Gifts & Hospitality Register

What this tool does

CM8-170 is a working gifts and hospitality register. You record each item given or received, who was involved on both sides, what it was worth and what happened to it. The tool tests every entry against thresholds you set yourself, keeps a running annual total for each counterparty, and prints a register a board, an auditor or a client can read without having to ask what any column means.

Everything runs inside this single file. There is no account, no upload and no network request of any kind. That matters here: a gifts register names identifiable employees alongside a judgement about their conduct, and it should not be sitting on a third party's server by accident.

What to record, and when

Record the offer, not only the acceptance. An entry that says a supplier offered something and it was declined is worth more to you than no entry at all — it evidences that the policy works, it shows which counterparties test the boundary, and it is the only way the pattern of offers ever becomes visible. A register containing nothing but accepted items is a register of the easy cases.

Record both directions. What you give is exactly as capable of creating an obligation as what you receive, and it is usually the direction people forget to write down.

• Reference — any scheme you like, as long as it is unique and sequential. Gaps in a sequence are the first thing an auditor looks for.
• Date offered drives the filters, the monthly chart and the year the cumulative total is counted in. Date received or provided is separate, because the gap between the two is often where the approval should have happened.
• Employee, role and department — the role is what tells a reader whether this person could influence a decision. "Procurement manager" and "receptionist" are not the same entry.
• Counterparty organisation and individual — spell the organisation the same way every time. The cumulative total is grouped by that name, ignoring case and surrounding spaces, so "Meridian Facilities" and "Meridian Facilities Group" will be counted as two different counterparties and the total that should have been flagged will not be.
• Description — plainly, what it actually was. "Hospitality" is not a description. "Two places in a shared box at a league fixture, including food and drink" is.

Record it promptly. A register written up at year end from memory is a work of fiction, and it reads like one.

Putting a value on it

Enter what it would have cost you to buy the same thing, not what the giver says it cost them and not the face value printed on a ticket. Where a benefit covered several people, record the value of the part the named employee received; where you genuinely cannot tell, estimate upwards and say so in the description. An under-estimated value is the quietest way to slip past a threshold.

Two categories are consistently under-valued: event places, where the true cost of a hospitality seat is usually a large multiple of the ticket price, and training or conference places, where a waived fee is a benefit even though no money changed hands. Both are in the list of benefit types for that reason.

The three thresholds

All three live on the Settings tab, in your own currency, and nothing is hard-coded. Set them to match your own policy — the defaults are placeholders, not advice.

The approval threshold is the point above which an item needs documented sign-off before it is accepted. The prohibition threshold is the point above which it should not be accepted at all. If your policy has no absolute ceiling, set the prohibition threshold very high rather than leaving it at zero, which would flag everything. If every item needs sign-off however small, set the approval threshold to zero.

Both tests compare a single entry against a single number. That is precisely why they are not enough on their own.

The cumulative total — the number that matters

A register that only checks single-item values will never see the thing it exists to catch. Nobody hands over one large envelope. What happens is a lunch, then another lunch, then a place at a match, then a dinner — every one of them under the approval threshold, every one of them individually defensible, and by the end of the year one supplier has spent a great deal of money on one buyer and everybody involved feels entirely comfortable about it.

So the register keeps a running total. For every entry it adds up the value of everything taken in from that same counterparty, in the same direction, in the same calendar year, up to and including that entry:

Three deliberate choices are worth stating. Declined and returned items are excluded, because nothing passed; they are still flagged in their own right and still appear in the register, but a refused offer does not build up an obligation. Received and given are counted separately, because they are different exposures and adding them together would net one against the other, which is exactly backwards. The running total is cumulative to date, not the whole year, so the entry that pushed a relationship over the threshold is the one flagged, and you can see when it happened rather than having every entry from that counterparty light up at once.

The running total in the register is always calculated from every entry in the file, whatever filter is applied — a filter should never be able to hide a total. The Counterparty summary table on the Reports tab is the opposite: it summarises only what the current filter shows, so that its entry counts agree with the register in front of you. If the two disagree, the filter is the reason.

How the review flag is worked out

An entry is flagged if any one of these is true, and the Review column names every reason that applies:

Entries that were declined or returned are still flagged, prefixed "Not accepted", because the offer itself is information. The colour is red where the item was above the prohibition threshold or involved a public official while officials are set to prohibited, and amber otherwise.

