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      1. What’s New
      2. Introduction
      3. Official Hospitality
      4 Internal Business Functions (Refreshments etc)
      5. Management Conferences, Seminars etc
      6. Working Lunches
      7. Teas, Coffees, Biscuits at Meetings
      8 Personal Events etc
      9 Provision of Alcoholic Drinks at Public Expense

      9.1 Authorising Officers Responsibilities

      Provision of Alcohol at Public Expense - Authorising
      10 Payment / Reimbursement
      11 Impact on Subsistence Claims
      12. Tax Liability

Welcome to the DWP Hospitality Framework. This framework
reflects the civil service-wide policy on the provision of official
hospitality, which is owned by the Cabinet Office. Expenditure on
official hospitality is a sensitive issue, which calls for sound
judgement on the part of those authorising expenditure. The
framework is part of wider DWP Regularity and Propriety guidance
contained in the Regularity and Propriety Framework.

The key principle for hospitality is that you must not accept
hospitality or receive other benefits from anyone which might
reasonably be seen to compromise your personal judgement or
integrity (Civil Service Code).

The framework also sets out the Department’s guidelines in respect
of management conferences, working lunches and teas and coffees
at official meetings, all of which are specific to DWP. It also
includes details of the provision of alcohol at public expense.

The framework ensures that the Department reflects appropriately
and proportionately the following requirement in the Civil Service
Management Code:

“Departments and agencies must inform staff of the circumstances
in which they need to report offers of gifts, hospitality, awards,
decorations and other benefits and of the circumstances in which
they need to seek permission before accepting them. In drawing up
such rules departments and agencies must draw the attention of staff
to the provisions of the Prevention of Corruption Acts 1906 and

This framework underpins and complements the Standing Financial
Instructions, which provide high-level guidance on the roles and
accountabilities of managers, and should therefore be read in
conjunction with this and other guidance on specific finance

If you cannot find what you are looking for please contact us and let
us know. We very much welcome feedback from users of these

1. What’s New
This framework was last updated in January 2010. It now includes:

      Revisions to the list of authorising officers for the provision
       of alcohol at public expense;
      Information and amendments included as a result of the ET
       paper on hospitality which was produced to take account of
       the Cabinet Office’s decision to publish an annual list of
       hospitality received by members of Departmental boards.
      Amendments reflecting operational changes within DWP;
      Other minor drafting changes.

2. Introduction
2.1 The provision of Hospitality and expenditure on associated
business functions (such as management conferences, working
lunches etc) is a sensitive issue which requires judgement when
considering the occasions on which such expenditure should be
incurred. A written record, demonstrating that the proposed
expenditure is justified by sound business reasons and delivers
value for money, should be produced to support this.

2.2 The amount that the Department spends on items of this nature
is regularly the subject of Parliamentary Questions, Freedom of
Information requests and press interest and therefore requires
detailed monitoring.

2.3 This document provides a framework within which all DWP
businesses must operate. As such, it does not, and could not,
provide a definitive list of “events” or attendees for which the
provision of either hospitality, or other associated business-related
expense, is appropriate. This is a decision for the officer responsible
for organising the “event” and their line management, using the
principles set out in this document.

2.4 Managers should be consulted if a third party offers hospitality
or benefits. If there are any doubts about the propriety of accepting
such offers of hospitality they must be refused.

2.5 Offers of conventional hospitality are acceptable providing they
are reasonable and appropriate to the circumstances i.e. coffee and
biscuits at meetings and working lunches of a modest nature to
further outstanding business. Hospitality of this nature does not
need to be recorded.

2.6 Invitations of a purely social nature from private sector
companies with whom the DWP has business, for example, to
sporting events or theatre or concert performances should normally
be declined. Invitations should only be accepted when attendance is
clearly in the interests of the Department. In such cases written line
management approval should be obtained.

