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Corporate Hospitality, Gifts, Guest Speaker Fees & Sponsorship policy
- Corporate Hospitality, Gifts, Guest Speaker Fees & Sponsorship policy
- Additional Employee and Consultants guidance relating to gifts, paid events, corporate hospitality and sponsorship - Appendix 1
- Templates for recording corporate hospitality and gifts and speaker fees - Appendix 2
1. Basic Principles
- The policy relating to the acceptance of corporate hospitality and this guidance are mandatory for all EP employees; including those on fixed-term contracts.
- All consultants, contractors and individuals employed by an agency or on secondment to English Partnerships who are invited through their direct work with English Partnerships, must also comply with this policy and guidance (collectively referred to in this guidance as ‘Consultants’).
- The acceptance of gifts from third parties involved with EP is not permitted (except token promotional items of very low value). Further information is provided within Section 2 of this guidance. Any attempt to undermine the impartiality of Employees or Consultants by the offer of substantial gifts or other inducements should be reported to the Head of Corporate Assurance or the Chief Operating Officer immediately.
- The acceptance of any form of corporate hospitality requires prior approval from an appropriate EMB member or Head of Department. For the avoidance of doubt, the final decision on whether corporate hospitality may or may not be accepted will always be at the discretion of an appropriate EMB Director, who will act as the ultimate arbiter.
- When accepting corporate hospitality Employees and Consultants should have due regard to EP’s policies and procedures (e.g. the equal opportunities policy; and the equality and diversity strategy and action plan). Employees and Consultants should only accept corporate hospitality that is ethically, morally, socially and politically ‘correct’. Nothing should be accepted that brings EP into disrepute.
- Corporate hospitality covers a wide area of interpretation. If Employees and Consultants are unsure whether an area falls within the interpretation of corporate hospitality or not, it usually does. Specific areas that are excluded from this interpretation are listed in Section 3 of this guidance.
- The general rule is that Employees and Consultants should decline all high value corporate hospitality, unless there are compelling business reasons to accept such hospitality. Approval prior to acceptance of corporate hospitality must be obtained from an Executive Director. In the circumstances outlined in section 4.2, the Chief Operating Officer must also approve corporate hospitality where the value of the hospitality exceeds £75.
- Employees and Consultants should note that there are strict rules regarding offers of business travel and / or accommodation paid for by third parties; speaking fees; and attendance at events sponsored by political parties. See Section 4 for further information.
- Employees and Consultants are not permitted to receive any form of corporate hospitality from a tenderer participating in a ‘high value’ EP procurement exercise (‘high value’ is defined as falling within the trigger threshold of the EU procurement regulations). See Section 5 for further information.
- For all other tenders and quotations, Panel Managers, recipients of the service being tendered, or those involved in any lower value tender process are not permitted to accept hospitality from an individual or organisation involved in an active tender. See Section 5 for further information.
- All Employees and Consultants are required to complete a record in a Register of hospitality received and any gifts declined, or speaker fees received. Record keeping and Register details are provided in Section 6.
- Failure to comply with any aspect of this policy will result in disciplinary action being taken where appropriate.
2. Receiving Gifts
2.1 Employees and Consultants are only permitted to accept and keep the following gifts paid for by third parties involved with EP:
- Token gifts of very low value such as pens, diaries and small promotional items (please note the guidance below regarding active tenders).
2.2 Accepting and keeping all other gifts is not generally permitted. Non-acceptance always applies when gifts are received from a bidder during an EP tender exercise. Outside the period of an EP procurement exercise there may be rare circumstances where declining the gift is likely to cause major offence (e.g. gifts from foreign dignitaries or religious leaders). In these circumstances the gift may be accepted and then donated to charity (with a record noted in the Register).
2.3 EP acknowledges that Employees and Consultants may receive unsolicited token gifts from bidders’ marketing departments from time to time, such as calenders and memo pads at Christmas. Employees and Consultants should consider the impact of displaying or using these items during an active tender process when other bidders may see them during an office visit.
2.4 It should be noted that all gifts offered and declined (or returned) in addition to those accepted and then donated must be recorded in the Register (see Section 6). This requirement is to protect Employees and Consultants by providing a record of which organisations or individuals are offering gifts to EP and where the gift has gone. All gifts offered or accepted by staff (even when declined) with an estimated value of more than £50 should be reported to the Chief Operating Officer, or in the case of an EMB Member, the Chief Executive.
2.5 For further guidance on perishable gifts, please see Appendix 1.
3. Policy interpretation of corporate hospitality
3.1 EP seeks to protect Employees and Consultants from allegations of impropriety by ensuring that the acceptance of hospitality is transparent and that there is appropriate approval and recording of details. Employees and Consultants should read the examples and further guidance on this subject located within Appendix 1. Specific advice on any grey area may be obtained from either the Head of Human Resources or the Head of Compliance.
3.2 Specific areas that are generally excluded from the EP interpretation of corporate hospitality are listed as follows:
- business and travel expenses properly incurred by Employees whilst attending events or occasions sponsored or supported by EP (see Annex 14 'Travelling, Subsistence and Other Business Expenses Procedures’ within the EP Terms and Conditions of Employment in relation to reimbursement of employees costs).
- normal business lunches and meals, although under certain circumstances special rules apply (further clarification is detailed in this Section).
