Gift and Hospitality Policy - Template, Sample Form Pro · UK-law
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GIFTS AND HOSPITALITY POLICY
________
Anti-Bribery and Anti-Corruption Compliance Policy
§ 1. DEFINITIONS
The following definitions apply throughout this policy to assist your understanding of its requirements.
1.1. The policyholder
The policyholder is ________, a company incorporated in England and Wales (company registration number ________) whose registered office is at ________. In this policy the words 'we', 'our' and 'us' refer to the policyholder. We have created this policy for our workforce.
1.2. The workforce
Our workforce comprises:
________
In this policy, the words 'you', 'your' and 'yours' refer to the workforce. This policy applies to all employees, directors, officers, workers, agency staff, consultants, contractors, agents and any other person who performs services for or on our behalf, irrespective of seniority or contractual status.
1.3. Interested third party
An interested third party includes any person, organisation or body who has or may influence our business, trading and financial operations. This includes, but is not limited to:
________
1.4. Gifts
A gift is something provided as a present to another person. Examples of gifts include, but are not limited to:
- cash;
- vouchers;
- tickets;
- flowers;
- alcohol;
- hampers.
1.5. Hospitality
Hospitality refers to a situation where food, accommodation and/or refreshments are provided to another person. Examples of hospitality include, but are not limited to:
- festive or seasonal events;
- sporting events;
- accommodation;
- dinners and lunches.
1.6. The Register
A register of all gifts and hospitality (the Register) is maintained in accordance with this policy. The Register may be accessed: ________.
1.7. The Bribery Act
The Bribery Act means the Bribery Act 2010, together with any subordinate legislation and statutory guidance issued under it (including guidance published by the Ministry of Justice pursuant to section 9 of that Act).
§ 2. INTRODUCTION
This policy sets out our approach to gifts and hospitality in the workplace. It applies to the whole of our workforce throughout the duration of your work with us.
This policy should be read in conjunction with our Anti-Bribery and Corruption Policy and our Whistleblowing Policy. This policy does not form part of any employee's contract of employment and we may amend it at any time. We will review this policy periodically to ensure it remains current and effective.
§ 3. PURPOSE OF THIS POLICY
3.1. Accepting or providing gifts or hospitality in the course of your work could give rise to a conflict of interest and may adversely affect the integrity or impartiality of our operations.
3.2. The whole workforce must ensure that our business remains free from bribery and corruption. Bribery is a criminal offence under the Bribery Act 2010. It is an offence to offer, promise, give, request, agree to receive or accept a financial or other advantage as an inducement or reward for the improper performance of a function or activity (sections 1 and 2 of the Bribery Act 2010), and a separate offence to bribe a foreign public official (section 6).
3.3. A commercial organisation may itself commit an offence under section 7 of the Bribery Act 2010 if a person associated with it bribes another person intending to obtain or retain business or an advantage for the organisation. It is a defence for the organisation to demonstrate that it had in place adequate procedures designed to prevent such conduct. This policy forms part of those procedures.
3.4. A breach of the Bribery Act 2010 may result in criminal liability for the individual concerned (including imprisonment and/or unlimited fines) and for us as an organisation. For these reasons, the requirements of this policy must be adhered to by you at all times.
§ 4. RECEIVING GIFTS AND HOSPITALITY
We set out below a general framework to assist you in determining the process to follow if you are offered or receive a gift or hospitality. To assist your assessment, it is helpful to consider:
- the intention behind any offer of gifts or hospitality;
- the timing of the offer;
- how it may affect your decision-making and impartiality;
- whether it is reasonable and proportionate in all the circumstances.
The examples provided in this policy are not exhaustive. If you are in any doubt you should always consult with ________.
The details of all gifts and hospitality, whether accepted or declined, must always be recorded on the Register.
4.1. Gifts and hospitality that are acceptable
The following types of gifts and hospitality from interested third parties will typically be considered acceptable:
4.1.1. Gifts with a value of less than £________, subject to the other provisions of this policy.
4.1.2. Hospitality with a value of less than £________, subject to the other provisions of this policy.
4.1.3. Gifts provided at an appropriate time and for an appropriate reason (e.g. cultural or as a thank you).
4.1.4. Hospitality provided at an appropriate time and for an appropriate reason, where this is customary and is not lavish or extravagant (e.g. light refreshments during the course of a meeting).
4.1.5. A gift or hospitality provided as part of an award ceremony, industry event or seasonal event hosted by a formal organisation, institution or body.
4.1.6. A gift or hospitality which is infrequent (offered less than annually).
You must ensure that any gift or hospitality from interested third parties accepted under this section is recorded on the Register.
4.2. Gifts and hospitality that may be accepted but must be explicitly approved
The following types of gifts and hospitality from interested third parties may be acceptable but require prior authorisation:
4.2.1. Gifts with a value of £________ and above, subject to the other provisions of this policy.
4.2.2. Hospitality with a value of £________ and above, subject to the other provisions of this policy.
4.2.3. Where a gift or hospitality has been offered by the same interested third party more than twice in any one-year period, this must be explicitly approved.
