Gifts & Hospitality Policy

1.     Purpose

 

1.1. The Society expects excellent standards of conduct from all colleagues. This includes being open and transparent about gifts and hospitality provided or received.

 

1.2. This Policy sets out the procedure all colleagues must follow when being offered, or giving, gifts and hospitality.

 

1.3. Gifts include any item of value provided to a third party or their employees or received from a third party.

 

1.4. Hospitality includes any business entertaining, such as travel, accommodation, meals and invitations to events given to the Society and its colleagues by third parties or given by the Society to third parties.

 

1.5. This Policy ensures that the Society has appropriate controls in place to monitor the giving and receiving of gifts and hospitality from third parties. This forms part of the Society’s measures to comply with relevant legislation related to Bribery and Fraud and should be read in conjunction with the Society’s Bribery and Fraud Policy.

 

1.6. This Policy does not form part of any colleague's contract of employment and we may amend it at any time.

 

 

2.     Scope

 

2.1. This Policy applies to all persons working for the Society or on its behalf in any capacity, including colleagues at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

 

2.2. This Policy also applies to spouses, partners or other associates if it can be perceived that the gift or hospitality is in fact for the benefit of the interested colleague.

 

3.     Associated documents

 

3.1 The Society’s associated policies and documents are:

- Gifts and Hospitality Notification Form

- Gifts and Hospitality Register (maintained by the Society Secretary)

- Bribery and Fraud Policy

- Whistleblowing Policy

 

4.     Principles concerning bribery and gifts or hospitality

 

4.1. The Society discourages colleagues from accepting or giving gifts or hospitality. We accept that the occasional modest giving and acceptance of gifts and hospitality may be a legitimate contribution to good business relationships. However, it is essential that such instances do not influence, nor could be perceived as influencing, business decision making. We must all consider whether the giving or receiving of a gift or hospitality is appropriate.

 

4.2. It is prohibited to offer or receive gifts or hospitality that could influence or be perceived as capable of influencing the outcome of transactions or decisions relating to our business.

 

4.3. In principle, the Society does not encourage colleagues to either give or receive gifts from third parties including clients and suppliers. In particular, gifts that are excessive or which are conditional on particular behaviours or conduct should be returned. Money and financial instruments may never be accepted. Gifts should be returned to the third party with an explanation to the effect that it is not our policy to accept gifts.

 

4.4. The Society recognises, however, that declining a gift may cause some offence. When considering whether to accept or decline a gift or hospitality, please refer to section 5 of this Policy.

 

4.5. You should not be seen to be securing valuable gifts and hospitality by virtue of your job.

 

4.6. You should not accept or provide any gift or hospitality if there is a risk this will give the impression that you have been influenced while acting on behalf of the Society. For example, you should consider the following points and make the Executive Team member and Secretary and Head of Governance aware of any relevant information, where applicable.

 

• Is the organisation providing the gift/hospitality due to renew any contracts or agreements with the Society?

• Is the organisation performing to its service level agreements?

• Could the offer place you or the Society under any obligation to that organisation?

• Could acceptance be misconstrued as potential favouritism towards that organisation in any way?

• Is the offer reasonable in the circumstances?

 

4.7. No gift or hospitality that may amount to or cause the recipient or giver to commit a criminal offence can either be given or accepted.

 

4.8. It is your responsibility to ensure that you are not placed in a position that risks, or appears to risk, compromising your role or the Society’s public image.

 

5. Procedure for receiving gifts or hospitality

 

5.1. As above, the Society does not encourage receiving gifts or hospitality. However, we recognise that declining a benefit offered may cause some offence. When considering whether to accept or decline a gift or hospitality, please use the table below and ensure the correct procedure is followed:

 

