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					Corporate Hospitality and Gifts: Procedures for Receipt of Corporate Hospitality and Gifts by Members of Staff and Governors of the University
March 2006

Document title

Corporate Hospitality and Gifts: Procedures for Receipt of Corporate Hospitality and Gifts by Members of Staff and Governors of the University March 2006
Document author and department Responsible person and department

Jo McGuigan, Deputy Director of Finance, Finance Department
Approving body

Emma Woollard, Director of Finance, Finance Department
Date of approval

Finance Committee
Review date

6 March 2006, Min 54.3
Edition no. ID code

March 2009 EITHER
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External queries relating to the document to be referred in the first instance to the University Secretary: telephone +44 (0)23 9284 3195 or email university.secretary@port.ac.uk

If you need this document in an alternative format, please contact +44 (0)23 9284 5776.

Corporate Hospitality and Gifts: Procedures for Receipt of Corporate Hospitality and Gifts by Members of Staff and Governors of the University March 2006
Executive summary
The purpose of this document is to lay down procedures to be followed by members of staff and governors in respect of the receipt of corporate hospitality and gifts. The key principles of these Procedures are: 1. No member of staff or governor shall be in receipt of gifts, excessive hospitality or any other inducement from a supplier or potential supplier of goods, materials or services to the University (the University’s Financial Regulations). All members of staff and governors must adhere to these procedures, to ensure the highest possible standards of public accountability in line with the Nolan Principles. Staff should be aware that reports of receipts of gifts and/or excessive hospitality can cause public disquiet and possibly lead to prosecutions for corruption. Staff who are in a position to award a contract or recommend contractors for the tender process must not work with any such University supplier on a personal basis including organising or securing services for other members of staff.

2.

3.

4.

UNIVERSITY OF PORTSMOUTH

CORPORATE HOSPITALITY AND GIFTS: PROCEDURES MARCH 2006

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1. Introduction
1.1 The University’s Financial Regulations state: ‘No member of staff or governor shall be in receipt of gifts, excessive hospitality or any other inducement from a supplier or potential supplier of goods, materials or services to the University’. The University seeks to adhere to the highest possible standards of public accountability in line with Nolan Principles. The procedures set out in this paper must be adhered to by all members of staff and governors. Staff and governors should be aware that reports of receipts of gifts and/or excessive hospitality can cause public disquiet and possibly lead to prosecutions for corruption. To ensure there is no basis for criticism staff or governors who are in a position to award a contract or recommend contractors for the tender process must not work with any such University supplier on a personal basis including organising or securing services for other members of staff or governors.

1.2

1.3

1.4

2. Corporate hospitality and gifts register
2.1 All disclosures of corporate hospitality and gifts will be recorded in a central register maintained by the Director of Finance. The Director of Finance will produce a summary of disclosures, at least quarterly, for the Vice-Chancellor and Chairman of the Board. The disclosure form is available online at www.port.ac.uk/departments/services/finance/CorporateHospitalityandGifts/ The paragraphs below explain the disclosure requirements.

2.2

2.3

3. Hospitality meals etc.
3.1 Members of staff and governors of the University may often find themselves in a position of being offered a meal or free attendance at a social/commercial function organised by an outside organisation. In general, receipt of hospitality in the following circumstances would be acceptable: a) attendance at a general demonstration of office or other equipment and services b) attendance at ceremonies associated with the opening of buildings c) attendance at dinners or functions organised by societies or other bodies d) attendance at functions of other academic institutions e) attendance at business meetings f) attendance at promotional events, e.g. hosted by Portsmouth City Council, SEEDA. Attendance at sporting and cultural events consequent upon invitations from suppliers, consultants etc. where entrance tickets and hospitality are provided, are not normally acceptable to the University. Where it is considered of benefit to the University for a member of staff to attend a sponsored event then the prior approval of the Director of Finance is required. 3.2 Under no circumstances should members of staff or governors directly accept any offer of accommodation or travel at the expense of contractors, suppliers, developers or consultants. In such circumstances, officers must report the offer to the Director of Finance who will deal with each occurrence on an individual basis. (Where there is a contractual arrangement for travel and accommodation to be provided to staff of the University, in particular by overseas colleges and institutions, separate arrangements will be made with the staff concerned.) In all cases referred to in paragraph 3.1 a)–f), associated travelling expenses and the cost of overnight accommodation should be approved in principle before the visit is undertaken (in accordance with current procedures) and the costs ultimately borne by the University. It is recognised that situations might arise overseas where members of staff or governors may be in a position where a refusal to accept may cause embarrassment to the University. In these situations the officer must only act in the interests of the University and report the full circumstances to the Director of Finance immediately upon return to the UK. In addition senior members of staff or governors may be invited to events where attendance is judged to provide additional background information on the host or other organisation. Subject to 3.2 above the senior officer would exercise his/her judgement and report the matter to the Director of Finance afterwards. In all cases where hospitality, including entertainment, meals and the like are provided, members of staff or governors must exercise discretion in taking meals with contractors or others with whom they are negotiating to ensure that the University and the members of staff or governors themselves are not compromised in any way.

