Gifts and Hospitality Policy 68108

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					GIFTS AND HOSPITALITY POLICY


Policy Statement
The following outlines the ODA’s overall approach to gifts and hospitality. All
employees should read it carefully, and any questions should be directed to your HR
Manager.

It is imperative that the acceptance of gifts and hospitality by ODA employees can
stand up to public scrutiny. As a rule of thumb, gifts should be declined wherever
possible, and any offers should be reported to your line manager. Where it would be
ungracious or otherwise difficult not to accept, you should inform your line manager
of the gift, the estimated value and the donor. You must take personal responsibility
to ensure that a record is placed in the hospitality register of the ODA which is kept
by the Head of Legal. Similarly, care should be taken that no extravagance is
involved with working lunches and other social occasions.

ODA staff should not receive benefits of any kind from a third party which might
reasonably be seen to compromise their personal judgement and integrity. ODA’s
employees are only permitted to accept and keep token gifts of very low value such
as pens, diaries and small promotional items (but not even these from third parties
involved in active tenders).

In the rare circumstances where declining the gift is likely to cause major offence
(e.g. gifts from foreign dignitaries or religious leaders), the gift may be accepted and
then donated to Charity.

Where it is impractical to decline or return a perishable gift (or to donate it to a
charity) under these circumstances alone and at the absolute discretion of an
appropriate Director, the perishable goods may be kept by the ODA, to be opened
and shared with employees at a suitable staff gathering (for example at a pre-
Christmas party gathering or a lunch time briefing session). Employees are not
permitted to make use of such goods solely for their own use and therefore the
raffling or distribution of gifts to staff and their families is not permitted.

The ODA trusts its employees to use their judgement when accepting business meal
hospitality from third parties (i.e. that the appropriateness of the meal or the
frequency of such hospitality is ‘reasonable’ and can be ‘justified’). If an employee is
in any way uncomfortable with the ‘lavishness’ of the meal hospitality (or the motives
of the third party) the subject should be raised with your line manager. All hospitality
should be recorded in the Register within five working days of receipt of the offer
unless it falls into an excluded category as set out in the Guidelines below.

Where the nature of the meal invitation also includes additional hospitality (such as a
post-meal visit to a club or entertainment venue), all the received hospitality
(including the meal) must be recorded in the Register and approval sought from your
line manager.

All gifts offered and declined (or returned) in addition to those accepted and then
donated (or where perishable, shared with staff) must be recorded in a register. This
record is to protect employees by providing a record of which organisations or
individuals are offering gifts to the ODA and where the gift has gone. Please ensure
you record in the Register [by informing the Head of Legal] all details of corporate
hospitality received and gifts offered and declined (or accepted and donated to
charity) as soon as possible and ideally within five working days of receipt.




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The detailed guidance and rules that follow and accompanying annexes are ODA
policy. The guidelines and rules are therefore mandatory for all employees (including
secondees, fixed term contract staff and temporary staff) and cover:

   •   the receipt by employees (and in certain cases their immediate family) of
       business meals, corporate hospitality, gifts, fees as a guest speaker and
       sponsorship; and
   •   the provision of corporate hospitality, gifts, guest speaker fees and the
       sponsoring of events or exhibitions by the ODA.

This policy and the accompanying annexes do not apply to:
   • business and travel expenses properly incurred whilst attending events or
       occasions sponsored or supported by the ODA;
   • hospitality provided to employees who are permitted by the ODA to attend
       externally organised courses, conferences, seminars and workshops paid for
       by the ODA (providing that in all cases such hospitality is open to all or a fair
       representation of delegates or attendees as part of the attendance fee):

Employees are required to familiarise themselves with this Note and the
accompanying annexes.




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General Guidelines for the Receipt of Corporate Hospitality, Gifts, Guest
Speaker Fees and Sponsorship

A summary of when details should be recorded in the Register of Corporate
Hospitality Received and Gifts (Annex 3) by employees receiving hospitality or gifts
appears in the table below.

Please note that working lunches with colleagues from LOCOG, GLA, LDA, TfL and
English Partnerships are not regarded as hospitality for the purposes of this policy.
The general rule is that Standard and Premium Corporate Hospitality may only be
accepted by an employee if authorised by an ODA Director in advance. Please note
that special rules apply during tendering.

