Gifts and Hospitality Policy Halesowen College

							                                                                                         QF028




                                             Gifts and Hospitality Policy

The Bribery Act 2010 has reformed existing criminal law and replaced the Prevention of
Corruption Acts 1889-1916, introducing a new modern and comprehensive scheme of
bribery offences:
         offering or receiving bribes
         bribing a foreign public official
         failure to prevent bribery

This policy sets out that the College will not tolerate bribery in any form, and provides a
framework for the receipt and offer of gifts and hospitality. As such, staff must not offer,
promise or give an advantage nor request, agree to or accept an advantage.

Gifts other than items of very small intrinsic value such as business diaries, calendars etc,
shall not usually be accepted. Members of College staff must not accept any gift or
consideration as an inducement or reward for doing, or refraining from doing, anything in an
official capacity or showing favour or disfavour to any person in an official capacity. Thus,
members of staff should not accept any gifts, rewards or hospitality (or have them given to
members of their families) from any organisation or individual with whom they have contact
in the course of their work that would cause them to reach a position whereby they might be,
or might be deemed to by others, to have been influenced in making a business decision as
a consequence of accepting such gifts or hospitality.

Individuals should only accept hospitality in the course of a courteous business relationship;
the frequency and nature of this not being significantly different to that which the Corporation
would provide.

Should any supplier et al attempt to bribe a member of staff they must report this
immediately to the Principal.

It is sometimes difficult to assess the level of hospitality that must be declined. In such
instances advice should be sought from the Principal. A register of gifts and hospitality will
be maintained and staff in receipt of such are obliged to notify the Principal or his
representative immediately and before any acceptance.

Similarly, staff must not attempt to bribe anyone by offering financial or other advantage to
another person. Any hospitality provided must be modest and organised through the
College’s catering functions or approved suppliers.

The giving of gifts or rewards to students should be part of supporting positive behaviour or
recognising particular achievements. In some situations, the giving of gifts as rewards may
be accepted practice for a group of students, whilst in other situations the giving of a gift to
an individual child or young person will be part of an agreed plan, recorded and discussed
with the Principal and the parent or carer.

It is acknowledged that there are specific occasions when staff may wish to give a student a
personal gift. This is only acceptable practice where the member of staff has first discussed
the giving of the gift and the reason for it, with a senior manager and parent or carer and the
action is recorded. Any gifts should be given openly and not be based on favouritism.



JC / QF028 Gifts and Hospitality Policy (June 2010)
Staff need to be aware however, that the giving of gifts can be misinterpreted by others as a
gesture either to bribe or groom1 a young person.

Staff should exercise care when selecting students for specific activities or privileges to
avoid perceptions of favouritism or unfairness. Methods and criteria for selection should
always be transparent and subject to scrutiny.

Care should also be taken to ensure that staff do not accept any gift from students or
parents that might be construed as a bribe by others, or lead the giver to expect preferential
treatment.

There may be occasions when students or parents wish to pass small tokens of appreciation
to staff, for example on special occasions or as a thank-you and this is acceptable. However,
it is unacceptable to receive gifts on a regular basis or of any significant value.

The reputation of the College depends on the conduct of its staff and what the public
believes about their conduct. Staff are expected to use common sense in assessing any
situation where improper influence could be construed. No member of staff should do
anything which could give rise to accusations of improper influence and which could not be
justified publicly.




1
    grooming’ – the act of gaining the trust of a child so that sexual abuse can take place.




JC / Gifts (May 2010)
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