Hospitality gifts policy 2006

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                                         HOSPITALITY AND GIFTS POLICY



1.     Introduction

The Hospitality and Gifts Policy of the XXX is intended to assist all corporate employees of the XXX in following
the guidance and legislation on the giving and receipt of hospitality or gifts. This covers both the requirements
and delivery of hospitality and gifts to both XXX staff and non XXX staff.

2.     Legal Framework

The law is set out in the Prevention of Corruption Acts, 1906 and 1916: it is an offence for employees corruptly
to accept any gifts or consideration as an inducement or reward for
     Doing, or refraining from doing, anything in their official capacity or
     Showing favour or disfavour to any person in their official capacity

Under the 1916 Act, any money, gift or consideration received by an employee in public service from a person or
organisation holding or seeking to obtain a contract will be deemed to have been received corruptly unless the
employee proves to the contrary.

Under XXX Standing Orders purchasing for s and Supplies, the requirement is for fair and open competition
between prospective contractors or suppliers.

3.      Policy and Scope

3.1    Each employee has a personal responsibility to declare hospitality and gifts. The provisions of the policy
       shall be held to apply to all employees, secondees and associates of the XXX. There is no seniority
       threshold. In cases of doubt, individuals should clear acceptance of hospitality with the Chief Executive or
       their Director.

       Note that:-
           As a general rule, hospitality should be of an equivalent scale and type to that normally offered by
               the XXX.

                Any hospitality or trivial gifts accepted should be entered on the hospitality register by means of
                 the form at Appendix 1.

3.2    It is the responsibility of all employees to ensure that they are not placed in a position that
       risks, or appears to risk, conflict between their personal interests and XXX duties. Non-
       compliance with the policy may lead to action under the Disciplinary or other relevant policy.

3.3    It is the responsibility of the Chief Executive register and make it accessible to the public and
       to auditors in accordance with the policy.

3.4    The register will be reviewed annually by Internal Audit and will be available to the External
       Auditors.




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4.        Principles - Receipt of Hospitality

4.1      Acceptable Hospitality

Modest hospitality, provided it is normal and reasonable in the circumstances, for example
lunches in the course of working visits, is acceptable and does not need to be recorded.

Other hospitality may be accepted, for instance where:

                An employee of staff is invited to a Society or Institute Dinner or function.
                There is a genuine need to impart information or represent the XXX at events
                A function or event is hosted for both XXX employees and others which adds benefit and value to
                 the XXX or the wider XXX.
                A function or event is hosted for XXX employees only for the purposes of training or organisational
                 development.

These types of hospitality must be recorded

4.2      Unacceptable Hospitality

The following examples are intended to give general guidance only on what may be regarded as
unacceptable hospitality:

                A holiday abroad or weekend in a holiday centre.
                Offers of hotel accommodation.
                Use of a company flat or hotel suite.
                Attendance at a function or event restricted to XXX employees which is not for the purposes of
                 training or organisational development.

ANY hospitality offered to XXX employees but declined should be recorded in the register. This will
enable the XXX to monitor the sources of the offers of hospitality.

4.3      Commercial Sponsorship

Attendance at relevant commercially sponsored conferences and courses is acceptable, but only where
acceptance will not, and can not be seen as compromising purchasing decisions in any way. Receipt of such
sponsorship should be recorded in the Register.

5.       Principles - Provision of Hospitality

     5.1 The provision of hospitality by employees of the XXX to representatives of other organisations
         should be modest and be appropriate in the circumstances, for example sandwich lunches in
         the course of working visits..

5.2      Provision of hospitality by the XXX to employees of the XXX would not normally be appropriate
         except in the case of working lunches where the majority attending are away from their normal
         base, training courses or organisational development events.

5.3      The use of XXX monies for hospitality and entertainment at conferences and seminars should
         be carefully considered. The XXX needs to be able to demonstrate good value in incurring
         public expenditure. Any such hospitality should be recorded in the register.

6.       Principles - Gifts

6.1      Acceptance of gifts



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Employees should not accept gifts which may be, or be capable of being construed as being able to
influence a purchasing decision or cast doubt on the integrity of such decisions. Casual gifts offered
by contractors, for example at Christmas time, should be declined except where they are of low
intrinsic value (e.g. small stationery items such as diaries or calendars, below £10 in value).

6.2    Giving of gifts

On occasions the Chief Executive will authorisation of gifts associated with XXX personal
esteem or welfare (e.g. Flowers for retiring employee). Gifts should be reasonable and limited in
value. All other XXX policies and procedures must also be adhered to.

6.3    Monetary gifts

The acceptance or giving of monetary gifts is not acceptable in any circumstances.

7.     Procedures - Records of Hospitality and Gifts Received, Provided or Offered

7.1     Requirement for a Hospitality and Gifts Register

XXX guidance requires that the XXX maintains a register of hospitality and gifts. Such a register
should record any offer, receipt or provision of hospitality or gifts and will be subject to review by both
Internal and External Audit.

7.2    Maintenance of the Register

The XXX will maintain a central register administered by the PA to the Chief Executive. For the
purposes of internal audit all employees are to use the standard register format (see paragraph 8).
Individuals may wish to keep a personal copy of all submissions made. When a submission is made
it is also important to record the estimated value of the hospitality or gift received, provided or offered.
Annual audits of the hospitality register will be undertaken against the following performance
measures:

               review of number of entries made to the register and source
               analysis of value of hospitality / gifts offered but declined
               analysis of hospitality / gifts accepted
               analysis of value and nature of hospitality / gifts provided
               analysis of outside organisations offering hospitality / gifts
               analysis of outside organisations receiving hospitality




8.     Form of Register

8.1    Submissions

The information required for the hospitality and gifts register is set out below and are used as fields on
the submission form available on the XXX intranet (see Appendix 1). Submissions should be made as
soon as is practically possible.

8.2    Information Required


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               date of entry
               name of recipient / provider
               job title
               nature and purpose of hospitality or gift received or provided and the name of any other
                organisation involved
               nature and purpose of hospitality or gift declined and the name of the organisation offering the
                hospitality or gift
               estimated value
               date of hospitality or gift.

If employees have any doubt about whether an item should or should not be recorded, they are
advised to record it.

9.     Related Policies

Reference should also be made to other relevant policies:

               whistle blowing
               counter fraud
               disciplinary

Corporate employees are also reminded that restrictions on the acceptance of gifts and hospitality are included
in their contract of employment, and non-compliance may lead to disciplinary action.




APPENDIX 1 – DECLARATION OF ACCEPTANCE OF GIFTS OR HOSPITALITY


This form must be completed if, in connection with your official duties, you accept any form of gift, hospitality or
consideration from a third party.

Following completion, pass the form to the Chief Executive or your Director for counter-signature. The
completed form will be filed on an official register, which will be periodically scrutinised by the auditors and may
be viewed at any time by a member of the public or interested organisation.


Name ……………………………………………………………………………………………………


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I disclose that on ………………………………………….. (Date) I accepted/declined the following gift/hospitality
(delete as appropriate)

Details……………………………………………………………………………………………………

……………………………………………………………………………………………………………

Estimated Value ……………………………………………………………………………………….

From …………………………………………………………………………………………………….
(Name of organisation offering gift or hospitality)

Any other organisation involved ………………………………………………………………….….

Signed ………………………………………………………

Date …………………………………………………………

Countersigned ……………………………………………..

Job Title …………………………………………………….

Date …………………………………………………………


Return completed form to the PA to the Chief Executive

Date of review 31.03.2007




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