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Client Entertainment Policy Template for England and Wales

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Key Requirements PROMPT example:

Client Entertainment Policy

"Need a Client Entertainment Policy for our UK-based financial services firm that includes strict monetary thresholds and compliance with FCA regulations, with particular focus on cryptocurrency clients and high-value entertainment events."

Document background
The Client Entertainment Policy serves as a comprehensive framework for managing corporate hospitality activities in accordance with English and Welsh law. This document is essential for organizations that engage in client entertainment as part of their business operations, providing clear guidelines on acceptable practices, spending limits, and approval procedures. It ensures compliance with key legislation such as the Bribery Act 2010, tax regulations, and industry-specific requirements while protecting both the company and its employees from legal and reputational risks.
Suggested Sections

1. Purpose and Scope: Defines the policy's objectives and who it applies to

2. Definitions: Key terms used throughout the policy including what constitutes entertainment, client, and business purpose

3. General Principles: Core rules and values governing entertainment including transparency, proportionality, and business purpose requirements

4. Approval Process: Required authorizations and procedures for entertainment requests

5. Monetary Limits: Specific spending thresholds and limits for different types of entertainment

6. Record Keeping: Required documentation and retention requirements for entertainment expenses

7. Compliance Requirements: Legal and regulatory obligations including anti-bribery, tax, and data protection requirements

Optional Sections

1. Industry-Specific Guidelines: Additional rules and requirements for regulated industries such as financial services

2. International Entertainment: Specific rules and considerations for cross-border entertainment activities

3. Virtual Entertainment: Guidelines and procedures for online events and virtual entertainment activities

Suggested Schedules

1. Entertainment Request Form: Standard template for requesting approval for client entertainment

2. Expense Claim Form: Template for submitting and claiming entertainment expenses

3. Approval Matrix: Table showing approval levels and authorities by amount and type of entertainment

4. Country-Specific Limits: Schedule of local monetary thresholds and limits for different jurisdictions

5. Risk Assessment Template: Standard form for evaluating and documenting entertainment-related risks

Authors

Alex Denne

Head of Growth (Open Source Law) @ ¶¶Òõ¶ÌÊÓÆµ | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

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Industries

Bribery Act 2010: Primary legislation governing corporate hospitality and gifts. Requires adequate procedures to prevent bribery and follows Ministry of Justice guidance. Critical for ensuring client entertainment doesn't constitute illegal inducements.

Income Tax Act 2003: Governs tax implications of business entertainment, including treatment of entertainment expenses, distinctions between staff and client entertainment, and associated record-keeping requirements.

VAT Act 1994: Covers VAT treatment of entertainment expenses, input tax recovery rules, and specific record-keeping requirements for entertainment-related expenses.

Financial Conduct Authority (FCA) Rules: Regulatory framework for FCA-regulated companies, covering inducements, recording and reporting obligations related to client entertainment.

Data Protection Act 2018 & UK GDPR: Legislation governing the recording and processing of client data, privacy considerations, and record retention requirements in relation to entertainment activities.

Money Laundering Regulations 2017: Regulations particularly relevant for high-value entertainment, including due diligence requirements and record-keeping obligations to prevent money laundering.

Criminal Finances Act 2017: Contains Corporate Criminal Offence of Failure to Prevent Tax Evasion, ensuring entertainment isn't used as a vehicle for tax evasion.

Companies Act 2006: Defines directors' duties regarding company resources and corporate governance considerations in relation to entertainment spending.

Health and Safety at Work Act 1974: Establishes duty of care requirements during corporate events and necessity for risk assessments for entertainment activities.

Equality Act 2010: Ensures entertainment activities don't discriminate and considers accessibility requirements for all participants.

Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks,  Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination,  Severance Pay, Governing Law, Entire Agreemen

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