Gifts and Hospitality policy statement and procedure PART A – Scope, definitions and application 1.
Scope
1.1
This guidance applies to all staff including executive and non-executive directors.
2.
Definitions
2.1
Meaning of ‘gifts’ and ‘hospitality’
2.2
The terms ‘gifts’ and ‘hospitality’ have wide meaning and no conclusive definition is possible. For the purpose of this policy, the following definitions apply:
What is a gift? 2.3
Gifts, include but are not limited to: – –
The free gift of any goods or services provided to employees or as a gift to the organisation. The opportunity to acquire any goods or services at terms not available to the general public, including additional services, privileges and other advantages related to your position at Keltbray (benefits and favours). This does not include discounts which may be negotiated by Keltbray on behalf of all employees. – The opportunity to obtain goods or services not available to the general public. What does hospitality mean? 2.4
Hospitality refers to the offer of food, drink, accommodation or entertainment (except that which is provided by Keltbray) or the opportunity to attend, any cultural, business or sporting event. Common hospitality includes lunches or dinners provided by external bodies or tickets to external events.
2.5
Where travel or accommodation associates with attendance at an international function, event or similar is made on Keltbray business and paid for by a third party, a gifts and hospitality declaration should be made. Travel and /or accommodation will, where the expenditure is reimbursed to Keltbray, also be an expense, and should be approved and reported as such.
PART B – Principles 3.
Principles to apply
3.1
In deciding whether it is appropriate to accept any gift or hospitality you must apply the following principles: – – – – –
– –
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Do not accept a gift or hospitality as an inducement or reward for anything you do at Keltbray. If you have any suspicion that the motive behind the gift or hospitality is an inducement or reward you must decline it Do not accept a gift or hospitality of significant value or the value of which is excessive in the circumstances Do not accept a gift or hospitality if you believe it will put you under any obligation to the provider as a consequence Do not solicit any gift or hospitality and avoid giving any perception of so doing Wherever possible, you must be clear as to the value of the gift/hospitality at the time that you agree to accept it; where the actual value of a gift or hospitality is not known or is not reasonably obtainable, you should decide how much a person could reasonably be expected to pay for it at a commercial rate. Where an item is difficult to value, even as an estimate, the Monitoring Officer is able to accept a form showing ‘value unknown’ in appropriate circumstances For staff, offers of hospitality should be accepted only with prior approval of a Line Manager or Director wherever possible You should declare receipt of any gift or hospitality what an ordinary member of the public might reasonably deem to be significant (for example, the identity of the provider or the wider context in which the item was provided), regardless of formal cash value Do not accept a gift or hospitality from: – Parties involved with Keltbray in a competitive tendering or other procurement process – From other parties in legal proceedings with Keltbray
You should use your judgement as to how accepting an offer might be perceived. If accepting a gift in kind from any third party – e.g. the provision of a free meeting venue, you should only declare if this would not have been obtained in the normal course of business, e.g. it has been obtained through a personal contact. 4.
Items that no not need to he declared
4.1
As a general rule, you will not need to declare:
KEL-CRP-POL-025 - Gifts and Hospitality policy statement and procedure
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