3. Official Hospitality
3.1 Hospitality (sometimes also referred to as “entertainment”)
means “entertaining” guests from the private or public sector
(normally, non-civil service) usually over a meal and off official
premises. The provision of official hospitality in these
circumstances must directly relate to Departmental business, even
though the guest or visitor may be from an external organisation or
a foreign country.

3.2 Expenditure on the provision of hospitality is a matter of
particular sensitivity and should be authorised only where it is
expressly in the Department’s interests. There must be no
appearance of extravagance, which might give rise to criticism that
Departmental staff are benefiting at taxpayers’ expense.

3.3 This is why there is a clear distinction drawn between Official
Hospitality provided to non-civil servants and working lunches
provided to civil servants. As a general rule, it is difficult to
envisage circumstances in which it is appropriate or acceptable to
“entertain” a fellow civil servant to a meal at taxpayers’ expense
(other than justifiable working lunches). Official Hospitality is
therefore normally only extended by Ministers, Chief Executives or
Executive Members of the Departmental Board (DB).

3.4 However, as with any guidelines, there are always exceptions to
the rules. There may be occasions when managers below this level
are required to entertain non-civil servants. For example, the
Department has major contracts with the Post Office (PO). There
may be occasions when one or two senior PO staff are involved in a
business meeting with relevant DWP staff where it is genuinely
considered that a working lunch is not appropriate and the PO
representatives are taken out to lunch. In circumstances such as
these, however, the following criteria apply:

      occasions of this nature should be the exception;
      there must be sound, clearly defined business reasons;
      the justification should not be solely to reciprocate
       hospitality given on some previous occasion;
      the number of Departmental officials or “hosts” must be
       kept to the absolute minimum and they must be active
       participants in the discussion or activity concerned;
      the number of Departmental officials must not, other than in
       very exceptional circumstances, exceed the number of
      hospitality should not normally be extended to the same
       guests regularly – e.g. more than once or twice in a year;
      hospitality should only be extended to spouses in
       exceptional circumstances. Where this occurs the attendance
       of a spouse should be recorded in the hospitality register;
      the expenditure must be approved by an officer who has
       personal responsibility for a running cost budget and is at
       least of SEO (or equivalent) grade or, in cases involving the
       Permanent Secretary’s Office, by an authorised member of
       that office;
      refreshments should normally be restricted to the provision
       of a modest lunch; and
      drinks provided should be non-alcoholic except in
       exceptional circumstances and with the express prior
       permission of the appropriate authorising officer (See
       Section on Alcohol). In support of cross-government
       sustainability objectives, bottled mineral water should not be

3.5 Hospitality Registers. Each DWP Finance Director is
accountable for the collation and maintenance of a Business-wide
register which records all hospitality, received by staff from
external sources for each Business Unit. Hospitality registers should
record the following details of hospitality offered to staff, as a

      date of offer;
      description of hospitality offered;
      name of organisation making the offer;
      to whom the offer was made;
      reason for the offer; and
      name, grade and job title of authorising officer.

It should be noted that it is not necessary to record hospitality that
has been declined.

3.6 Gifts. With the exception of protocol gifts made by Ministers to
representatives of Overseas Governments, for which separate
guidance exists, hospitality must not be extended to cover the
provision of gifts. (See Gifts Giving and Receiving Departmental
Guide for further information).

4 Internal Business Functions
(Refreshments etc)
Although public funds should not be used for the “entertainment” of
civil servants, there are occasions when, in the interests of good
management, some expenditure on refreshments and / or meeting
accommodation may be appropriate. These types of event are
collectively referred to as “internal business functions”, and fall into
3 individual categories:

      management conferences;
      working lunches; and
      teas/coffees/biscuits at meetings.

Information about each of these categories is detailed below.

5. Management Conferences,
Seminars etc
5.1 Management Conferences are defined as:

“Meetings or events, the majority of which should be composed of
an "educational" element. These may be organised by senior
management to, for example, enable senior officers to meet and
bring up to date staff who are remote from their management; to
bring together officers as part of staff development or awareness
initiatives; or to bring together senior staff from other departments
or agencies to exchange views on current issues or developments”.

