accepting gifts or benefits on account of anything done in the discharge of official duties; only customary gifts of nominal value from personal friends are exempted.
Philippines
Asia-PacificRA 3019 (Anti-Graft) & RA 6713 (Code of Conduct)
Giving or receiving gifts tied to a public officer's duties during any occasion is punishable; only unsolicited gifts of nominal value not given in anticipation of favor are excepted.
Qatar
Middle EastPenal Code (Law No. 11 of 2004, Art. 140–147)
Offering or giving any benefit to a public official to act or refrain from acting in their official capacity is a felony; public officials are barred from accepting gifts that could influence their duties.
Saudi Arabia
Middle EastAnti-Bribery Law (Royal Decree M/36 of 1992)
Public servants are strictly prohibited from soliciting or accepting any gifts, gratuities, or favors in connection with official duties; offering any benefit to influence an official act carries severe criminal penalties.
Singapore
Asia-PacificPrevention of Corruption Act (PCA, Cap. 241)
Giving or receiving any gratification as an inducement is illegal; civil servants cannot retain gifts unless formally declared and approved by a Permanent Secretary, and gifts kept personally must not exceed SGD 50 (~USD 37).
South Africa
AfricaPRECCA (Act 12 of 2004)
Offering or accepting any gratification to influence an official act is a criminal offence; public service regulations require officials to disclose all gifts and hospitality exceeding 350 ZAR (~USD 20).
South Korea
Asia-PacificImproper Solicitation & Graft Act (2016)
Public officials cannot accept gifts over strict statutory limits: generally 50,000 KRW (~USD 36) for gifts and 150,000 KRW (~USD 108) for agricultural/livestock gifts, even without direct relation to duties.
Switzerland
EuropeSwiss Criminal Code (Art. 322ter–322decies)
Federal employees are prohibited from accepting gifts or advantages in connection with their official activities; social gifts of minor value up to 200 CHF (~USD 225) are permitted only if they do not compromise independence.
Thailand
Asia-PacificOrganic Act on Anti-Corruption (B.E. 2561)
Government officials are prohibited from accepting gifts or benefits valued over 3,000 THB (~USD 85) from anyone other than family members on ethical or customary occasions.
United Kingdom
EuropeBribery Act 2010 (Sections 1, 2, and 6)
Corporate hospitality and gifts must be reasonable, proportionate, and transparent; offering gifts or hospitality with the intention of inducing improper conduct or influencing a foreign public official is a criminal offence.
United States
AmericasFCPA (15 U.S.C. § 78dd-1) & 18 U.S.C. § 201
Offering anything of value to influence an official act is illegal; federal executive branch employees are subject to the $20 / $50 rule (gifts under USD 20 per occasion, up to USD 50 annually per source).
Vietnam
Asia-PacificPenal Code (Art. 354 & 364) & Anti-Corruption Law
Public officials are prohibited from accepting gifts in any form from agencies or individuals related to their duties; offering any benefit valued at 2,000,000 VND (~USD 80) or above constitutes criminal bribery.
Reporting a mistake
If you think you've mistakenly violated any of the above, tell us — we'll work with you to put it right.
Emailhello@sugary.me