Receipt of Corporate Hospitality and Gifts Summary Table


Type of hospitality / gift received Record in Annex 3 Additional comments
                                    Register?
Working lunch at a third party's No
office
Out of office meal paid by third Yes                  Must be "reasonable"
party
Standard Corporate Hospitality      Yes               See Annex 1 examples
Premium Corporate Hospitality Yes                     See Annex 1 examples
(avoid)
Any / all hospitality valued £50    Yes               Director of Finance
                                                      informed
Token gifts                         No                Limited items only
Other gifts (decline or accept and Yes                Record all occurrences
donate only)
Gifts (even if declined) valued £50 Yes               Director of Finance
                                                      informed

A summary of when details should be recorded in the Register of Speaking Fees
received (Annex 4) by employees receiving fees appears in the table below:

Receipt of Speaking Fees Summary Table


Received                                  Record in Annex 4 Additional
                                          Register?         comments
Speaking fees (avoid fees if possible) Yes                  Fees go to the ODA
Gift in lieu of speaking fees (gift rules No                Record in Annex 3
apply - see Annex 1)                                        instead




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Receiving Corporate Hospitality, Gifts, Guest Speaker Fees and Sponsorship
In its first report on Standards in Public Life, the Nolan Committee noted that
although corporate hospitality guidance for public servants was implemented via
current policy documents, further improvements were recommended, namely a
central or local record of invitations and offers of hospitality accepted should be kept
in all departments and agencies.

There should be clear rules specifying the circumstances in which staff should seek
management advice about the advisability of accepting invitations and offers of
hospitality.

The ODA has adopted these recommendations and the main principles outlined in
HM Treasury’s Guidance Note 55: Ethics in Procurement. To ensure consistency
across the organisation, the accompanying Annex 1 (Guidelines for the Receipt of
Corporate Hospitality, Gifts, Guest Speaker Fees & Sponsorship) provides
mandatory guidance on accepting corporate hospitality, gifts and speaker fees;
permitted exemptions; and recording procedures (see Annexes 3 and 4) to ensure
compliance with Nolan Committee requirements.

Providing Corporate Hospitality, Gifts, Guest Speaker Fees and Sponsorship
As a public sector organisation, the ODA operates under tight constraints in its ability
to

   •   provide gifts and corporate hospitality to third parties;
   •   in its sponsorship of external events or occasions; and;
   •   in its provision of guest speaker fees.

To further ensure consistency across the organisation, the accompanying Annex 2
(Guidelines for the Provision of Corporate Hospitality, Gifts, Guest Speaker Fees &
Sponsorship) provides comprehensive guidance on this subject and procedural
information on event briefing; evaluation; and recording procedure for gifts given (see
Annex 5).

Key Principles
The general test of caution is one of common sense:

   •   Would the public question the appropriateness of hospitality or gifts received
       by an ODA employee?
   •   Would a reasonable person, assessing the hospitality, sponsorship or any gift
       provided by the ODA, judge that it was appropriate and represented
       reasonable value for money to the public purse?

Best Practice and General Rules
Employees are required to adhere to the guidance as set out in this policy and its
annexes and, where directed, to retain a proper record of their activities for
justification purposes. Failure to do so may result in disciplinary action.

Corporate hospitality, the sponsorship of events and exhibitions and the distribution
of promotional items are permissible as a tool to raise awareness of the ODA’s
activities, subject to the provisions of this policy and its accompanying annexes.
Employees and their immediate family are not permitted to receive any form of
hospitality or gifts (including working lunches) from any third party participating in an
active tender for ODA business. If employees discover they (or their immediate
family) have inadvertently breached this rule, they must notify their Director and the



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Director or the Director of Finance and Corporate Services immediately, who in turn
must seek advice from the Head of Legal.

Subject to the exceptions detailed in Annex 1, employees will be required to record
the receipt of all corporate hospitality (except business meals); details of gifts
declined, received and donated; and details of any fees received as a guest speaker
at conferences and the like.

The Register of Corporate Hospitality Received and Gifts (Annex 3 to this policy);
and the Register of Speaking Fees Received (Annex 4 to this policy); is held by the
Head of Legal. The Register of Gifts (Provided) (Annex 5 to this Note) is held by the
Head of Legal.

Annex 2 provides examples of hospitality and sponsorship activities that:

   •   usually will comply with the ODA objectives;
   •   do not comply as they are considered excessive, novel, contentious or are
       repercussive proposals

The Annex 2 examples should also be considered when assessing the
appropriateness of purchasing and the distribution of promotional items.