Benefit received	Procedure
Small gift, below £30  (includes diaries, calendars, pens and so on)	Colleagues may accept. No recording or approval required.
Two or more small gifts, each below £30, received from same third party within a 6-month period (includes diaries, calendars, pens and so on)	Upon receipt of the offer of the second gift, colleagues are required to seek approval and report the offer following the same procedure for gifts exceeding £30 below.
Gifts exceeding £30   (includes bottles of champagne, spirits, tokens, vouchers, presents and so on)	Colleagues are required to seek approval and report the offer of the gift. You must seek approval by email from your Executive Team member, who will decide among any of the following acceptable options: share the gift with all colleagues in a team or department raffle the gift to allow other colleagues to participate in the opportunity to benefit donate the gift to charity; or keep it for yourself. You must also report the offer of the gift by completing the Gifts and Hospitality Notification Form and send it by email to the Society Secretary (Edward.parker@midcounties.coop),
Attendance at business functions associated with your role in the Society or your professional status (ie professional dinners or events)	Obtain prior written consent from your line manager.
Attendance at purely social events (such as sporting events, horse racing, golf days)	In all cases (irrelevant of value) colleagues are required to seek approval and report the offer of the hospitality. You must seek approval by email from your Executive Team member, prior to accepting the hospitality. You must also report the offer of hospitality by completing the Gifts and Hospitality Notification Form and send it by email to the Society Secretary (Edward.parker@midcounties.coop).
Hospitality accepted (such as lunches, dinners)	In all cases (irrelevant of value) colleagues are required to seek approval and report the offer of the hospitality. You must seek approval by email from your Executive Team member, prior to accepting the hospitality. You must also report the offer of hospitality by completing the Gifts and Hospitality Notification Form and send it by email to the Society Secretary (Edward.parker@midcounties.coop).

 

5.3. Declined gifts or hospitality must also be reported in the same way.

 

5.4. We acknowledge that sometimes obtaining prior approval may not be practicable, for example if the gift is received from a customer and rejecting it could be impolite.  In these circumstances, you may accept the gift provisionally and then seek approval from your Executive Team member and report it, using the above process.

 

5.5. Reported gifts and hospitality will be recorded on the Society’s Gifts and Hospitality Register maintained by the Secretary & Head of Governance. The Register may be reviewed periodically by the Board of Directors and Internal Audit.

 

5.6. Some business groups may maintain their own internal register of gifts and hospitality.  It is essential that such registers include all of the information in the Gifts and Hospitality Notification Form. Any such internal register must be forwarded to the Secretary & Head of Governance on a regular basis, so that the Society’s Gifts and Hospitality Register can be kept up to date.

 

5.7.  When determining the monetary value of a benefit you must consider market value. If you are unsure of the monetary value, you may seek guidance from the Society Secretary. If the value remains unclear and the benefit offered is a gift, you should assume the value exceeds £30.

 

6.     What steps do I take giving gifts?

 

6.1. You should first consider the principles at section 4 of this Policy to see whether giving of the gift or hospitality is appropriate.

 

6.2. All giving of gifts (with a value greater than £30) or hospitality (of any value) must be pre-approved in writing/email by your Executive Team member.

 

6.3. Once approved, gifts or hospitality that are given to a third party, person or organisation, must be reported by email to the Secretary & Head of Governance by completing the Gifts and Hospitality Notification Form.   You should ensure that you have copied your Executive Team member, and that you have retained a copy of the email for your own records.

 

 

7.     Where do I go for help or advice?

 

7.1. You should consult the Secretary & Head of Governance for any guidance required on this Policy. In general terms, if you have any doubt about whether an item should be approved and reported, you are advised to seek approval and report it.

 

8.     Policy Breach

 

8.1. Any breach of this Policy will be taken seriously. Where those involved are employed by the Society, it will result in disciplinary action being taken which may lead to dismissal. Where those involved are not employed by the Society, they may have their contract terminated with immediate effect. Where those involved have not yet contracted with the Society, they will be excluded from future procurement opportunities.

 

8.2. Where the breach of this Policy amounts to bribery, the Society may involve the Police or other relevant authority, regardless of any person’s relationship with the Society, their position, or their length of service. This could result in prison sentences being imposed on the perpetrators.

 

 

9.     Policy Review

 

9.1. This Policy will be reviewed at least every other year and amended as and when required.

 

 

Policy name:	Hospitality and Gifts Policy	Date of last review:	October 2023
Policy owner:	Secretariat	Issue number:	PSG-EP-003