Hospitality

You're heading to the kitchen when David Mercer catches you in the corridor. Just back from London — suit jacket over one arm, looking relaxed. He mentions it almost as an afterthought.

Alexa — good timing. Quick one. I was at Wimbledon over the weekend. Corporate box, Haldane's invite. Took Jenny from proposals. Spectacular match — Sinner vs. Alcaraz. Anyway, just thought I'd mention it. Should I log it somewhere?

David, the Haldane contract renewal is next week.

Exactly. That's why the relationship matters. Look, this isn't a brown envelope, Alexa. It's tennis. Everyone does it.

Helen, I've logged the Wimbledon hospitality — £5,000 total, accepted during the contract renewal window, no pre-approval. I've drafted a disclosure letter for David to send to Haldane's compliance team.

A letter to their compliance team? That's a bit much, isn't it? We don't want Haldane thinking we're accusing them of anything.

It's not accusatory — it's transparency. We're telling them we received hospitality, we've logged it, and it doesn't influence our commercial relationship. If we don't disclose and someone asks questions later, the silence looks worse than the hospitality.

And if David pushes back?

He will. But this is exactly what our procedures are for. Section 7 holds the company liable if we don't have adequate procedures. We have a policy — we just need to enforce it.

Helen, I've logged the Wimbledon event in the gifts register. £5,000 total, no pre-approval. I've spoken to David about the pre-approval requirement.

Good. And David?

He understands. Says it won't happen again.

Fine. Let's move on.

Alexa, what's your assessment on the Wimbledon thing?

Honestly, Helen, I think it's standard corporate hospitality. David's been doing this for years. The Bribery Act doesn't prohibit reasonable hospitality — the SFO has said as much.

That's reassuring. I didn't want to overreact.

You're right that the Bribery Act doesn't prohibit hospitality. But you've missed the critical word: reasonable. £5,000 of hospitality three days before a procurement decision is not the SFO's definition of reasonable. And by not logging it, you've ensured there's no record that Meridian even knew about it — which is exactly the gap Section 7 was designed to close.

For the record, I think this is disproportionate. But Alexa has a point about the policy.

The combined hospitality with Haldane totals £6,800 during an active contract renewal. Our policy requires board notification above £500. I'm not suggesting anyone acted in bad faith — I'm asking the board to note the disclosure and confirm next steps.

Helen, I won't take it to the board — yet. But I need three things: David sends a written disclosure to Haldane's compliance team, both events get a full compliance review note on file, and David signs a written acknowledgement of the pre-approval policy.

That sounds reasonable. I'll talk to David.

One more thing. If anything similar happens again — with any client — it goes to the board automatically. I need that commitment from you.

Agreed. Let's close this out.

You're right, Helen. I'll keep this at our level. The register entry is there, David knows the policy. I don't think we need to escalate further.

Good call. Sometimes proportionate means knowing when not to make a mountain out of a molehill.

Helen is relieved. The board never learns that £6,800 of hospitality was exchanged with a client during a live £4.2M contract renewal. Your policy says board notification is required above £500. You've now created a documented case where the policy wasn't followed — and the reason was your boss told you not to.

Walk me through this proposal.

Three components. First, a pre-approval form — 90 seconds, auto-routes to compliance, responses within 24 hours. Not a barrier, a checkpoint. Second, annual training with real scenarios. Third, quarterly reporting to the board — aggregate data, trends, anything above threshold.

David's going to hate the form.

David will use the form if it takes 90 seconds and we approve most requests within 24 hours. If David had called me before Wimbledon, we could have approved it with conditions — log it, document the business rationale. He'd have gone to the tennis and we'd have a clean file. Total additional cost: approximately zero. The cost of not doing it is a Section 7 prosecution where we can't demonstrate adequate procedures.

I've updated the register to require pre-approval above £500 and drafted a company-wide reminder. I'll present the policy at the next all-hands.

Sensible. Not too heavy-handed.

The email goes out on Monday. 73% of staff open it. By Friday it's forgotten. Eight months later, another BD manager accepts an invitation to the Emirates Stadium from a contractor bidding on a subcontract. He doesn't pre-approve it — because he didn't read the email either.

I've drafted a note for David's personnel file documenting the policy breach. The policy already covers this — he just didn't follow it.

Fair enough. These things happen.

The note goes into David's file. David never sees it. No one else in the business learns anything from the incident. The pre-approval process remains a paragraph on page 7 of the employee handbook. The gifts register remains a spreadsheet that compliance reviews annually — retroactively, after the events have already happened.