Sales team code: one page, and what to say when asked for commission

Print this. Keep it where the sales team will see it. It sits underneath the full policy.

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The rules

1. We never give or promise anything to the person who places an order, unless the person whose money it is has been told and has agreed in writing first.
2. We never accept anything in return for an order or a decision.
3. We do not keep secrets about commissions or incentives from the person whose money it is, from their employer, or from our compliance lead.
4. We do not use anyone else to do what we may not do ourselves.
5. Everything is recorded. Offers given, received, accepted and declined go in the register.
6. If in doubt, ask first. If asked to break the rules, say no, and tell [compliance lead].

What you can offer

• A price discount shown on the invoice, which the customer sees and keeps.
• A written rebate with the customer.
• Samples and tastings for the team, logged.
• A modest meal at a genuine business meeting, within the limit in the policy, never while an order is pending with that person.

What you can never offer

Cash. Gift cards. Personal discounts. Free wine or spirits to an individual. Travel. Tickets. Jobs for relatives. Anything "between us". Anything you would not be comfortable with the owner seeing.

When someone asks for a commission

Stay friendly. Stay short. Use these words:

"Thank you for asking. We don't pay commission or any kind of benefit to anyone placing an order. It's our policy, and it's written down. What we can do is offer your client a discount on the invoice, which they'll see and keep."

If they push:

"I understand, and I'm sorry we can't help with that. It's the same for everyone, and it's how we protect your client and you. If you'd like to read the policy, I'll send it."

If they say they will take the order elsewhere:

"I understand, and thank you for considering us. We'd rather lose the order than break our policy."

Then, the same day:

1. Write it in the register: date, who (role and company), what was asked, what you said.
2. Tell [compliance lead] if it was for money, if it came with a threat, or if it was the second time.
3. Do not discuss it with competitors, and do not hold it against the person.

When you are offered something

A broker or crew member offers you a drink, a trip or a favour for the order: decline, record, report. A supplier offers you a bonus or a gift for the business you give them: decline, record, report.

Five questions before you do anything

1. Does the person whose money it is know?
2. Would they agree if they saw it?
3. Is it written down?
4. Would I be happy to see it on the front page?
5. Is it the same thing I would do for any customer?

If any answer is "no" or "not sure", stop and ask.

Who to call

[Compliance lead]: [name], [contact]. A director: [name], [contact]. Outside adviser: [name], [contact]. You will never be in trouble for asking.

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General information, not legal advice.