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Gifts and Hospitality Policy

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					Gifts and Hospitality Policy
Document Authors Relevant to Approved by Responsibility for Policy Responsibility for document review Date introduced Date(s) modified Next Review Date Frank Sanderson, Belinda McGuiness, and Jeanette Wordsworth All Staff SMG on 24 February 2009 Finance Director Deputy Finance Director (Control) March 2009 March 2011

The Deputy Finance Director (Control) reserves the right to amend this document at any time should the need arise.

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INTRODUCTION The receipt of gifts or excessive hospitality can damage the University’s reputation and possibly lead to prosecutions for corruption. This policy seeks to protect staff from suspicion of dishonesty and ensure that they are free from any conflict of interest with respect to the acceptance or provision of gifts, hospitality, or any other inducement from or to suppliers of goods or services to the university. DEFINITIONS Gifts are items given or received for which no payment or service was given or received in return. Hospitality can be defined as any food, drink, accommodation or entertainment provided free of charge or heavily discounted.

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PRINCIPLES The University expects staff and members of the Board of Governors to exercise the utmost discretion in giving and accepting gifts and hospitality when on University business. Particular care should be taken about a gift from a person or organization that has, or is hoping to have, a contract with the University. Staff must not accept gifts, hospitality or benefits of any kind from a third party where it might be perceived that their personal integrity is being compromised, or that the University might be placed under an obligation. No favour or preference which is not generally available should be sought accepted or given. Staff must not make use of their official position to further their private interests or those of others.

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CONTRACTS WITH SUPPLIERS Staff must base all purchasing decisions and negotiations for contracts solely on achieving best value for money for LJMU. Staff involved in contracts with suppliers, particularly those authorised to sign purchase orders or place contracts are required to adhere to the Ethical Code of the Institute of Purchasing and Supply. Such staff should also be aware of the Prevention of Corruption Act 1916 which states that 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 by the courts to have been received corruptly unless the employee proves the contrary. LJMU requires its employees who have official dealings with contractors and other suppliers of goods and services to LJMU to avoid conducting any private business with them by any means other than available through normal commercial channels. If in any doubt, staff should seek advice from their line manager who in turn may consult a senior colleague with specialist knowledge, e.g., Deputy Finance Director (Control).

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5. 5.1

GIFTS AND HOSPITALITY Gifts of low intrinsic value such as promotional calendars or diaries, or small tokens of gratitude, can be accepted. If there is any doubt as to whether the acceptance of such an item is appropriate, staff should decline the gift or refer the matter to their line manager. Where approval is granted, any gift or hospitality received with an equivalent value of £30 or over must be recorded in the relevant Register of Gifts and Hospitality. In cases where a staff member receives a gift on behalf of the University, the gift remains the property of the University. The gift may be required for departmental display or it may, with the line-manager’s approval, remain in the care of the recipient. Unless otherwise agreed, the gift should be returned to the Department on or before the recipient’s last working day (see Staff Leaving guidelines). Modest hospitality, provided it is reasonable in the circumstances, for example, lunches in the course of working visits, may be acceptable, though it should be similar to the scale of hospitality which LJMU as an employer would be likely to offer (see LJMU Hospitality Expenses). It is recognized that LJMU conducts business with other, often international, organizations where it is normal practice to offer relatively generous gifts and hospitality, and where offence may be given by rejection. In cases where an immediate decision is necessary, staff can accept a gift or hospitality on behalf of LJMU which must be declared to their line manager on return. Staff attendance at sporting and cultural events at the invitation of suppliers, potential suppliers or consultants is not normally acceptable to the University.

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Where it is considered that there is a benefit to LJMU in a member of staff attending a sponsored event, the attendance should be formally approved by the relevant line manager. 5.6 Business gifts, which include hospitality, can be provided by LJMU in connection with third party entertaining, but must not exceed £50 in a year for any one recipient, and must not be provided in expectation of material benefit to LJMU (See LJMU Entertainment Expenses).

6. 6.1

GIFTS TO AND FROM STUDENTS Given the nature of the professional responsibilities of staff and the unequal power relationship between staff and students, staff are strongly advised not to give gifts/hospitality to or receive gifts/hospitality from students during their period of study. A gift / hospitality is sometimes offered by a student to a staff member who is in a position of influence in matters relating to the donor, for example, as an assessor, supervisor or member of an Assessment Board. In such circumstances, staff are strongly advised not to accept gifts/hospitality from students. In cases where it is judged that offence might be given by refusal, the member of staff should immediately declare that they have an interest to their line manager. Any gifts / hospitality received from students must be entered in the relevant local Register of Gifts and Hospitality.

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7. 7.1

REGISTER OF GIFTS In the interests of transparency, the VC, the Finance Director, PVCs and the Deans must each ensure that local Registers of Gifts and Hospitality are kept within their areas of responsibility. Any member of staff who accepts an offer of a gift or hospitality must ensure this is recorded in the appropriate Register of Gifts and Hospitality. The following should be specified: • Nature of gift/hospitality. In the case of a gift, it should be specified whether it is a personal gift for the recipient or a related party, such as a partner, or a corporate gift accepted by the recipient on behalf of the University. Value of gift / hospitality; Name of firm / individual concerned; Date gift / hospitality accepted; Name of employee.

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The entry containing the information should be signed by the recipient of the gift or hospitality, and countersigned by the relevant line manager. 7.3 In the case of Governors, any gifts or hospitality received relating to their connection with LJMU should be recorded in the Register of Gifts and Hospitality held by the PVC (Administration).

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RELEVANT DOCUMENTS • LJMU Financial Regulations and Policies • Staff Code of Conduct • Public Interest Disclosure Policy • Staff Disciplinary Procedure • Ethical Code of the Institute of Purchasing and Supply • Prevention of Corruption Act 1916 • Institute of Business Ethics briefing on The Ethics of Gifts & Hospitality

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