Gifts & Hospitality

We support the practice of offering modest non-cash gifts to business partners where appropriate for marketing purposes or, as long as the gift is occasional and not regular or repeated, other purposes such as expressing thanks or making a goodwill gesture.  For example, we may offer promotional material for marketing purposes or send a small token gift to a business partner as a Christmas gift.

If you want to offer gifts worth more than £100 you must obtain prior approval from your Manager who will decide if the proposed gift is legitimate, proportionate and reasonable in line with monetary limits and authorisation levels.

You should never offer:

• cash gifts;
• gifts in secret;
• any sort of gift where the intention is to influence the recipient’s judgment;
• any sort of gift where you know that the recipient is not allowed to receive it

 

 

You are allowed to accept token gifts from business partners or potential business partners where this constitutes legitimate and reasonable marketing or where it is a legitimate goodwill gesture.  For example, you can accept promotional items such as desk calendars or pens or occasional gestures such as a bunch of flowers from a customer to express thanks or offer congratulations.

You should never accept:

• cash gifts; or
• gifts which are extravagant or out of proportion, for example above a value of £100 or
• repeated/regular gifts from the same donor; or
• any gift which you are asked to keep secret; or
• any sort of gift where your judgment might reasonably be thought to be at risk of influence as a result of the gift (for example, a gift from a potential business partner shortly before you make a decision over whether or not to award them a contract); or
• any sort of gift which might reasonably bring the business into disrepute or be contrary to terms or the spirit of our equal opportunities/dignity at work policy, for example a pin-up calendar.

Be aware that a ‘gift’ includes food, drink and other corporate hospitality if the host is not present.  For example, if you are invited to attend a test match at Lords by one of our suppliers but the supplier will not be present then the tickets are a gift.

Those responsible for purchase/procurement of supplies/components /tender process for large contracts are prohibited from receiving gifts from potential business partners during any kind of active bidding/procurement/negotiation process.

If you are offered a gift in circumstances which make you concerned or uncomfortable then you should raise this with your manager.

It is our policy and your responsibility to act ethically at all times.

If any unauthorised gift is offered to you then you should decline it politely explaining that our policy does not permit you to accept it, unless to do so would be embarrassing or insulting (for example because the gift is offered in public) in which case you should accept the gift and then refer the situation to your manager.  The company is likely to write to the donor of the gift explaining our policy and returning the item.

 

 

If you are travelling overseas on business to an area where gifts are an important part of business culture then you will be allowed and expected to participate in gift giving and receiving but this still needs to be proportionate and reasonable from a UK perspective. You should seek guidance from the Finance Director

Our policy is to participate in corporate hospitality and entertainment where this will promote good relationships with our business partners.

For example, taking business partners out for dinner would be supported by the business as long as it is reasonable and proportionate.  In addition, working lunches with business partners are appropriate, as long as they are reasonable/modest/in line with our expenses policy.

However, corporate hospitality and entertainment, including attendance at dinners or sporting events, should not be offered or accepted without prior approval in advance if the estimated value exceeds £100; or

• it is lavish or extravagant; or
• it is on a scale which is disproportionate to the legitimate business value of the relationship; or
• you are offering it with the intention of influencing the recipient’s judgment or when you know they are not permitted to accept it; or
• you are offered it in circumstances when acceptance would influence your business judgment or put you in a difficult position, for example being offered Wimbledon tickets by a supplier shortly before their contract came up for renewal; or
• if it would infringe our expenses policy; or
• if it might reasonably bring the business into disrepute or contravene the terms or the spirit of our equal opportunities/dignity at work policy, for example a post-meal visits to a ‘gentleman’s club’.

You should not offer daily cash allowances to individuals as part of any corporate hospitality or entertainment provided by us if this means that we will have no control over the spending of the allowance. If you are offered any such daily cash allowance by a third party, then please speak to the Finance Director who will offer guidance on what you should do. You may, for example, be required to submit receipts for genuine expenses and to re-imburse the provider for any unused portion of the allowance.

If you are unsure as to whether a particular invitation, event or offer is appropriate, you should seek guidance from the Finance Director.

Those responsible for purchase/procurement of supplies/components /tender process for large contracts are prohibited from accepting any kind of invitation whatsoever during any kind of active bidding/procurement/negotiation process.

 

Refer to the expenses policy for clarification on spending limits where not already indicated, this is held in the Finance Department.

Permission to accept any gift or hospitality must be approved in advance in line the Gift and Hospitality Limits by completing a Gift and Hospitality Approval Form.