The tiles count the same things. "Above approval threshold" counts every entry worth more than the approval threshold, regardless of what happened to it. "Unapproved entries" counts something different and more uncomfortable:

That is the count of things your organisation is currently holding without a decision having been recorded. It should normally be a small number and it should not stay the same from one month to the next.

Public officials and live tenders

Two checkboxes carry more weight than anything else in the entry form.

Public official should be ticked for anyone exercising public authority — inspectors, licensing and permitting staff, customs and tax officers, and employees of state-owned or state-controlled enterprises, who are frequently caught by rules people assume apply only to civil servants. When the setting "benefits involving a public official are prohibited outright" is ticked, any such entry is flagged whatever it is worth, down to a cup of coffee. Many organisations run exactly that rule because it is the only one that needs no judgement at the moment it is being applied.

Tender or negotiation live should be ticked if any competitive process, renewal, variation or price negotiation with that counterparty was open at the time. Timing is what turns an ordinary courtesy into something that has to be explained, and it is the fact most often left out of the description because at the time it seemed irrelevant.

The tool never refuses to save an entry because it breaches your policy. A register has to be able to record what actually happened, including the things that should not have. It flags them instead.

Outcome and status are different things

Outcome is what physically happened to the benefit: accepted by the individual, declined and never received, returned to the giver, donated to charity, or retained by the organisation. Status is where the approval decision stands: pending, approved, declined by the approver, or escalated.

They are recorded separately because the interesting cases are the ones where they disagree — something accepted while approval is still pending, or kept after an approver refused it. The tool blocks the combinations that are simply data entry errors, such as an approved entry with no approver named, or a declined outcome carrying a date received. It does not block an accepted item with a pending status, because that happens constantly in real life and hiding it would defeat the purpose.

Reading the charts and tables

Value by counterparty ranks counterparties by what was actually taken in, and colours a bar red when that counterparty's largest single-year, single-direction total is above your cumulative threshold. A counterparty whose offers were all declined shows a value of nil and still appears, which is intentional.

Entries by nature of benefit counts entries rather than value, so a single expensive item does not dominate it. Entries by month shows the count with the value taken in underneath; watch for gaps, which usually mean the register stopped being maintained, and for clusters just before a contract award. Value by department shows where the exposure sits — the question is not whether a department is high but whether it is a department that awards contracts or approves invoices.

The Entries requiring review table is the working list: everything flagged, largest value first, with the reason spelled out and the approval status alongside. The Counterparty summary gives, for each counterparty, the number of entries, the value taken in, the largest single entry, the largest year total and how much headroom is left against the cumulative threshold.

What this tool cannot do

It cannot tell you whether something was declared. Everything here depends on somebody choosing to write an entry, and the entries that were never made are the ones that matter most. Treat a register that is suspiciously clean as a finding in itself, and check it against expense claims, diaries and the recollection of the people involved.

It cannot tell you whether a value is honest, whether a description is complete, or whether the person who approved an item was sufficiently independent of the person who received it. It does not know your policy, your contracts, or the law and regulation that apply to you and to your counterparties, all of which differ by country and by sector. It applies only the four settings in this file, and it approves nothing.

Printing and sharing

Print Report produces a report from whatever the current filter shows: header, the six headline figures, the four charts, the review list, the counterparty summary, the full register and your closing notes. Print to PDF to circulate it.

The scope line under the title states the filter in force and the currency. Clear the filters before issuing anything described as the full register, and state the period on the report header, because a cumulative annual threshold means nothing without knowing which year is on the page.

Saving your work

Entries, settings and the report header are written to this browser's local storage as you type, and the toolbar shows the time of the last save. That storage belongs to one browser on one computer: another browser, a private window, a second machine or a clean-up tool that clears site data will not have it.

Treat Export .json as the real save — one file containing everything, which Import .json restores anywhere. Export CSV gives you the register for spreadsheet work and includes every filtered record, not only those drawn on screen. Reset asks twice, then erases everything this tool has stored. There is no undo.

The file names identifiable employees next to a judgement about their conduct, so treat exports as confidential and keep them for as long as your own retention rules require — which for records of this kind is usually years rather than months.

Accuracy & disclaimer

This tool records what you enter and calculates from it. It cannot verify a value, a date, a relationship or an approval, and every figure it produces depends on all four.

Thresholds, prohibitions, approval requirements, reporting duties and retention periods differ by country, by sector and by contract, and the rules that apply to a public official are frequently stricter than those that apply to anyone else. This is an internal record-keeping and calculation aid, not legal or compliance advice, not an approval, and not a substitute for your own policy or for advice on the rules that apply to you.