3.3

3.4

3.5

3.6

4

CORPORATE HOSPITALITY AND GIFTS: PROCEDURES MARCH 2006

UNIVERSITY OF PORTSMOUTH

4. Gifts
4.1 Gifts may be offered by organisations or persons who are providing or are seeking to provide goods, materials or services (see 1.1) to the University. Subject to the exceptions listed below the officer should decline, politely and courteously, any personal gift offered immediately to him/her or to a member of his/her family and should report the offer to his/her Departmental Head and the Director of Finance. The exceptions to this general rule are: a) modest gifts of a promotional character given to a wide range of people and not uniquely to the employee. These gifts are usually given at Christmas time and include calendars, diaries, desk sets, flow charts, tape measures, scales and other articles of use in the office or in the officer’s employment; b) modest gifts on the conclusion of any courtesy visit to an organisation or institution of a sort normally given by that organisation or institution e.g. pens, mugs etc. It is recognised that offence could be taken by some organisations, particularly overseas, if courtesy gifts are declined. In some circumstances these can be considered to be expensive. In these cases the gift should be accepted and the case notified to the Director of Finance for his/her consideration. 4.3 In considering the exceptions above, it is imperative that members of staff or governors should err on the side of caution. A gift which is obviously expensive should raise a question, even if it otherwise falls within the above categories. If there is any doubt, the advice of the Director of Finance must be sought. In circumstances where gifts are left by contractors and other organisations and which do not fall into the above categories, the gift must be delivered to the Director of Finance who will deal with the matter. If any gift is received of a value in excess of £10, then receipt of that gift must be reported to the Director of Finance.

4.2

4.4

4.5

5. Senior post holders (as defined by the University’s Articles of Government)
It is recognised that by virtue of the range of University activities, holders of senior posts are more frequently involved in events which involve hospitality, occasionally of a corporate nature. The procedures apply equally to senior post holders.

6. General
6.1 To ensure that the University’s policy in this matter is circulated as widely as possible the Director of Finance or delegated officer will on an annual basis remind all the University’s major contractors and suppliers of the University’s policy to ensure that they are aware of the high standards of probity set by the University. The communication will also point out to the contractors and suppliers that their contracts with the University could be terminated if it is considered that there has been a breach of the University’s Conditions of Contract. These state: ‘In connection with this or any other Contract between You and Us, You shall not give, provide, or offer to Our staff and agents any loan, fee, reward, gift or any emolument or advantage whatsoever. In the event of any breach of this Condition, We shall, without prejudice to any other rights We may possess, be at liberty forthwith to terminate this and any other Contract and to recover from You any loss or damage resulting from such termination.’ 6.2 To ensure that the University is not compromised in any way staff of the University will be required to complete on an annual basis declarations of interests in contracts and shareholdings in any company which is likely to conflict with the interests of the University. If in doubt of any matter associated with this important subject, the advice of the Director of Finance should be sought. Clearly, the best safeguard against impropriety or suspicion of impropriety, is complete openness. Failure to comply with the procedures outlined will result in the appropriate disciplinary action being taken.

6.3

6.4

UNIVERSITY OF PORTSMOUTH

CORPORATE HOSPITALITY AND GIFTS: PROCEDURES MARCH 2006

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University of Portsmouth Finance Department University House Winston Churchill Avenue Portsmouth PO1 2UP United Kingdom
MD2991 0308

T: F: E: W:

+44 (0)23 9284 3195 +44 (0)23 9284 3319 university.secretary@port.ac.uk www.port.ac.uk


				
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