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GIFTS AND HOSPITALITY POLICY AND PROCEDURES

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					                                                                   GIFTS AND HOSPITALITY POLICY
                                                                               AND PROCEDURES




   1.0 Definition
   We expect excellent standards of conduct from everyone at Carillion and this includes being open and
   transparent about gifts and hospitality provided or received.


   Gifts include any item of value provided to a third party or their employees or received from a third party by
   Carillion or its employees. (See table below in 5.1.2. for definitions of value)

   Hospitality includes any business entertaining, such as travel, accommodation, meals and invitations to events
   given to Carillion and its employees by third parties or given by Carillion to third parties.


   2.0 Scope
   This policy applies to all employees of Carillion, its subsidiaries and associated companies worldwide and joint
   ventures.


   3.0 Objective
       To ensure that Carillion commits to all of our values by providing clear guidance.
       To communicate Carillion’s requirements in respect of the acceptance and receipt of gifts and hospitality.
       To ensure that employees do not exploit their position for personal benefit.


   4.0 Principles
   4.1 Gifts and hospitality
   As a general principle we discourage employees from accepting or giving gifts or hospitality. Whilst we accept
   that the occasional modest giving and acceptance of gifts and hospitality may be a legitimate contribution to
   good business relationships, it is essential that they do not influence, nor could be perceived as influencing,
   business decision making. We must all consider whether the giving or receiving of a gift or hospitality is
   appropriate. It is prohibited to offer or receive gifts or hospitality that could influence or be perceived to be
   capable of influencing the outcome of transactions or decisions relating to Carillion’s business.


   4.2 Policy discretion
   A Carillion business unit or function may at its discretion impose a more onerous policy. Where this applies,
   individuals are subject to the more stringent requirements of the business or function.




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   5. Procedure
   5.1 Receiving gifts or hospitality:

   5.1.1 The Principle
   In principle, Carillion does not permit employees to receive gifts from third parties. Money may never be
   accepted. Gifts should be returned to the third party with an explanation to the effect that it is not Carillion policy
   to accept gifts. When it is considered that declining a gift may cause offence, use the table below to ensure the
   correct procedures are followed.


   5.1.2 Gifts and Hospitality Guide
                 Benefit received                                               Procedure
   Small Gift – below £25.                       Individuals may accept. No record or approval required.
   (Includes diaries, calendars, pens etc)
   Gifts in excess of £25                        Individuals may accept gifts over £25 however they must be
   (i.e. bottles of champagne, spirits,          surrendered into departmental or business raffles to allow all to
   tokens, vouchers, presents)                   participate in the opportunity to benefit (and raise funds for Company
                                                 approved charities where appropriate). Gifts in excess of £100 must
                                                 be approved and recorded*.
                                                 For all gifts accepted the following steps apply:
                                                          Value between £25 and £100 – Inform Line Manager and
                                                          surrender.
                                                          Value between £100 and £500 – Obtain written approval from
                                                          Line Manager, surrender and record*.
                                                          Value in excess of £500 – Also obtain written approval from
                                                          the relevant Business Unit SMT, surrender and record.
                                                          (Business Unit SMT require approval from CET member and
                                                          the CET require authorisation from an Executive Director.)
   Attendance       at   business   functions    Inform and obtain verbal consent from your Line Manager prior to the
   associated with your role in Carillion or     event.
   your        Professional   status     (i.e.
   professional dinners/events).
   Attendance at purely social events (i.e.      Discouraged. In all cases (irrelevant of value) seek prior written
   sporting events, horse racing, golf           approval from your line manager and record*. If the value is in excess
   days etc)                                     of £500, prior written approval should also be obtained from a member
                                                 of the relevant Business Unit SMT. (Business Unit SMT require



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                                                approval from CET member and the CET require authorisation from an
                                                Executive Director).
   Hospitality   accepted    (i.e.   lunches,   Ensure that is it reasonable, proportionate, not lavish and that Carillion
   dinners)                                     would be willing to reciprocate.
                                                Where hospitality exceeds £100 approval and recording is required:
                                                        Value between £100 and £500 – Obtain written approval from
                                                        Line Manager and record*.
                                                        Value in excess of £500 – Also obtain written approval from a
                                                        member of the relevant Business Unit SMT and record*.
                                                        (Business Unit SMT require approval from CET member and
                                                        the CET require authorisation from an Executive Director.)
   (Approvals must be written but could be in the form of an email. The approval must be kept for audit purposes).