Providing and Receiving Corporate Hospitality
In choosing to accept or provide corporate hospitality, employees must consider if
attendance at an event is appropriate in the light of our current business and our
relationships with external organisations and or individuals. If there is any concern as
to the propriety or value for money of provision of corporate hospitality, the matter
should be referred to the Head of Governance for a decision. A rule of thumb should
be to err on the side of caution. The following rule of thumb should be applied when
considering if the acceptance of corporate hospitality needs to be recorded in the
Register of Corporate Hospitality Received & Gifts. Where the ODA does not directly
pay for all or part of the event that is being attended, the details must be recorded in
the Register. There are only limited exceptions to this rule.

All meals, hospitality and gifts, either given or received, will be open to public
scrutiny. If you have any doubts as to the appropriateness of accepting specific
hospitality or gifts, you must seek advice from the Head of Governance or the
Director of Finance and Corporate Services.

Providing and Receiving Sponsorship
The Annex 2 guidelines apply to whole or part sponsorship of an event staged by an
outside organisation. As a public sector organisation, the ODA operates under tight
constraints in its ability to provide sponsorship. Annex 1 also provides guidance to
employees on the receipt of sponsorship from other parties.

All employees with responsibility for sponsorship are required to adhere to the
guidance in this policy and the accompanying Annexes 1 & 2 and to retain a proper
record of their activities for justification purposes. Failure to do so may result in
disciplinary action. Provision of sponsorship must be demonstrably linked to the
ODA’s current business and considered in the light of our relationships with other
partner organisations. Attention should also be given to the potential for the
sponsorship to be considered novel, contentious or repercussive. If there is any
concern as to the propriety of the provision of sponsorship, the matter should be
referred to the Head of Governance for a decision.



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ODA Events - Briefing and Evaluation
To ensure all ODA events are appropriately resourced, branded and collated on a
central database, an Events & Exhibitions Briefing Document should be completed.
Similarly, all staff attending ODA sponsored exhibitions and events should complete
an Events and Exhibitions Report Document to evaluate success and return these to
the Head of PR and Media. Copies of both of these documents may be found
attached to the accompanying Annex 2.

Providing and Receiving Gifts
The Head of Legal holds the Register of Gifts (see accompanying Annex 5). Gifts to
third parties or to ODA employees (or their relatives) are not a normal aspect of ODA
expenditure. However, any gift approved by the ODA will be recorded in this
Register to ensure compliance with ODPM requirements. With the exception of token
gifts detailed in Annex 1, employees and their families are not permitted to accept
gifts from third parties working for the ODA (or those seeking work from the ODA).

External Communication and Implementation
This policy and the accompanying annexes will be placed on the ODA Publication
Scheme (Freedom of Information) and open to public inspection. Employees are
reminded to ensure that their records are kept up to date as the ODA may be
required to disclose information from the Register of Corporate Hospitality Received
and Gifts under the Freedom of Information Act provisions or to our Sponsor
Department or auditors without warning.


Human Resources
March 2007




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Annexes



  •   Annex 1 – Guests, Speaker Fees and Sponsorship;

  •   Annex 2 – Guidelines for the Provision of Corporate Hospitality, Gifts,
      Guest Speaker Fees & Sponsorship;

  •   Annex 3 – Register of Corporate Hospitality Received and Gifts;

  •   Annex 4 – Register of Speaking Fees Received;

  •   Annex 5 – Register of Gifts (Provided)




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                                                                              Annex 1

Corporate Hospitality, Gifts, Guest Speaker Fees & Sponsorship Policy
These Guidelines provide best practice policy for employees that receive or are
offered corporate hospitality, gifts, guest speaker fees or sponsorship in connection
with their duties at the ODA. The Guidelines in this Annex have been prepared in line
with the Nolan Report and HM Treasury guidance. The ODA endorses the main
principles outlined in HM Treasury’s Guidance Note 55: Ethics in Procurement.
These Guidelines are mandatory for all the ODA employees (including secondees
and fixed term contract staff).

This annex does not apply to:
   • the provision by the ODA of corporate hospitality, gifts or general sponsorship
       (see Annex 2 Guidelines for the Provision of Corporate Hospitality, Gifts &
       Sponsorship of the accompanying Best Practice Note on this subject).
   • business and travel expenses properly incurred by employees whilst
       attending events or occasions sponsored or supported by the ODA (see
       Business Expenses in the Employee Handbook in relation to reimbursement
       of employees costs).
   • hospitality provided to employees who are permitted by the ODA to attend
       externally organised courses, conferences, seminars and workshops which
       are paid for by the ODA providing that in all cases such hospitality is open to:
       all delegates or attendees as part of the attendance fee; or in the case of very
       large events is open to a fair representation of attendees.
   • gifts or incentives provided by recognised business 'frequent traveller' loyalty
       schemes and awarded during travel paid for by the ODA.
   • vouchers or financial compensation awarded due to delays during travel paid
       for by the ODA.

