Policy for the Acceptance of Corporate Hospitality
The guiding principle in this policy is that a member of staff should not be influenced in any decision-making, or in providing advice on decision-making, by the acceptance of any gifts, hospitality or favours from any organisation. These procedures should be read in conjunction with the University’s Anti-bribery Policy.
Staff should adhere to the following:
- No personal gift, money, hospitality or favours, or participation in any social or leisure functions should be accepted by any member of staff (with the exception of points 2. and 3. below) from any organisation or individual from whom the University purchases services or items, or to whom contracts are let, or in respect of whom a beneficial decision is possible. The same would apply for any organisation or individual where the University has an intention to purchase from, let a contract to or make a beneficial decision about in the future. In general, gifts, hospitality etc. should therefore be politely refused, with an explanation that this is University policy.
- A gift which has a low intrinsic value (e.g. calendar, diary etc.) may be accepted so long as the existence of the gift is notified to the Head of College/School or Central Service Department.
- An exchange of modest gifts or reciprocal hospitality, (e.g. with a visitor from another university or organisation) which is a gesture of goodwill and where embarrassment might be caused to the University if the gift/ hospitality is refused, may be accepted and recorded in the Register of Gifts & Hospitality. However, staff members should always attempt to discuss the appropriateness of such an exchange with the relevant Head of College/School / Central Service Department prior to acceptance.
- Participation in events or exhibitions etc. which have a commercial orientation and are run by organisations or individuals from whom the University purchases services or items, or to whom contracts are let, or in respect of whom a beneficial decision is possible must be authorised by the Head of School or Central Service Department. The same would apply for any organisation or individual where the University has an intention to purchase from, let a contract to or make a beneficial decision about in the future. Such participation should be declared and noted in the College/School/Department’s Register of Gifts and Hospitality.
- The definition of corporate hospitality is not intended to cover working lunches which are effectively meetings or extensions of meetings or the offer of non-alcoholic drinks or light refreshments; similarly, invitations to dinners organised by professional bodies may be accepted, although staff members should use their discretion as to when it would be appropriate for such invitations to be accepted, having due regard to the requirements of these procedures, the proportionality of the hospitality and the University’s Anti-bribery Policy.
If anyone is in any doubt over any particular instance, he/she should consult their Head of College/ School / Central Service Department. The Head of College / School / Central Service Department, in turn, may bring the matter to the Head of Compliance for advice or a final decision.
Any non-compliance with this policy may result in disciplinary action.
The College / School / Department’s Register of Gifts & Hospitality shall be available for inspection by the Internal Auditor, Audit Committee or others as deemed necessary.