   * Oracle ESS must be used to record gifts and hospitality. Manual processes to record gifts should be used
   where Oracle HR is not in place.


   When determining the monetary value of a benefit you must take into account market value. Where no
   monetary value can be placed on a benefit you must consider if the acceptance could give rise to a conflict of
   interest or be perceived to be inappropriate and seek guidance from your Line Manager.


   5.2 Giving Gifts or Hospitality:
   5.2.1   The Principle.
   The giving of gifts to third parties is discouraged. In determining whether the giving of a gift is appropriate,
   consideration should be given to the recipient, the value of the gift and the reason for it.


   Hospitality given should be within the boundaries of the Carillion Business Travel and Expenses Policy and the
   Fit for the Future guidance. Hospitality may be offered if it is reasonable in all the circumstances to do so and is
   proportionate and not lavish or extravagant.


   5.2.2 What steps do I take?
   It is essential that the following steps are taken when giving gifts or hospitality:


           Gifts or hospitality given must be pre-authorised by a member of the relevant Business Unit SMT. At
           Business Unit SMT level approval will be by the CET member. For the CET, authorisation will be by an




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           Executive Director. (The Entertainment Pre-Authorisation Form must be completed, or for gifts, a
           documented record of approval must be maintained).
           Benefits provided with a value in excess of £100 in total must be recorded on the Oracle ESS system,
           with details of the individual or customer to whom it was provided. Manual processes to record benefits
           should be used where Oracle HR is not in place.
           Gifts and hospitability given must be consistent with the policy of the applicable third party organisation.
           Under no circumstances shall Carillion partners (including suppliers, business partners, joint venture
           partners, sub contractors or advisors) be asked to contribute towards the cost of entertaining customers
           on behalf of Carillion.
           There must be limitations on the number of Carillion staff benefiting from hospitality.
           There is a risk that gifts or hospitality provided to foreign public officials may be construed as a bribe, in
           these circumstances pre approval must be given by a member of the relevant Business Unit SMT.


   5.2.3 Where do I go for help or advice?
   If you would like further advice please contact your:
   Line Manager,
   Business Unit HR Director, or
   Business Unit Legal Director.


   To assist a couple of scenarios are provided below:


   Scenario 1:
   Mary works in Supply Chain on a major hospital Facilities Management Contract and has a close relationship
   with ASupplier Limited. ASupplier has sent her a case of expensive champagne for a Christmas treat (worth in
   excess of £100). ASupplier explains that this is to thank her for their close working relationship over the last 10
   years and that ASupplier looks forward to working with Mary for another 10 years. Mary has known the
   Managing Director of ASupplier, Nasreen for 10 years and knows Nasreen would be upset if Mary rejected this
   gift.


   Mary accepts the gift but makes it clear to Nasreen that it will be put into a department raffle in aid of charity in
   line with Carillion policy. Mary notifies her Line Manager that she has done this and records the gift and actions
   taken on ESS.




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   Scenario 2:
   Mary is still employed in the supply chain team on the hospital contract and the matter of the case of
   champagne was resolved amicably and in such a manner as satisfied all our ethical requirements.


   Mary is out for dinner with another friend of hers, Donald, who happens to have recently joined BSupplier
   Limited. BSupplier Limited have wanted to do work for Carillion on this particular hospital contract for some time.
   Mary happens to mention that two weeks ago her heating broke down and she hasn't been able to get it fixed.
   Donald offers to send some engineers from BSupplier Limited to Mary's house to fix the problem for free.


   The value of the work could easily be construed as influencing Mary's decision because of her position in the
   supply chain team. Mary cannot accept this offer and to do so could have the appearance of a bribe. She should
   reject it and report the fact it was offered to her Line Manager. Mary should also consider whether her friendship
   with Donald creates a conflict of interest that she should report further.




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