Gifts and Hospitality
Acceptable limits on gifts, hospitality and travel — approval thresholds and the disclosure register.
Group Policy & Procedure | Document No. | P-POL-012 |
Group Supply Chain | Ver. No. | Rev Date | 0.4 | 08 APR 2026 |
Title: Gifts & Hospitality | Effective Date | 08 April 2026 |
BUKHATIR GROUP
Strength through Diversity
Group Policy and Procedure
Group Supply Chain (GSC)
Gifts & Hospitality
Thresholds, Disclosure & Prohibitions
Document No: P-POL-012
Copyright © 2026 Bukhatir Group
Revision Control
This document is issued under the authority of Bukhatir Group and applies when carrying out the activities described. Revisions may be issued as necessary under the authority of the Group Head of Procurement. Revision history is recorded below with every revised policy.
Revision History
Ver. No. | Effective Date | Description |
|---|---|---|
02 | September 2016 | Original Procurement Policy |
0.3 | March 2026 | Procurement Policy – Gifts & Hospitality |
0.4 | 08 April 2026 | Redesign, content modernization & flowcharts – Gifts & Hospitality |
Revision Sign-Off
Approving Committee | Name | Signature |
|---|---|---|
Endorsed by — Group Head of Supply Chain | Mohamad Koussa | |
Reviewed by — BIIL CEO | Mr. Ayman Ismail | |
Reviewed by — Group Chief Financial Officer | Mohamad Adnaan Sait | |
Approved by — Group Vice Chairman & Group CEO | Mr. Salah Bukhatir |
Distribution List
# | Departments |
|---|---|
1 | Business Unit Procurement Departments |
2 | Group Supply Chain (GSC) |
3 | Finance, Legal, Compliance, Internal Audit |
4 | Business Unit Management |
1. Purpose
This policy defines acceptable limits and disclosure requirements for gifts, hospitality, entertainment and travel offered to or by Bukhatir Group procurement staff, to protect the Group from undue influence, bribery and reputational harm.
2. Scope
Applies to all employees, directors, agents and contractors of the Group in their dealings with suppliers, potential suppliers, customers and other business counterparties.
3. General Principle
TRANSPARENCY & PROPORTIONALITY Gifts and hospitality must be infrequent, modest, transparent, directly related to a legitimate business purpose, and never linked (directly or indirectly) to any procurement decision. |
4. Thresholds
Category | De-Minimis Limit | Approval Required Above Limit |
|---|---|---|
Promotional items (pens, mugs) | AED 100 | N/A — generally permitted |
Gifts received | AED 250 per item / AED 500 per year | Line Manager + Compliance |
Business meals | AED 300 per person | Line Manager |
Events / hospitality | AED 750 per event | Head of Supply Chain + Compliance |
Travel & accommodation | Not permitted | CFO pre-approval mandatory |
Cash or cash equivalents | PROHIBITED | Never |
5. Disclosure
All gifts and hospitality received above the de minimis threshold shall be logged in the Group Gifts & Hospitality Register within 5 working days of receipt. The Register is reviewed monthly by Compliance.
6. Prohibited Circumstances
- During any active tender, evaluation or negotiation.
- From any supplier currently under dispute, investigation or performance review.
- Cash, gift cards or cash-equivalent instruments of any value.
- Any benefit to a family member intended to influence the employee.
7. Reference Form
Form F-GH-01 — Gifts & Hospitality Disclosure Form.
8. Definitions & Acronyms
Acronym / Term | Definition |
|---|---|
AED | United Arab Emirates Dirham |
BU | Business Unit |
COI | Conflict of Interest |
GSC | Group Supply Chain |
UAE | United Arab Emirates |