The following policy is intended to provide guidance and clarification to all employees on what is and what is not acceptable with respect to the giving and receiving of gifts and hospitality, especially in light of bribery and corruption.
The Criminal Justice (Corruption Offences) Act 2018 covers the criminal law relating to bribery and the penalties for committing a crime under the Act range from a maximum of 10 years imprisonment to an unlimited fine.
It is not the intention of this policy to prohibit the giving or receipt of normal, reasonable and appropriate hospitality and gifts aimed at maintaining and building good relationships with customers and suppliers. The giving and /or receiving of hospitality and gifts is only acceptable if certain conditions are met.
When is it acceptable to offer or receive gifts & hospitality?
The following tests should always be applied when deciding whether a gift or hospitality is appropriate, and reasonable:
The offer of the hospitality or gift is not made with the intention of influencing a third party to obtain or retain business, to gain business advantage, or in exchange for favour or benefit.
The offer of the hospitality or gift is legal.
The offer is made in the company name and not in personal name.
The offer is not given as cash or in cash value, e.g. gift cards, vouchers, loans, shares.
The offer is appropriate to the circumstances, e.g. a ‘token’ gift at Christmas.
Taking into account the reason for the offer, it is of an appropriate type and value, and given at an appropriate time.
The offer is made openly and not in secret.
The offer should not have political connotations or influence.
If the above tests are not passed, the offer must be rejected or not made.
When is it not acceptable to offer or receive gifts & hospitality?
Never offer any gift or hospitality with the expectation, hope or intention that either a business advantage will be received (by DPD Ireland) or a personal advantage, or to reward any advantage already received.
Never accept from a third party any gift or hospitality that you know (or suspect) is offered with the expectation that it will obtain a business or personal advantage for that third party from DPD Ireland.
Never solicit (in the capacity of a DPD Ireland employee) personal benefits (including discounts) from suppliers and customers, in any circumstances.
Never accept personal benefits which are intended to influence the decision making of the recipient arising as a result of their position within DPD Ireland (even if the personal benefit in question falls within the allowable gifts and hospitality as outlined within this policy).
Process for the acceptance of hospitality and business gifts
Modest and infrequent hospitality and gifts from suppliers or customers (e.g. meals, attendance at theatre/music/sports events, wine, hampers, chocolates) is an accepted courtesy of a business relationship, but it must be authorised by the Board of Directors.
In all cases and irrespective of the value, the offer must be properly declared by the recipient by completing the Gifts and Hospitality Declaration Form. Information submitted via the declaration form will go to the Board of Directors for review.
The ‘Gifts and Hospitality Register’, which is managed and controlled by the Compliance Manager, will be updated with the outcome of the Directors review.
Should a gift or hospitality from a supplier or customer exceed the value of €500, it should be politely refused. However this offer must also be properly declared and recorded as declined by using the ‘Gifts and Hospitality Declaration Form’.
All hospitality or gifts from suppliers and customers which would be considered over and above the usual course of business (e.g. holidays, short breaks, overseas travel, watches/jewellery, paintings, electronic equipment, transport upgrade, luxurious clothing etc.), or is disproportionate to the type of business dealing to which it relates, must be politely refused.
Hospitality and gifts of any sort should not be accepted during tender or contractual negotiations.
All gifts given by suppliers and customers during the Christmas period are to be handed to the People Team; The People Team will ensure all items are declared using the Gifts & Hospitality Declaration Form and subsequently redistributed by the company.
If you are unsure whether an offer is acceptable, you should consult the Compliance Manager, DPD Ireland Ethics Officer, or Chief Compliance Officer (CCO) for advice.
If a gift is sent unsolicited, and for whatever reason cannot be returned to the sender, the item must be:
Properly declared (as described above).
Raffled within the business and the funds donated to charity.
Under no circumstances should you actively solicit a gift or corporate hospitality.
Providing hospitality and business gifts to suppliers and customers
Hospitality (attendance at theatre/music/sports events) or gifts offered to suppliers and customers must be authorised by the Board of Directors in advance of making the offer.
In all cases irrespective of the value, the Gifts and Hospitality Declaration Form must be completed by the employee wishing to offer hospitality or a gift, and submitted to the Board of Directors for review.
The ‘Gifts and Hospitality Register’, which is managed and controlled by the Compliance Manager, will be updated with the outcome of the Directors review.
Each year at Christmas time the business sends out hampers/champagne to its largest customers. As this is done with full knowledge of the Board of Directors, these gifts are exempt from the above mentioned rules.
In offering hospitality or gifts, the DPD employee should not be seen to be deliberately trying to influence the judgement or impartiality of the customer (the DPD image/brand should be preserved at all times).
No hospitality or gifts should be offered to suppliers or customers which a reasonable person would consider over and above the usual course of business (i.e. holidays, short breaks, overseas travel, watches/jewellery, money, transport upgrade, paintings, electronic equipment, luxurious clothing etc), or, is disproportionate to the type of business dealing to which it relates, or, is likely to offend.
Hospitality or gifts of any sort should not be offered during tender or contractual negotiations (approved DPD Group and DPD Ireland marketing gifts such as umbrellas, keyrings, mouse mats, pens etc. are excluded from this, and can be given to customers in this instance.)
Application of the policy
This policy will be audited on an annual basis to ensure the correct rules have been applied. This will include contacting third parties such as customers and suppliers to reconcile records. For further details, contact the Compliance Manager.
Any employee who has failed to comply with the policy will be subject to disciplinary action.
How to raise concerns
You are encouraged to raise any concerns you have regarding the giving and /or receiving of hospitality and gifts (either concerning yourself or others). This should be done at the earliest possible opportunity, either through:
Bringing it to the attention of your Supervisor or Manager.
Contacting a Senior Manager or Head of Department.
Contacting the DPD Ireland Ethics Officer.
Contacting the Compliance Manager.
Contacting the Chief Compliance Officer (CCO).
Raising an alert via the the confidential DPD Ireland whistleblowing hotline:
Safecall - 24 hours a day / 365 days a year.
Telephone on 1800 812 740.
Dedicated portal www.safecall.co.uk/report.
CG Doc No 4 Issue 3.0
Issue Date: 24th November 2025
Next Review Date: November 2028
Reviewed by: Steven Thacker, Ethics Officer
Approved by: Patricia Lennon, Chief Compliance Officer