Hospitality & Gifts Policy
Last Updated 5 Nov 2018 in Ways of Working
From time to time colleagues may be offered gifts or invited to events by third parties, such as suppliers. There is a formal procedure for managing such gifts.
Key points covered:
- The kinds of things that are considered gifts
- What to do if you are offered a gift of any kind
- Things to consider when assessing why the gift has been given
- The official reporting procedure
1.1. This Policy sets out the procedure all colleagues must follow when being offered, or giving, gifts and hospitality.
1.2. The Society needs to ensure appropriate management and have control in place to monitor the giving and receiving of gifts and hospitality from third parties, external suppliers, contractors, etc. in order that no inappropriate advantage is offered, or inferred to individual colleagues and/or the Society as a whole.
2.1. This Policy applies to full-time and part-time colleagues on a substantive or fixed-term contract, and to associated persons, agency staff contractors and others employed under a contract of service by the Society.
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. Policy Statement
3.1. You must declare all offers of gifts and hospitality, made to or by you, regardless of value. All such offers must be declared whether accepted or declined. Offers of gifts and hospitality may include items ranging from diaries, wall charts, and boxes of chocolates, to free international travel and accommodation.
Declarations will be recorded on the Society’s Gifts and Hospitality Register maintained by the Secretary & Head of Governance. The Register will be reviewed periodically by the Board of Directors and Internal Audit.
3.2. 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.
3.3. You should not be seen to be securing valuable gifts and hospitality by virtue of your job.
3.4. You should not accept or provide any gift or hospitality if such acceptance or provision will give the impression that you have been influenced while acting on behalf of the Society. For example, you should consider the following points before seeking authorisation:
3.4.1. Is the organisation providing the gift/hospitality due to renew any contracts or agreements with the Society?
3.4.2. Is the organisation performing to its service level agreements?
3.4.3. Could the offer place you or the Society under any obligation to that organisation?
3.4.4. Could acceptance be misconstrued as potential favouritism towards that organisation in any way?
3.4.5. Is the offer reasonable in the circumstances?
4. Receiving Gifts
4.1. Any gifts valued at £30 or under, must be notified by email to the Society’s Secretary & Head of Governance, in copy to your Group General Manager.
4.2. For gifts exceeding the value of £30, you must seek approval by email from your Group General Manager, who will decide among any of the following acceptable options:
4.2.1. share the gift with all colleagues
4.2.2. raffle the gift for charity;
4.2.3. donate the gift to charity; or
4.2.4. keep it for yourself.
4.3. If you are in doubt about accepting a gift, you should refer to this Policy in the first instance or seek advice from the Secretary & Head of Governance before accepting it.
4.4. However, sometimes this may not be practicable, for example if the gift is received from a customer, or a member, and rejecting it could be unpolite. In these circumstances, you should accept the gift and then report it, using the process explained in this Policy.
5. Giving Gifts
5.1. All giving of gifts must be discussed with, and agreed by, your Group General Manager in the first instance.
5.2. Generally, these cases will be dealt with on an ad-hoc basis.
5.3. Gifts which are given to a third party, person or organisation, must be reported to the Secretary & Head of Governance following the process explained in this Policy. You should ensure that you have copied your Group General Manager, and that you have retained a copy of the email for your own records.
6. Receiving and Giving Hospitality
6.1. All hospitality offers must be discussed in advance with your Group General Manager before being accepted.
6.2. Any offer for hospitality, whether accepted or declined, must be reported to the Secretary & Head of Governance using the process explained in this Policy.
6.3. Inappropriate offers must be reported by email to your Group General Manager and the Secretary & Head of Governance.
7. Reporting Procedure
7.1. Receiving a one-off gift
7.1.1. If you don’t receive gifts on a regular basis, it is recommended that you report any one-off gift that you may receive to the Secretary & Head of Governance by email (in copy to your Group General Manager), and you should retain a copy for your personal records
7.1.2. Declined gifts must also be reported following the same procedure.
7.1.3. Your email will need to include the following information:
18.104.22.168. date of offer of gift
22.214.171.124. details of the person, or supplier, third-party provider etc. you received the gift from
126.96.36.199. nature and purpose of gift received (or declined)
188.8.131.52. estimated value of gift or hospitality.
7.2. Receiving regular gifts
7.2.1. Some business groups may be receiving gifts on a more regular basis from their suppliers, especially during – but not limited to - a festive season. In this case, business groups should maintain their own internal register of gifts & hospitality (acceptable formats are Word or Excel) where frequent gifts can be noted. The register should contain the elements required in point 7.1.3. above.
7.2.2. Any internal register should be forwarded to the Secretary & Head of Governance on a regular basis, ie. each Period, in order that the Society’s Gifts & Hospitality Register can be kept up to date.
7.3. 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 or should not be declared, you are advised to declare it.
8. Policy Breach
8.1. Any breach of this Policy may be subject to disciplinary action.
9. Policy Review
9.1. This Policy will be reviewed on a yearly basis and amended as and when required.
Hospitality and Gifts Policy
Date of last review: