POLICY ON GIFTS AND HOSPITALITY 1. Principles 1.1 This policy on the receipt of gifts and hospitality is designed to protect staff from accusations of bribery and corruption and thereby also protect the reputation of the University. Such gifts and/or hospitality might be offered by private companies, contractors or consultants or any organisation or person seeking preferential treatment. This policy applies to gifts and hospitality offered by staff to students and vice versa. Gifts and hospitality offered to friends and family of University staff will also be unacceptable if they might be seen to entice future business with the University. 1.2 The expectation is that all staff will conduct themselves with integrity, honesty and openness at all times. They should maintain high standards of professionalism and propriety. The conduct of staff should not arouse suspicion of any conflict between their official duty and their private interest. The actions of individuals acting in their official capacity should not give the impression to any member of the public, to any organisation, or to colleagues, that they have been or may have been influenced by a benefit to show favour or disfavour to an organisation. 1.3 The acceptance of gifts and hospitality is only permitted in the limited circumstances set out below at paragraph 2. 2. Circumstances in which It May Be Permissible to Accept Gifts and Hospitality 2.1 The following types of gift/hospitality are considered to be acceptable: (a) A small gift regarded as trivial and of nominal value which may be of a promotional or advertising nature such as calendars, diaries and charts or where refusal of such a small or trivial gift would cause needless offence. (b) Conventional hospitality such as working lunches in the course of official visits; attendance in an official capacity as a University employee at higher education related functions, conferences, seminars etc. The above list is not exhaustive; each offer should be considered carefully in relation to the circumstances. 2.2 Staff responsible for the purchase of supplies, equipment or services must take particular care to ensure that there can be no criticism that unequal treatment has been given to suppliers involved in tendering processes through the acceptance of any gifts or other benefits however trivial. 2.3 Where a more valuable gift or benefit is offered from which the University in general might benefit, rather than an individual employee, acceptance should be referred to the Director of Development for consideration under the University’s Donations Policy. 2.4 In the case of doubt or where the regularity or value of any hospitality or benefit is in question, the matter should be referred to the Dean or equivalent senior manager for decision who should consider taking advice from the University Secretary and Registrar if appropriate. Acceptance of any gift or hospitality in such circumstances should be notified to the University Secretary and Registrar and recorded in the Register of Interests (see paragraph 4 below). 3. Unacceptable Gifts/Hospitality 3.1 The types of gift/hospitality below are unacceptable and acceptance of such gifts/hospitality are likely to result in disciplinary action being taken against the member of staff involved: (a) Gifts/hospitality which are lavish or expensive, particularly where received on a regular basis from the same source. Repeated acceptance of meals, tickets and invitations to sporting, cultural or social events, particularly from the same source. (b) Travel, holidays or accommodation. (c) Offers of items or services for personal use at trade or discounted price other than discounts generally available to all or most members of staff. (d) Receiving payment or other reward from an external organisation/company for work undertaken in an individual’s official capacity as an employee of the University. (e) Acceptance of gifts/hospitality which could be deemed as influential in the award of a contract or business to an external organization. (f) Inducements that could lead to a contractual position between the University and a supplier, contractor or consultant. It is also unacceptable to ask for gifts and/or hospitality. 3.2 The list in paragraph 3.1 above is not exhaustive. Each offer needs to be considered with due regard to its particular circumstances and the nature of the gift/hospitality offered. 3.3 Under the University’s disciplinary procedure, dishonesty (such as bribery and corruption) in connection with the work of a member of staff constitutes gross misconduct and where such allegations are substantiated, summary dismissal (dismissal without notice) may occur. Consequently, it is a disciplinary offence for a member of staff to accept any gift/hospitality as an inducement or reward for: (a) Not undertaking their correct duties and responsibilities. (b) Showing favour or disfavour to an individual/organization. Similarly, accepting any gift/hospitality that is listed under the section entitled “Unacceptable Gifts/Hospitality” would constitute a disciplinary offence. Any attempt at bribery or corruption should be reported to the line manager of the member of staff and to the Director of Finance without delay. Bribery and corruption are criminal offences that can be reported to the police. 4. Register of Interests 4.1 Governors and all senior staff who are members of Executive Board or are at Dean or equivalent level must annually submit a declaration of interests to the University Secretary and Registrar. As a senior member of staff, the University Secretary and Registrar will submit an annual declaration for inclusion in the register which will be reported to the Rector. 4.2 This register is also used to record the acceptance of any gift or hospitality at paragraph 2.4 above and will include those staff below Dean level for this purpose only. Staff should be aware that this register is open to the public for inspection on request.
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