This Annex therefore applies to:
   • all other events and occasions staged by external organisations and attended
      by the ODA employees free of charge or at a discounted rate; and business
      meals, drinks, lectures, workshops and similar networking opportunities
      sponsored or paid for by all external third parties (including suppliers and
      contractors).
   • gifts offered to employees.
   • payment for speaking engagements.

The Sponsorship section in this Annex applies only to circumstances where the ODA
(or individual employees or their relatives) are offered sponsorship opportunities from
other organisations or individuals. Employees are reminded that the General Rules
detailed in the accompanying Corporate Hospitality, Gifts, Guest Speaker Fees &
Sponsorship Best Practice and General Rules section above apply to this Annex.

The Register of Corporate Hospitality Received and Gifts
The Head of Legal holds a Register of Corporate Hospitality Received & Gifts (the
Register). A sample Register is provided in Annex 3. Details of the holders
responsible for maintaining the Register are also listed on the 'Checklist' section.
Subject to the exceptions listed in these Guidelines, the ODA requires employees to
record in the Register all details of corporate hospitality received and gifts offered
and declined (or accepted and donated to charity) as soon as possible and ideally
within two working days of receipt.




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The Register record should be passed to an appropriate individual for endorsement
(for example the employee's line manager, a Head of Department, or a Director). The
holder of the Register is required to report all corporate hospitality with an estimated
value of more than £50 to the Director of Finance. Employees should note that they
are required to periodically self-certify that their personal Register records are up to
date. The procedure for complying with this requirement will be notified to employees
annually. Employees failing to self certify when requested, or failing to record
corporate hospitality received or gifts declined (or accepted and donated to charity)
may be subject to the ODA disciplinary procedures.

Receiving Corporate Gifts and Hospitality
Employees and their families are not permitted to receive any form of gift or
hospitality (including working lunches) from any third party participating in an active
tender for the ODA’s business. This rule also applies where existing panel
consultants or suppliers are tendering for the ODA business outside their existing
panel or supply contract. Where existing panel consultants are involved in active
inter-panel competitive quotations, employees should use common sense to
determine if accepting a business meal, other forms of hospitality or gift from them is
likely, or may be perceived as potentially affecting, the ODA’s impartiality in awarding
the contract. If in doubt, the meal or hospitality should be declined.

The ODA seeks to protect employees from allegations of impropriety by ensuring that
the acceptance of all forms of corporate hospitality is transparent, approved and,
where appropriate, recorded. The main risk of challenge is acknowledged to be
when employees receive standard or premium forms of corporate hospitality, rather
than modest business meals provided by third parties.

Working Lunches at a Third Party's Office
The occasional office-based working lunch provided by a third party to an ODA
employee during a business visit requires no previous approval and need not be
recorded in the Register.

Out of Office Business Meals
The ODA trusts its employees to use their judgement when accepting business meal
hospitality from third parties (i.e. that the appropriateness of the meal or the
frequency of such hospitality is ‘reasonable’ and can be ‘justified’). Although prior
approval to attend a business meal is not required, employees should wherever
possible make their line manager aware of the business meal and should record it in
the Register. This is to protect employees from challenges by others who may not be
aware that the meal is deemed to be ‘reasonable’ and ‘justified’. If an employee is in
any way uncomfortable with the ‘lavishness’ of the meal hospitality (or the motives of
the third party) the subject should be raised with their Director.

Where the nature of the meal invitation also includes additional hospitality (such as a
post-meal visit to a club or entertainment venue), all the received hospitality
(including the meal) must be recorded in the Register and approval sought from the
Director.

Standard Corporate Hospitality
As mentioned previously, employees are not required to record in the Register details
of hospitality provided and paid for (or sponsored) by the ODA. Similarly, a Register
record is not required for any hospitality provided whilst attending a work-related
conference, lecture, seminar or similar educational event organised by a third party,
but where attendance is paid for by the ODA (providing such hospitality is open to all,
or in the case of very large events, is open to a fair representation of attendees).