Where you judge that a gift or hospitality falls within this section, you must seek authorisation (see 'Obtaining Approval' below).
You must ensure that any gift or hospitality from interested third parties under this section is recorded on the Register, whether approved or declined.
4.3. Gifts and hospitality that are never acceptable
The following types of gifts and hospitality from interested third parties will be considered unacceptable and must not be accepted under any circumstances:
4.3.1. Any gift of cash or cash equivalent (such as vouchers).
4.3.2. Any gift or hospitality which would affect your impartiality and influence your judgement during your work (e.g. a gift offered in anticipation of a certain transaction or business arrangement).
4.3.3. A gift or hospitality which has been solicited or encouraged by you.
4.3.4. A gift or hospitality which is extravagant or regularly recurring.
4.3.5. A gift with a value of more than £________. You should take into account the nature of any recent gifts offered or received when assessing this figure.
4.3.6. Hospitality with a value of more than £________. You should take into account the nature of any recent hospitality offered or received when assessing this figure.
4.3.7. A gift or hospitality which is provided in secret or concealed in any way.
4.3.8. A gift or hospitality provided to you in your own name rather than our name.
4.3.9. Any gift or hospitality which would constitute, or could reasonably be perceived to constitute, an offence under the Bribery Act 2010 or any other applicable law.
4.3.10. A gift or hospitality which is sexual in nature.
You must ensure that any offers from interested third parties declined in accordance with this section are still recorded on the Register.
§ 5. OBTAINING APPROVAL
5.1. If you are offered a gift or hospitality which requires prior authorisation:
5.1.1. You must inform ________ as soon as reasonably practicable after the offer; and
5.1.2. ________ will indicate whether the gift or hospitality may be accepted or should be declined.
5.2. Where you receive a gift without prior warning:
5.2.1. You must inform ________ as soon as reasonably practicable after receiving the gift; and
5.2.2. ________ will indicate whether the gift is deemed acceptable or whether any further action is required (which may include returning the gift or donating it to charity).
§ 6. PROVIDING GIFTS AND HOSPITALITY
6.1. There may be occasions where it is appropriate for us to provide gifts or hospitality to interested third parties in the course of our business. Any gift or hospitality provided must be reasonable, proportionate and given in good faith for a legitimate business purpose.
6.2. You must never provide a gift or hospitality with the intention of improperly influencing the recipient, or which could be perceived as a bribe or inducement to secure a business advantage. Gifts of cash or cash equivalents (such as vouchers) must never be offered, and gifts or hospitality which are lavish, extravagant or inappropriate must not be provided.
6.3. Particular care must be taken where the recipient is a foreign public official, given the offence created by section 6 of the Bribery Act 2010. Facilitation payments (unofficial payments made to secure or expedite a routine action by a government official) are strictly prohibited and must never be made.
6.4. The details of all gifts and hospitality provided by us, whether accepted or declined, must always be recorded on the Register. If you are in any doubt as to whether a gift or hospitality may be provided, you must seek prior authorisation in accordance with § 5 (Obtaining Approval) above.
§ 7. DATA PROTECTION
§ 8. IMPLEMENTATION AND COMPLIANCE
8.1. Before implementing this policy, we have consulted with the following trade union/representative body: ________.
8.2. You must comply with this policy and all procedures contained within it as a condition of your work with us.
8.3. A failure to comply with the requirements of this policy will be referred for action under our disciplinary procedure and may, in serious cases, amount to gross misconduct justifying summary dismissal. Where the conduct may involve a criminal offence, the matter may be reported to the relevant authorities.
8.4. You must report any wrongdoing which may amount to a breach of this policy. You should report your concerns to ________. If you do not consider it appropriate to speak to this person, you should raise the matter with another senior member of staff in accordance with our Whistleblowing Policy. Workers who raise genuine concerns are protected from detriment and dismissal under the Employment Rights Act 1996 (as amended by the Public Interest Disclosure Act 1998).
8.5. We will investigate all concerns raised in accordance with this policy without undue delay.
§ 9. GOVERNING LAW
This policy and any matters arising from it shall be governed by and construed in accordance with the law of England and Wales.
This policy was approved and authorised by:
Name: ________
Position: ________
Signature: ________
DATED:
________
THE REGISTER
Template register
Gifts Received
| Date of receipt | Description of gift | Value | Donor | Recipient staff member(s) | Accepted/ declined? |
Authorised by (name and signature, where applicable) |
Gifts Provided
| Date of donation | Description of gift | Value | Recipient | Authorised by (name and signature) |
Hospitality Received
| Date of receipt | Description/occasion | Value | Invitation from: | Recipient staff member(s) | Accepted/ declined? |
Authorised by (name and signature, where applicable) |
Hospitality Provided
| Date | Description/occasion | Value | Recipient |
Authorised by (name and signature) |
Fields you complete are inserted into the document live. This template is general guidance only — not legal advice.