Gifts, hospitality and commission-requests register

Keep this on the yacht, in the office or in a shared spreadsheet. It protects you if anyone ever asks. It shows an owner, a manager or an auditor that you take the rules seriously. It also lets you see patterns: who asks, how often, and for what.

How to use it

1. Log everything above the trivial. Every gift, meal, trip, sample, discount, favour or request for commission, given or received, accepted or declined, goes in. If you are not sure whether to log it, log it.
2. Log it within five working days, or the same day if it was a request for money, a threat, or a repeated approach.
3. Say who, what, when and why. Names are best. If you prefer, give the role and organisation.
4. Say what you did: declined, declined and reported, accepted and handed over, or accepted with approval.
5. Keep any message, email or document and refer to it in the notes.
6. Review it with your captain, manager or compliance lead at least every three months, and sign each review.

Template

Date	Direction (offered to us / by us, requested of us / by us)	Person (name, or role) and organisation	What, and approximate value	Connected to an order, quote or decision? (Y/N, which)	What I did	Approved or reported to	Notes and documents
					Declined / Declined and reported / Accepted and handed over / Accepted with approval

Quarterly review

Date	Reviewed by	Patterns noticed	Action taken	Next review

Rules of thumb

• Anything connected to an order is not a gift. It is a risk. Decline it.
• A request for commission is also an entry. A request is not a good business reason to change your behaviour. It is a fact to record.
• Low-value courtesies, such as a coffee at a meeting, are normal. Log them anyway if you are unsure.
• If it makes you uncomfortable, write it down and tell someone. The next person asked may not say no.

General information, not legal advice.