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An example not requiring recording in the Register would be a delegate-only cocktail
party or dinner during a conference where the ODA has specifically paid fees for an
employee to attend or where the ODA receives a set number of places as part of an
'official sponsor' package deal. However, employees must record in the Register all
other standard forms of corporate hospitality which are not financially supported by
the ODA, even when the employee is attending the event as an 'official'
representative of the ODA. This policy ensures that there is complete transparency
as to what is being accepted from third parties and what is being paid for by the
ODA. For example, drinks receptions and launch parties promoted by either public or
private sector organisations will require the details to be recorded by the employee in
the Register. Attending lectures, conferences, seminars or any other similar
educational event or function as a guest of a third party and where the ODA is not
financially supporting the event or paying for delegate places will always require
recording in the Register. The examples here are not exhaustive and there will
always be grey areas. In all such cases employees should use common sense and
where necessary err on the side of caution by recording details in the Register if they
are at all unclear if an event is paid for by the ODA.

As a rule of thumb, if the ODA is directly paying for all or part of the event, the
employee is not required to record the details in the Register.

Premium Corporate Hospitality
Offers of premium corporate hospitality such as entertainment, participating in or
attending sporting events, free trips, accommodation and other travel-related
hospitality from external third parties, should be avoided.
However, it is acknowledged that there are various events sponsored by the property
and construction industry where attendance will produce good networking
opportunities for the ODA. Wherever possible the ODA will prefer to pay its own way
to attend appropriate events and will nominate relevant employees to attend.
Where an invitation to attend such an event is only available from (and will be paid in
part or in full by) a third party, employees should not attend without seeking prior
written approval from their Director or the Board. The employee will in all cases be
required to record full details of the hospitality in the Register.

Employees should note that the holder of the Register is required to report all
corporate hospitality with an estimated value of more than £50 to the Director of
Finance and Corporate Services (or in the case of that Director, the Chief Executive).

Fact-finding or Business Review Visits Involving Contractors or Suppliers
Employees are not generally permitted to receive from external third parties any paid
travel, accommodation or general subsistence (except for de minimis travel such as
taxi sharing and the like) when conducting fact-finding investigations, business
review visits or any such similar meeting. Accepting business meals during such a
visit is permitted in accordance with the previous guidance in this annex. In rare
circumstances it may be impractical for the ODA to independently arrange travel or
accommodation (for example where the supplier provides on-site accommodation in
a remote location). In all cases, prior approval will be required from the Director or
the Director of Finance and Corporate Services or the Chief Executive and details
must be recorded in the Register.

Receiving Gifts
ODA employees are only permitted to accept and keep the following gifts:




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   •   token gifts of very low value such as pens, diaries and small promotional
       items (except from third parties involved in active tenders).
   •   "written off” ODA promotional stock.
   •   modest floral tributes (or similar) approved by the ODA for employees or their
       relatives.

Accepting and keeping all other gifts is not generally permitted. In the rare
circumstances where declining the gift is likely to cause major offence (e.g. gifts from
foreign dignitaries or religious leaders), the gift may be accepted and then donated to
charity (with a record noted in the Register). However, special rules apply to
perishable gifts and these are listed below.

It is common in a number of industries to distribute alcohol and perishable goods
such as chocolates and cakes to trading partners as a gesture of good will, especially
before Christmas. The ODA policy is that employees should decline or return these
gifts unless to do so would cause major offence. All non-perishable goods that are
accepted must be donated to an appropriate charity. Where it is impractical to decline
or return a perishable gift (or to donate it to a charity) under these circumstances
alone and at the absolute discretion of an appropriate Director, the perishable goods
may be kept by the ODA, to be opened and shared with employees at a suitable staff
gathering (for example at a pre-Christmas party gathering or a lunch time briefing
session). Under no circumstances are employees permitted to make use of such
goods solely for their own use and therefore the raffling or distribution of gifts to staff
and their families is not permitted. It should be noted that all gifts offered and
declined (or returned) in addition to those accepted and then donated (or where
perishable, shared with staff) must be recorded in the Register. This record is to
protect employees by providing a record of which organisations or individuals are
offering gifts to the ODA and where the gift has gone.

Employees should note that the holder of the Register is required to report all gifts
offered to or accepted by staff (even when declined) with an estimated value of more
than £50 to the Director of Finance and Corporate Services.

Any attempt to undermine the impartiality of employees by the offer of substantial
gifts or other inducements should be reported to the Head of Governance or the
Director of Finance and Corporate Services immediately.

Donation of surplus items of equipment (e.g. redundant computers to an employee
nominated school or registered charity) or the distribution of obsolete (written off)
ODA stock to staff (e.g. old logo promotional items) will require the approval of the
relevant Director or the Director of Finance and Corporate Services. In each case,
the approver will be required to record the details of the beneficiary and the items
donated or distributed in the appropriate asset register (or such other recognised
system that may be in place to record stock disposal).

