Comprehensive Disclosure Form for High-Value Gifts, Travel & Entertainment from External Parties

Employee Full Name

Employee ID Number

Job Title

Department/Business Unit

Direct Manager's Full Name

Employee Corporate Email Address

Employee Contact Phone Number

Primary Work Location/Office

Length of Service at Company (in years)

Is this your first disclosure submission?

Please confirm you have reviewed the Corporate Ethics Policy and understand disclosure requirements:

How many disclosures have you submitted in the past 12 months?

Do you have financial signing authority or procurement decision-making power?

What is your authorized signing limit?

What is your level of involvement in procurement or vendor management?

Describe your decision-making authority:

Describe how you influence decisions:

Specify your involvement:

External Party Primary Contact Full Name

External Party Organization Legal Name

Organization Type

Organization Industry Sector

Relationship Duration with Organization

Nature of Current Business Relationship (select all that apply)

Approximate Annual Contract Value (if applicable)

Is this organization classified as a strategic account?

Have you received any gifts, travel, or entertainment from this party in the last 12 months?

Provide details of previous disclosures (dates, types, values):

Have you given any gifts, travel, or entertainment to this party in the last 12 months?

Provide details of what was given and business justification:

Do you have any personal relationship (friendship, family, former colleague) with any representative of this organization?

Describe the nature and extent of the personal relationship:

Are there any family members employed by or serving on the board of this organization?

Provide details of family connection and role:

Type of Disclosure

Describe the physical gift in detail (brand, model, specifications):

Specify cash amount or gift card value and vendor:

Describe domestic travel purpose and destinations:

Describe international travel purpose and countries visited:

Describe entertainment event (venue, performers, activity):

Describe each component of the combination:

Specify the type of disclosure:

Status of the Gift/Travel/Entertainment

Explain why you declined and how you communicated this:

Specify what was accepted vs declined and rationale:

Date the gift/travel/entertainment was offered

Date the gift/travel/entertainment was received/accepted (if different)

Time of event (if applicable)

Location/Venue Name

Was this a group event involving multiple employees?

How many company employees attended or were invited?

Number of external party representatives involved

Detailed Cost Breakdown & Valuation

Have you attached supporting documentation (receipts, invitations, itineraries)?

Upload supporting documents (PDF, DOC, XLS, etc.):

Explain why documentation is unavailable:

Can you provide visual documentation (photos, screenshots)?

Upload relevant images:

Was alcohol served or consumed during this event?

Describe the context and quantity:

Did this occur during a recognized holiday season or cultural celebration?

Specify the occasion:

Describe the business context in which this was offered (meeting, conference, unsolicited, etc.):

Do you believe this gift/travel/entertainment could create an actual or perceived conflict of interest?

Explain the nature of the potential conflict:

Rate the following risk dimensions

Are you aware of any pending decisions, contracts, or evaluations involving this party?

Describe pending matters and timeline:

Does this gift/travel/entertainment comply with your understanding of company ethics policy?

Specify which policy provisions may be violated:

Have you consulted the written Corporate Ethics & Anti-Corruption Policy?

Explain why not and how you determined compliance:

Are you aware of any applicable laws or regulations that might prohibit or restrict this?

Specify applicable laws and potential violations:

What is the monetary threshold requiring disclosure in your company's policy?

Does the estimated value exceed your company's disclosure threshold?

Explain why this should still be permitted or provide additional justification:

What alternatives to acceptance did you consider? (select all that apply)

Rank your primary reasons for accepting this exchange (1 = most important)

Provide comprehensive business justification for accepting this gift/travel/entertainment:

Was there any explicit or implicit expectation of reciprocity or favorable treatment?

Describe the expectation communicated:

Is this type of exchange customary and accepted practice in your industry?

Explain industry norms and how this aligns:

Explain why you accepted despite it not being customary:

Would you be comfortable if details of this exchange were made public or reported to media?

Explain your discomfort and potential reputational risks:

Have you discussed this matter with your peers or colleagues for perspective?

Summarize peer feedback and names of those consulted:

Overall risk assessment: Rate the compliance risk level of this exchange (1 = Minimal Risk, 5 = Critical Risk)

Propose specific mitigation measures to address any identified risks:

Primary Reviewing Manager Name

Manager's Corporate Email

Recommended Approval Authority Level

Has your manager been notified verbally about this disclosure?

Date of verbal notification:

Explain why prior notification was not possible:

Supporting Documents Attached (check all that apply)

Priority Level for Review

Requested Review Completion Date

Additional Comments for Reviewers:

Employee Digital Signature - By signing, I certify that all information provided is truthful and accurate to the best of my knowledge.

Submission Date