Is it a conflict of interest if my spouse’s company is a vendor?

Yes — it can be a conflict of interest. If your spouse works for a company that does business with your employer, the relationship could influence, or appear to influence, business decisions and must be disclosed.

Short Scenario (1:16): Watch how a technology leader navigates an anti-corruption dilemma when a vendor offers ‘lavish’ tablet computers during a contract renewal process. This real-world scenario demonstrates the clear line between a business courtesy and an improper kickback.

EMPLOYEE QUESTION

The service contract for our network maintenance provider, MEGA-SECURE, is up for renewal. In accordance with our guidelines, we need to make a recommendation to re-negotiate by opening the tender process to other providers.

MEGA-SECURE contacted our Technology team and proposed that in order to retain the contract, they will maintain the service fees for the next 3 years. In addition, they will throw in the latest tablet computers for each of the management team as an added incentive. These tablet computers are given as a personal gift to the management committee as a thank you from MEGA-SECURE for their unwavering support.

Is there anything wrong with accepting the tablet computers?

FEEDBACK
Bribes do not necessarily have to involve cash to be considered a criminal act or to breach Company policies. In this case, the tablet computers may be considered as “payment” for allowing MEGA-SECURE to retain the contract.

Additionally, the tablet computers may be considered excessive or “lavish” and definitely fall outside of the money threshold for acceptable business gifts.

The Technology Head should decline the MEGA-SECURE offer and proceed with the open renewal.

What Policies and Laws Typically Apply

Most companies prohibit offering anything of value that could influence, or appear to influence, a business decision.

This scenario is commonly governed by:

When gifts are given during negotiations or renewals, scrutiny is significantly higher.

Top Frequently Asked Questions (FAQs)

Do bribes have to involve cash?

  • No. A bribe can be anything of value, including electronics, travel, jewelry, or even job offers for a family member.

  • In this scenario, the tablets are viewed as a “payment” to retain a contrac

What is considered a “lavish” or “excessive” gift?

  • Any gift that exceeds the company’s specific money threshold for acceptable business courtesies.

  • High-end electronics almost always fall into the “lavish” category and are prohibited.

Can giving a gift put the other company’s employee at risk?

Yes. Many organizations have strict gift limits, and receiving expensive items could put the recipient in violation of their policies, potentially jeopardizing their employment. Responsible business relationships consider both sides’ compliance obligations.

If a vendor offers a high-value gift during a contract talk, what should I do?

  • You must decline the offer immediately.

  • You should proceed with an open and transparent renewal process.

  • Report the offer to your Legal or Compliance department to ensure the integrity of the bidding process.

What counts as a bribe under anti-corruption rules?

A bribe is anything of value offered or given to influence a business decision. This can include cash, gifts, travel, entertainment, or expensive items such as electronics — especially when provided during negotiations or renewals.

  • Value is not limited to cash

  • Timing and intent are critical factors

  • Appearance of influence matters

Does intent matter if the gift is meant as a goodwill gesture?

Intent alone does not eliminate risk. Even goodwill gifts can be considered improper if they coincide with business decisions or exceed policy limits.

Employees should focus on how the gift could be perceived by others.

What should I do if a vendor or partner offers a high-value gift?

Employees should not accept high-value gifts without review. The safest approach is to disclose the offer to Compliance or Legal and follow company guidance before taking any action.

  • Do not accept first, ask later

  • Disclosure protects both you and the company

  • Declining may be required

Are promotional or branded items treated differently?

Low-value promotional items may be allowed if they are modest, widely distributed, and not tied to business decisions. High-value electronics or personalized items typically do not qualify as acceptable promotional gifts.

How to use Compliance Scenarios in your Training Program

Don’t just teach your Anti-Bribery and Anti-Corruption policy once. Xcelus recommends that three days after your core training, you ‘push’ this Tablet ‘bribe’ scenario to learners. This resets the forgetting curve and creates the ‘stickiness’ needed to turn abstract rules into long-term retention. By moving from a once-a-year event to periodic, real-world reinforcement, you ensure the training actually sticks when it matters most.

Build Your Custom Training Campaign

Looking for more real-world compliance scenarios? Browse our library of high-impact, mobile-first dilemmas covering Anti-Bribery, Harassment, Conflicts of Interest, and anti-corruption rules. Our scenario bursts are designed to bridge the gap between policy and behavior, ensuring your training sticks long after the initial course.