Fees for Speaking Engagements
Offers of fees for speaking engagements are usually discouraged. Fees may only be
accepted on the basis that they are payable to the ODA to cover associated costs
and expenses. The ODA prefers to arrange and pay for its own travel,
accommodation and subsistence arrangements wherever possible.

The ODA maintains a Register of Speaking Fees Received (Annex 4), held by the
Head of Legal alongside the Register of Corporate Hospitality Received & Gifts.
Where the payment for a speaking engagement is a gift of any description, the usual



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rules on accepting gifts apply. However, the details of such a gift in lieu of payment
need only be recorded in the Register of Corporate Hospitality Received and Gifts.

Receiving Sponsorship
This section of the Guidelines covers sponsorship offered to ODA employees and
their families, as well as general sponsorship offered by third parties to support ODA
events. Annex 2 provides guidance for the sponsorship and support of third party
organised events.

Individuals Receiving Sponsorship
Employees and their families are not permitted to receive 'personal' direct
sponsorship from third parties providing (or tendering for) services, works or supplies
to the ODA. The receipt of indirect sponsorship (for example a construction company
Partner sponsoring a school football team where an employee's child participates) is
permitted, providing the sponsorship has not been brokered in the first place by the
ODA. It should be noted that the ODA rarely sponsors individual employees or their
families to participate in charity events or sports activities. However, where an ODA
team is participating in an event, any specific requests should be addressed to the
Head of PR and Media.

The ODA Receiving Sponsorship or Exhibitor Fees
The ODA does not endorse services or products from private sector organisations or
charities unless such endorsement is by way of association. Sole sponsorship by the
private sector of any ODA event is usually inappropriate and rarely permitted.
Offers of sponsorship from more than one private sector organisation; or a request to
buy exhibition space during ODA organised exhibitions or conferences; or a request
for sole sponsorship by a public body must always be submitted for approval to the
Head of PR and Media, who will determine the appropriateness of the sponsor /
exhibitor for the event, whilst bearing in mind the aims and objectives of the ODA.




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                                                                              Annex 2
Corporate Hospitality, Gifts, Guest Speaker Fees & Sponsorship Policy

Scope
This annex paper sets out best practice policy for all staff who provide corporate
hospitality, give gifts or sponsor events and exhibitions on behalf of the ODA. The
guidelines have been prepared in line with ODPM / HM Treasury practice. These
Guidelines are mandatory for all ODA employees (including secondees, fixed term
and contract staff).

This Annex includes all events or occasions organised by the ODA (including those
for third parties) and those staged by outside organisations for which the ODA
provides part or complete funding. This Annex also covers the sponsorship of
materials such as publications and websites and the provision of gifts by the ODA to
third parties and to the ODA staff or their relatives.

This Annex does not cover:
   • expenses incurred whilst attending events or occasions sponsored or
       supported by the ODA (see Business Expenses section in the Employee
       Handbook in relation to reimbursement of staff costs).
   • ODA staff receiving corporate hospitality, gifts, sponsorship or payment for
       speaking engagements (see Annex 1 Receipt of Corporate Hospitality, Gifts,
       Guest Speaker Fees & Sponsorship Guidelines).
   • the purchase of promotional items of modest value as approved by the Head
       of PR and Media featuring the ODA logo and distributed at recognised ODA
       events.
Employees are reminded that the General Rules detailed in the accompanying
Corporate Hospitality, Gifts, Guest Speaker Fees & Sponsorship Best apply to this
Annex.

Providing corporate hospitality and gifts
Corporate hospitality can be provided as a tool to raise awareness of the
organisation’s activities, normally within the following range of objectives:

   •   To promote the ODA’s work to key partners and stakeholders
   •   To assist in the general marketing of the work of the ODA
   •   To promote a specific site as a development or occupation opportunity
   •   To mark project milestones
   •   To launch a new publication, programme or initiative
   •   To facilitate community awareness and participation

All such events should be outlined in detail (consistent with information required in an
Events & Exhibitions Briefing Document - sample attached to this Annex). Corporate
hospitality events arising during the course of the year should be agreed with that
team’s Head of Department / Director and approved by the Head of Governance.

Appropriateness of Corporate Hospitality and Value for Money
All corporate hospitality events should have a demonstrable link to the work of the
ODA and represent good value for money. Sporting and artistic events unrelated to
the ODA’s areas of operation would not normally be appropriate. A request to
participate in an unrelated event should always be addressed in the first instance to
the Head of PR and Marketing.




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Corporate hospitality must not be provided for party political activity or events that
conflict with our own objectives or the objectives of our sponsoring department or
partners.

