Templates and records · ISO 26000:2010 · Clause 6.6.3
Gifts, hospitality and conflicts of interest register template
A log of gifts and hospitality given or received above a threshold, and of situations where a personal interest clashes with the company’s.
In one sentence
The gifts and conflicts of interest register logs gifts, invitations and hospitality above the set threshold, who gives or receives them, who authorises them, and conflict of interest declarations with how they were resolved; it is good practice for applying the anti-corruption guidance in clause 6.6.3 of ISO 26000.
- Where the standard requires it
- ISO 26000:2010 · Clause 6.6.3 Clauses are cited using the numbering of ISO 26000:2010, the only edition published. As it is a guidance standard, no template is mandatory: all are listed as good practice.
- Type of information
- Good practice Good practice: ISO 26000 is a guidance standard (clause 6.6.3)
- Who fills it in
- Whoever gives or receives the gift Authorised by their manager or by compliance, depending on the amount
- When
- For every gift above the threshold Conflict of interest declarations on joining and every year
- How long it is kept
- Decided by the organisation As a guidance standard, ISO 26000 sets no retention periods. Keeping several years’ worth lets you show progress over time, which is what stakeholders value most.
What the standard requires
What ISO 26000:2010 demands and what it leaves to your judgement
Under fair operating practices, the guidance recommends identifying corruption risks, implementing anti-corruption policies and practices, training employees and representatives, and encouraging people to report breaches without fear of reprisal.
A gifts register does not prevent corruption on its own, but it makes visible what would otherwise go unnoticed and forces the policy to be applied. SGE 21 expressly calls for criteria on giving and receiving gifts and for ways of detecting conflicts of interest (6.1.9).
Structure
Fields the template should include
- Date, person and department
- Given or received, and counterparty
- Description and estimated value
- Current business relationship with the counterparty
- Authorisation: accepted, declined or returned
- Conflict of interest declaration and action taken
Example
Example: three entries (invented data)
Company, people and figures are fictitious: the example only shows what a properly completed record looks like.
| Field | Content |
|---|---|
| Policy threshold | €50 per gift or invitation; anything above is logged and authorised |
| Received | Christmas hamper from a packaging supplier · €120 · accepted and raffled among staff |
| Invitation | Trade fair trip paid for by a seed supplier, offered to the purchasing manager · declined: a tender is open |
| Conflict of interest | Agronomist whose brother is a partner in an irrigation supplier · steps aside from that contract award |
At the audit
Mistakes auditors commonly flag
- The policy exists, but nobody logs anything.
- There is no threshold and everyone decides for themselves what an acceptable gift is.
- Conflicts of interest are declared once and never updated.
- Invitations received during a tender are not distinguished from the rest.
In Kimobox
How this record is kept in Kimobox
- 1The anti-corruption policy is published as a controlled document, with read receipts.
- 2The management team’s conflict of interest declarations are recorded.
- 3Any related incident is recorded as a nonconformity.
- 4The whistleblowing channel allows breaches to be reported with restricted access.
Frequently asked questions
What people ask us before getting started
What threshold is reasonable?
The guidance does not set one. Many companies use a low amount and ban any gift during an open tender or negotiation. What matters is that the threshold is written down and applied.
Is it the same as a compliance system?
It is one piece of it. A compliance management system, such as one based on ISO 37301, covers risk assessment, controls, training and investigation; the gifts register is one of those controls.
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Sources
Where each figure comes from
References to the official text in force. If a standard is revised, this page is updated and the review date says so.
- ISO 26000:2010 — Guidance on social responsibility ISO · 2010 ed.
- SGE 21. Sistema de Gestión Ética, Sostenible y Responsable (Ethical, Sustainable and Responsible Management System) Forética · October 2024 version