5.2 The circumstances outlined above are not exhaustive but the key
to classification of an event as a management conference is that they
are deemed to have “educational” or training elements as a major
part. It is also expected that such events should have a supporting
agenda detailing the activities that will be taking place. In this case,
and provided DWP complies with the agreed rules (see Section on
Tax Liability), Her Majesty’s Revenue and Customs (HMRC) has
confirmed there will be no tax liability for attendees or the

5.3 Wherever possible, management conferences and seminars
should take place on official premises. There may be cases where
the hire of rooms or the use of hotel facilities is necessary, but no
such expenditure should be authorised unless supported by a written
justification approved by a senior officer. The case for the hire of
rooms or use of hotel facilities should be judged against the
availability of reasonable alternatives, the location of the facilities
in relation to the home location of the majority of attendees, and the
associated travel costs. In accordance with Departmental policy, use
of external venues for Management Conferences must be arranged
via NYS Corporate, as set out in the Departmental Business Travel
Regulations (BTRegs) and accessed via the Intranet under
“conference bookings”.

5.4 The provision of modest refreshments, such as a buffet lunch,
may be arranged where the event necessarily takes up the greater
part of the working day and where a number of officers have
travelled from off-site. If the event is held on official premises, staff
restaurant facilities should normally be used, where available and
cost effective. Where modest refreshments are provided, officers
should, where appropriate, be reminded of the requirement to
reduce subsistence claims in recognition of the provision of
refreshments (see Section on Subsistence).

5.5 Alcoholic beverages must not be provided at public expense
except in exceptional circumstances and with prior permission of
the appropriate authorising officer (See Section on Alcohol).

6. Working Lunches
6.1 A working lunch is defined as:

“the provision of a modest lunch during a meeting between civil
servants to discuss business issues”.

6.2 It is necessary that an agenda and a list of attendees are provided
to support the provision of a working lunch. There is also an
assumption that some attendees will have travelled from off-site.

6.3 In determining whether a modest working lunch is appropriate,
the following rules apply:

       the event necessarily occupies the greater part of a normal
        working day during which business continues over lunch;
       meetings should not start or end with the lunch and should
        be held on Departmental premises wherever possible;
       if non-civil servants also attend the meeting, it is appropriate
       that the cost should still be charged to working lunches, not
      where Eurest catering facilities or a staff restaurant exist
       they must be used. Where this is not available, organisers
       can source local suppliers that will accept the Government
       Procurement Card (GPC);
      Only modest buffet menus should be used and Value for
       Money should always be considered ; and
      alcoholic drinks may not be provided at working lunches
       except with the express prior permission of the appropriate
       authorising officer (See Section on Alcohol). Individual
       orders for working lunches must be certified as received by
       the Chair of the meeting prior to payment of the invoice.

6.4 If the meeting is of sufficient length to also justify provision of
teas / coffees / biscuits, either mid-morning or mid-afternoon and
where the charges for working lunches and teas / coffees / biscuits
appear on the same invoice, it is reasonable and administratively
sensible to charge the whole expenditure to working lunches.

6.5 The EU Working Time Directive states that staff whose daily
working time is more than 6 hours must take a break of at least 20
minutes. In support of this directive, the Department’s employee
policy states that the minimum break should be 30 minutes. It
follows, therefore, that managers will need to consider the
implications on their scheduled meetings and include a formal break
of at least 30 minutes where appropriate. This should be reflected in
the agenda and consideration given as to whether a working lunch is

7. Teas, Coffees, Biscuits at
7.1 Teas, coffees (and biscuits) may be provided at public expense
for meetings at the discretion of the Chair, after consultation with
the cost centre manager as appropriate, providing the event
necessarily takes up a substantial part of the morning or afternoon.