To represent value for money, the investment should not only be in proportion to the
value of the project or initiative to the organisation (i.e. budget or receipts) but should
also be within a reasonable level of expenditure per head.

Examples of corporate hospitality provision, which would be considered excessive,
are:

   •   The hosting of sit-down meals for large numbers of guests, where, for
       example, the meal is unrelated to an activity such as an ODA conference.
   •   The purchase of tickets for sporting and artistic events, where these events
       are unrelated to our areas of operation.
   •   The provision of inappropriate levels of entertainment for a public sector
       organisation, e.g. expensive equipment or luxury leisure pursuits.
   •   The hire of unreasonably expensive venues in relation to market rates,
       relevant audience and public sector expenditure considerations.
   •   Payments on behalf of third parties enabling them to attend luxury events
       provided by third parties.
   •   Novel, contentious or repercussive proposals (apart from the examples given
       above) could be activities where:
   •   The expenditure is out of proportion to the ODA’s activities and budgets.
   •   Value for money is not demonstrable via a link to our activities or a
       reasonable expectation of increased business or receipts.
   •   The per head cost exceeds a reasonable value for money threshold in
       relation to the nature of the event.
   •   Events are related to party political activity, conflict with the ODA’s objectives
       or conflict with the objectives of our Sponsor Department or partners.

Corporate Hospitality Briefing and Evaluation
To ensure all corporate hospitality events are appropriately planned, resourced,
branded and collated on a central database, an Events & Exhibitions Briefing
Document should be completed by the organiser and sent to the Head of PR and
Media.

Similarly, all staff attending ODA sponsored exhibitions and events should complete
an Events and Exhibitions Report Document to evaluate success and send these to
the Head of PR and Media. Copies of both the above mentioned forms are attached
to this Annex.

Each department should ensure that their events are given individual cost codes to
monitor actual spend versus projected spend and to allow a full value for money
assessment to be made of the event.

The Provision of Gifts
Gifts to third parties or to ODA employees (or their relatives) are not a normal aspect
of ODA expenditure. However, where a gift is specifically purchased for a third party
(or an employee) these Guidelines will always apply. Any gift with a value of more
than £50 must also be authorised in advance of purchase by the Chief Executive.
Every gift (regardless of value) must be recorded in the Register of Gifts (Provided)
and Special Payments to ensure compliance with Sponsor Department guidance
(currently a maximum value of £1,000 per gift item and a total delegation of £10,000


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GIFTS AND HOSPITALITY POLICY


in any financial year). The Register of Gifts (Provided) and Special Payments is held
by the Head of Legal (see Annex 5).

The Head of Governance will be responsible for setting the ODA policy on the
provision of corporate gifts, however, it is up to each budget holder to justify in writing
why they have approved expenditure to purchase the gift and attach this to Annex 5.

Where appropriate, modest floral tributes (or similar) may be presented to staff, their
relatives or other third party business contacts on behalf of the ODA or the Board to
show the organisation’s appreciation, congratulations or sympathy. Payment for
such tributes should be authorised by an appropriate Director and charged by
accounting staff through the Petty Cash system to 'Sundries', or such other
procedure as authorised. For the avoidance of doubt, the purchase of approved
promotional items of modest value which feature the ODA logo and distributed to
visitors or guests at recognised ODA events are not considered to be gifts within
these guidelines.

Donation of surplus items of equipment (e.g. redundant computers to an employee
nominated school or registered charity) or the distribution of obsolete (written off)
ODA stock to staff (e.g. old logo promotional items) will require the approval of the
relevant Head of Department / Director or the Director of Finance and Corporate
Services. In each case, the approver will be required to record the details of the
beneficiary and the items donated or distributed in the appropriate asset register (or
such other recognised system that may be in place to record stock disposal).

Payment of Speaker Fees
The ODA will reimburse reasonable expenses paid to guest speakers attending
conferences and events it organises or supports. The Head of PR and Media must
approve all payments prior to final agreement with the guest speaker. It is standard
practice in the public sector to engage keynote and guest speakers who provide their
services free of charge. However from time to time a paid keynote speaker may be
justifiable and written permission will be required from the Head of Governance
before contractual terms are agreed.

Sponsorship of Exhibitions and Events
Provision of Sponsorship
There must be not only a demonstrable link to our business for the provision of
sponsorship, but also a proper business case and the event should represent good
value for money. An expected return on the investment must be specified in either
qualitative or quantitative terms, i.e. increased awareness by a particular audience or
an increased number of enquiries for a particular site or initiative.
Sponsorship of events should be outlined in detail and budgeted as part of the
normal annual corporate Communications Strategy, and the Directorate Business
Planning cycles, as approved by the Board. Sponsorship opportunities arising during
the course of the years should be agreed with that team’s Head of Department /
Director and approved by the Head of Governance. Similar rules will apply to the
sponsorship of publications and new media opportunities (for example web sites).

