Gift and Hospitality Policy - Template, Sample Form
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GIFT AND HOSPITALITY POLICY
________
1. DEFINITIONS
Please refer to the below definitions to assist your understanding of this policy.
1.1. The policyholder
The policyholder is ________. In this policy the words 'we', 'our' and 'us' shall refer to the policyholder. We have created this policy for our workforce.
1.2. The workforce
Our workforce comprises of:
________
In this policy, the words 'you', 'your' and 'yours' shall refer to the workforce.
1.3. Interested third party
An interested third party will include any person, organisation or body who has or may influence our business, trading and financial operations. This will include, but is not limited to:
________
1.4. Gifts
A gift is something which is 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 the 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 can be accessed: ________.
2. INTRODUCTION
This policy sets out our gift and hospitality policy in the workplace. This policy applies to the whole of our workforce during the course of your work with us.
3. PURPOSE OF THIS POLICY
Accepting gifts or hospitality from interested third parties during the course of your work could give rise to a conflict of interest and may adversely impact the integrity or impartiality of our operations.
The whole workforce must ensure that our work remains free from bribery and corruption.
For these reasons, the requirements of this policy must be adhered to by you at all times.
4. RECEIVING GIFTS AND HOSPITALITY
We provide a general framework below to assist you in determining the process which you should follow if you are offered or receive a gift or hospitality. To help you make an assessment it is also helpful to consider:
- the intention behind any offer of hospitality or gifts
- the timing of the offer
- how this may impact your decision-making and impartiality
Please note that the examples provided in this policy are not exhaustive. If you are unsure you should always consult with ________.
The details of all gifts and hospitality, whether accepted or declined, should 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 to be acceptable:
4.1.1. Gifts which are of a value of less than £________, subject to the other provisions of this policy.
4.1.2. Hospitality which is of a value of less than £________, subject to the other provisions of this policy.
4.1.3. Gifts that are provided at an appropriate time and for an appropriate reason (e.g. cultural or as a thank you).
4.1.4. Hospitality that is 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 that is provided as part of an award ceremony, industry event or seasonal event which is hosted by a formal organisation, institution or body.
4.1.6. A gift or hospitality that is infrequent (offered less than annually).
You must ensure that any gift or hospitality from interested third parties which is 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 considered to be acceptable but will 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 provision of this policy.
4.2.3. Where a gift or hospitality has been offered from the same interested third party more than twice any a one-year period, this should be explicitly approved.
Where you judge that a gift or hospitality falls within this section, you should seek authorisation (see 'Obtaining Approval' below).
You must ensure that any gift or hospitality from interested third parties that is accepted 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 to be unacceptable and should 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 impact 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 which is provided to you in your name rather than our name.
4.3.9. An illegal gift or hospitality that would constitute an illegal activity.
4.3.10. A gift or hospitality which is sexual in nature.
You must ensure that any offers from interested third parties that are declined in accordance with this section are still recorded on the Register.
5. OBTAINING APPROVAL
5.1. If you have been offered a gift or hospitality which requires prior authorisation:
5.1.1. You should inform ________ as soon as reasonably practicable after the offer;
5.1.2. ________ will indicate whether the Gift may be accepted or should be declined.
5.2. In circumstances where you receive a gift without prior warning:
5.2.1. You should inform ________ as soon as reasonably practicable after you receive the gift;
5.2.2. ________ will indicate whether the gift is deemed to be acceptable or whether any further action may be required.
6. PROVIDING GIFTS AND HOSPITALITY
There may be occasions where it is appropriate for us to provide gifts or hospitality to interested third parties during the course of our business. Any gift or hospitality which is provided must be reasonable, proportionate and given in good faith for a legitimate business purpose.
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 should seek prior authorisation in accordance with the 'Obtaining Approval' section above.
7. IMPLEMENTATION AND COMPLIANCE
Before implementing this code of conduct, the we have consulted with the following trade union: ________.
You must ensure that you comply with this policy and all procedures contained within it as a condition of your work with us.
A failure to comply with the requirements of this policy will be referred for disciplinary action under our usual disciplinary procedures.
You must report any wrongdoing which may amount to a breach of the requirements of this policy. You should report your concerns to ________. If you feel that it is not appropriate to speak to this person, then you should raise the issue with another senior member of staff.
We will investigate all concerns raised in accordance with this policy without delay.
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 | Inivation 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.