7.2 It is generally expected that some of the attendees will have
travelled from off-site, but cost centre managers may exercise some
discretion, subject to value for money considerations. For example,
it may be less time consuming and disruptive, where large numbers
of staff are involved, to provide refreshments rather than using the
normal facilities provided – e.g. drinks machines.

7.3 When provided in addition to a working lunch, and billed on the
same invoice, it is administratively more sensible to charge the
whole bill to working lunches.

7.4 HMRC has confirmed that there are no personal taxation issues
associated with the provision of teas / coffees / biscuits at meetings.
There is, however, a value for money issue from a departmental
perspective and some judgement is therefore required.

7.5 If non-civil servants attend a routine, business-related, official
meeting, the cost of providing them with teas and coffees should
still be charged as expenditure on Teas and Coffees (or Working
Lunches, where appropriate to do so), not Hospitality.

8 Personal Events etc
8.1 It is not appropriate to provide official hospitality or
refreshments at personal events such as retirement or long service
award presentations. Treasury rules make it clear that such personal
events must not be funded at public expense.

9 Provision of Alcoholic Drinks
at Public Expense
9.1 Authorising Officers Responsibilities
9.1.1 The provision of alcoholic drinks at public expense is a very
sensitive issue and alcohol may only be provided with the express
prior written permission of the appropriate authorising officer.
Authorising officers have a particular responsibility for ensuring

      alcoholic drinks are served only in exceptional and narrowly
       defined circumstances;
      a written submission is always produced clearly setting out
       the business reasons for, and estimated cost of, the provision
       of alcohol; and
      approval, based upon the written evidence, is provided in

9.1.2 Only modest amounts of alcohol may be purchased at public
expense – a reasonable guide would be no more than two glasses of
moderately priced wine with a meal for each attendee. There must
be no suggestion of extravagance.

9.1.3 Extra care should be taken to consider the appropriateness of
the provision of alcoholic drinks at events where staff may be
travelling after the event. The Department must act with
responsibility towards its employees; in particular due recognition
must be given to the inherent dangers associated with the
consumption of alcohol and driving.

9.1.4 Authorising officers may not further delegate within their
business area their authority to approve the provision of alcohol.

9.1.5 Authorising officers should retain a record containing details
of the reason for each event – i.e. hospitality, management
conference or working lunch - the number of attendees at each event
at which alcohol is provided at public expense and the cost of the
alcohol provided. This information is required to enable the
Department to respond to potential Parliamentary Questions and to
provide the Permanent Secretary with assurance that the agreed
policy is operating as intended.

Provision of Alcohol at Public
Expense - Authorising Officers
Leigh Lewis, Permanent Secretary

Adam Sharples, Work Welfare and Equality Group Director

Chris Last, Group Human Resources Director General

Terry Moran, Chief Executive, The Pension, Disability and Carers

Richard Heaton, Director General, Strategy, Information and

Stephen Geraghty, Commissioner for Child Maintenance and
Enforcement Commission

Joe Harley, DWP Corporate IT Director General and Chief
Information Officer

Richard Paul, Group Finance Director General

Darra Singh, Chief Executive for Jobcentre Plus

Isabel Letwin, Director General of Legal Group

Sue Garrard, Director of Communications

Sue Owen, Director General for Welfare and Wellbeing Group
John Oliver, Principal Private Secretary

10 Payment / Reimbursement
10.1 Where payment is to be made by the organiser on receipt of
invoices from the supplier, invoices should be authorised and
submitted for payment in accordance with existing instructions.

10.2 If overnight accommodation is an integral part of an event –
e.g. a management conference - and is paid for by the organiser, the
costs should be charged to the appropriate account code
(management conferences etc). If attendees are required to claim
subsistence expenses themselves, the appropriate RM fields should
be completed in the usual way and expenditure accounted for under
the appropriate subsistence codes.