Appropriateness of Sponsorship and Value for Money
Except in exceptional circumstances sponsorship of sporting and artistic events
unrelated to the ODA areas of operation would not normally be appropriate. On such
occasions a request to participate should always be addressed in the first instance to
the Head of PR and Media. Value for money and avoidance of novel, contentious or
repercussive proposals should also be major factors in assessing sponsorship
opportunities. The investment in any sponsorship opportunity should be in direct


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GIFTS AND HOSPITALITY POLICY


relation to the value of the project or initiative to the organisation (i.e. budget, receipts
or overall awareness and profile).

All sponsorship proposals for high-profile events and materials (e.g. televised events,
magazine special issues, newspaper supplements and websites) should be raised
with the Head of PR and Media. As with corporate hospitality, no sponsorship should
be provided for party political activity or events that conflict with our own objectives or
the objectives of our Sponsor Department or partners.

The ODA Receiving Sponsorship or Exhibitor Fees
The ODA does not endorse services or products from private sector organisations or
charities unless such endorsement is by way of association (such as where the ODA
is a shareholder in a joint venture partnership or other similar delivery vehicle). Sole
sponsorship by the private sector of any ODA event is usually inappropriate and
rarely permitted.

Offers of sponsorship from more than one private sector organisation; or a request to
buy exhibition space during ODA organised exhibitions or conferences; or a request
for sole sponsorship by a public body must always be submitted for approval to the
Head of PR and Media, who will determine the appropriateness of the sponsor /
exhibitor and the event bearing in mind the aims and objectives of the ODA.

Sponsorship Briefing and Evaluation
To ensure that all sponsored events are appropriately planned, resourced, branded
and collated on a central database, an Events & Exhibitions Briefing Document
should be completed by the sponsor and sent to the Head of Press and PR for
inclusion on the Corporate Calendar.
All staff attending ODA sponsored exhibitions and events should complete an Events
and Exhibitions Report Document to evaluate success and send these to the Head of
Press and PR.




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GIFTS AND HOSPITALITY POLICY


                                                                               Annex 3

Corporate Hospitality, Gifts, Guest Speaker Fees & Sponsorship Policy

Code abbreviations:
   • H (hospitality received)
   • HD (hospitality declined)
   • GRD (gift received and then donated)
   • GD (gift declined)

N.B. Holders of this Register are required to report all recorded hospitality or gifts
with a value of £50 or higher to the Director of Finance and Corporate Services.

Register of Corporate Hospitality Received & Gifts
Code    Date           ODA      Name of              Describe the     Where         Authorising
        hospitality    employee organisation         hospitality or   accepted:     officer
        /gift                   and/or               gift and its     reason for    (Director)
        received,               individual           monetary         acceptance
        declined or             offering or          value.           of gift/
        donated                 providing the                         hospitality
                                hospitality or
                                gift. Contact
                                details of
                                charities
                                receiving a
                                donated gift.




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GIFTS AND HOSPITALITY POLICY


                                                                        Annex 4

Corporate Hospitality, Gifts, Guest Speaker Fees & Sponsorship Policy

Register of Speaking Fees Received

Date of Name of Conference     Details   of   the Fees Authorising
payment employee or      event conference      or paid officer(Director)
                 organiser     event    including
                               subject, location
                               and date




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GIFTS AND HOSPITALITY POLICY




                                                                       Annexe 5
REGISTER OF GIFTS (PROVIDED)
Sponsor department delegated authority permits the ODA to purchase and provide
gifts up to a maximum value of £1,000 per gift item and a total gift purchase
delegation of £10,000 in any one financial year.

All gifts provided by (or on behalf of) the ODA must be justified in writing and
approved in advance by the budget holder and recorded in this Register to ensure
the Sponsor Department delegations are not breached.

Any gift or payment with a value of more than £50 must also be authorised in
advance by the Chief Executive.

Register of Gifts Provided

Date Name of       Name of gift    Describe gift Value Date      Signature
gift  employee     recipient and   and reasons of gift approved and name of
given giving the   their           why this is         by budget gift
      gift         company or      being       given   holder    authorising
                   organisation    (attach                       officer   (the
                                   justification                 budget
                                   paper where                   holder)and
                                   appropriate)                  the      Chief
                                                                 Executive if
                                                                 over £50




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