During February and March of 2009 the Society of Corporate Compliance and Ethics (SCCE) and the Health Care Compliance Association (HCCA) jointly fielded a survey among the compliance community. The goal was to determine the level of acceptable business entertainment and gift giving.

The 2009 survey revealed that, on the whole, business is fairly restrictive of the gifts employees can give and receive, as well as how they can entertain. About two-thirds (63%) either ban gifts to employees or require that they be modest or at a price less than $50.

To determine if gift-giving and entertainment policies had changed in the intervening three years, SCCE and HCCA fielded the research again in June 2012. The results showed a surprisingly unchanged picture, despite increased scrutiny of corporate behavior, Dodd-Frank, the UK Bribery Act, and ongoing FCPA enforcement.

Most organizations have restrictive policies, with healthcare leading the way. In addition, non-profits were generally more restrictive than for profits, and publicly traded companies, interestingly, had the least restrictive policies.

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