10.3 It is important that the correct account codes are always used.
This is necessary to avoid incorrect reporting both internally and
when responding to external requests for information such as
Parliamentary Questions or Freedom of Information Requests. In
particular, hospitality should only be used where there is an element
of entertaining guests usually over a meal and off official premises.
Where working lunches and or teas and coffees are provided to non-
civil servants as part of business meetings, these should be charged
to the appropriate account codes and not to hospitality.

10.4 The correct account codes to be used are:

      Management Conferences - 32705
      Hospitality / entertainment - 32706
      Working Lunches - 32707
      Teas and coffees - 32708

11 Impact on Subsistence
11.1 In ensuring that the provision of hospitality or internal business
functions provides value for money for the taxpayer and to comply
with Departmental travel and subsistence rules, it is the
responsibility of officers who have travelled from off-site to reduce
their subsistence claims in recognition of the provision of a working
lunch at either a management conference or official meeting. Line
managers should satisfy themselves that the necessary reduction has
been made before authorising the subsistence claim.

11.2 Any officer who does not reduce their subsistence claim
appropriately will have the claim returned to them for amendment
and, dependent upon the individual circumstances, may be required
to personally meet the tax liability applying to the particular
working lunch they received. (See Section on Tax Liability).

12. Tax Liability
12.1 HMRC, the authority on tax law, considers the provision of
lunches, dinners and refreshments as a staff benefit and therefore
taxable. Strictly speaking, the tax liability falls on the individual
member of staff in receipt of the “benefit”.

12.2 However, DWP has negotiated a set of rules with HMRC
which, provided that these are strictly adhered to and can be
demonstrated to HMRC’s satisfaction, mean that the tax liability
has been mitigated, as follows:

12.3 Management Conferences (seminars etc). A tax liability arises
due to the receipt of lunch, dinner or refreshments by individual
attendees at the taxpayers’ expense. However, a dispensation has
been agreed with HMRC, whereby the tax liability will not be
imposed provided that:

      the majority of the conference has a clear “educational” (or
       “training”) element;
      a copy of the formal agenda is retained demonstrating the
       “educational” element and including a list of attendees;
      the formal agenda demonstrates that the conference did not
       start or end with lunch or dinner; and
      all delegates are reminded of the requirement to reduce any
       relevant subsistence claim in recognition of a lunch or
       dinner at the taxpayers’ expense.

12.4 Working Lunches. Because of the complexities of monitoring
and controlling the provision of working lunches to HMRC’s
satisfaction, no dispensation has been given to DWP by HMRC.
However, DWP has negotiated an exemption whereby tax is paid on
50% of working lunches. Strictly speaking, this liability falls to the
individual in receipt of the working lunch. However, DWP has
decided that the tax liability will be met from Departmental funding
– i.e. the cost centre of the manager responsible for organising the
event. Nevertheless, managers still have a responsibility to ensure

              working lunches are provided only in accordance
               with Departmental policy; and
              staff who travel to the event are made aware of the
               requirement to reduce any relevant subsistence
               claims in recognition of the provision of a working

The Tax Advice and Assurance Group carries out checks on
working lunches and conferences. They require:

      Agenda; and
      List of attendees

The Tax Advice and Assurance Group checks the agenda to ensure
the relevant rules are adhered to e.g:

      the meeting did not start or end with a working lunch;
      the meeting covered the majority of the day etc; and
      if a conference took place that there was a majority element
       of training.

If the agenda is missing or does not meet these rules the whole
amount becomes eligible for tax. The list of attendees is checked to
ensure that Daily Meal Allowance, (DMA), is not claimed unless
hours of attendance permit the purchase of another meal. If DMA is
claimed incorrectly a refund will be requested and where a refund is
not paid the individual will be taxed.

12.5 Teas, Coffees and Biscuits at meetings. Because such items are
categorised as “trivial” by HMRC, by nature of their low intrinsic
value, no tax liability arises. Nevertheless, managers are required to
ensure that expenditure on such items cannot be considered to be
excessive, either on an individual, or collective, meeting basis.

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