- hospitality provided to Employees and Consultants who are permitted by EP to attend externally organised courses, conferences, seminars and workshops which are paid for by the Agency, providing that in all cases such hospitality is open to: all delegates or attendees as part of the attendance fee; or in the case of very large events is open to a fair representation of attendees. See Appendix 1 for examples.
- specific EP rules now apply to free educational seminars and industry awareness sessions (further clarification is detailed in this Section).
- gifts or incentives provided by recognised business 'frequent traveller' loyalty schemes and awarded during travel paid for by EP (such guidance will be provided in a future 'Travelling, Subsistence and Other Business Expenses Procedures' update).
- vouchers or financial compensation awarded due to delays during travel paid for by EP (such guidance will be provided in a future 'Travelling, Subsistence and Other Business Expenses Procedures’ update).
3.3 As a general rule EP interprets corporate hospitality as covering all other invitations and activities falling outside the exceptions above.
3.4 Working lunches at a third party's office
3.4.1 The occasional office-based working lunch provided by a third party to an EP Employee or Consultant during a business visit requires no previous approval and need not be recorded in the Register.
3.5 Out of office business meals
3.5.1 EP does not require Employees and Consultants to record in the Register details of reasonable and justifiable business meals provided by third parties; however, special rules apply during procurement and tender exercises (see Section 5).
3.5.2 Although prior approval to attend a business meal is not required under the Terms and Conditions of Service, Employees and Consultants should wherever possible make their Head of Department or EMB Director aware of the business meal before it takes place. This is to protect Employees and Consultants from challenges by others who may not be aware that the meal is deemed to be ‘reasonable’ and ‘justified’. If an Employee or Consultant is in any way uncomfortable with the ‘lavishness’ of the business meal (or the motives of the third party) the subject should be raised with their Head of Department or EMB Director and the details of the meal should be recorded in the Register as a precaution.
3.5.3 Where the nature of the meal invitation also includes additional hospitality (such as a post-meal visit to a club or entertainment venue), all the received hospitality (including the meal) must be approved in advance by an appropriate Head of Department or EMB Director and recorded in the Register.
3.6 Free educational seminars and industry awareness sessions
3.6.1 Continuous Professional Development (CPD) events will always fall within the corporate hospitality policy if they relate directly to an industry sector that is participating in a high value (or OJEU) EP tender or procurement exercise or where other Section 5 rules apply to Employees or Consultants. In these circumstances the invitation should be declined (even when the event takes place outside working hours). Further guidance and examples are contained within Appendix 1.
3.6.2 At all other times CPD events paid for or offered free of charge by third parties will usually fall outside the normal corporate hospitality acceptance policy unless the circumstances listed in Appendix 1 apply.
3.6.3 Permission should be obtained in advance by an appropriate Head of Department or a Director to attend any CPD event during the working day that is paid for by a third party. No permission is required to attend CPD events outside working hours.
4. Accepting corporate hospitality
4.1 The Terms and Conditions of Service will apply to all other forms of corporate hospitality as detailed in this Guidance. Employees and Consultants are required to notify and obtain approval from their Head of Department or Executive Director before they accept and attend corporate hospitality paid for or provided by third parties and details should be recorded in the Register in the usual way.
4.2 Visits to shows, sporting events and similar entertainment requires approval prior to acceptance of the invitation. Due to the high participant cost at this type of event, when a third party offers to pay for an EP Employee or Consultant to attend, an approval must be obtained in advance from an appropriate Executive Director, together with approval from the Chief Operating Officer when the estimated value exceeds £75 per person. Details must always be recorded in the Register. Further examples and guidance are contained within Appendix 1.
4.3 Fact-finding or business review visits involving contractors or suppliers
4.3.1 Employees and Consultants are not permitted to receive from external third parties any paid travel, accommodation or general subsistence (except for minimal-cost travel arrangements such as taxi sharing and the like) when conducting fact-finding investigations, business review visits or any such similar meeting. However, in rare circumstances it may be impractical for English Partnerships to independently arrange travel or accommodation (for example where the supplier provides on-site accommodation in a remote location). In all cases, prior approval will be required from the Chief Operating Officer or the Chief Executive and details must be recorded in the Register.
4.4 Hospitality provided by political parties
4.4.1 Employees and Consultants are not permitted to accept any work-related hospitality that is directly or indirectly paid for by any political party without prior approval of the Chief Executive (and where appropriate EP’s Sponsor Department DCLG).
5. Specific rules during procurement and tender exercises
5.1 Employees, Consultants and their respective families are not permitted to receive any form of corporate hospitality from a tenderer participating in a high value EP procurement or tender exercise. ‘High value’ in this instance is the OJEU threshold for supplies, services and works as detailed in the EP Competition, Tendering and Financial Vetting Rules Part 5 (available within the EP Project Guidance).
5.2 For all other tenders (including ‘mini-tenders’ within existing Panels of consultants and suppliers below the OJEU threshold) Panel Managers, recipients of the service being tendered, or those involved in the tender process are not permitted to accept hospitality from an individual or organisation involved in an active tender.
5.3 Details of active tenders are available from the EP Procurement Officer. Please note that high value tenders take many months to complete. This typically causes potential conflicts during the Christmas festive season, when a significant amount of property industry hospitality is bestowed.
6. The register of corporate hospitality received & gifts
6.1 All Executive Directors are responsible for holding records of corporate hospitality and gifts received by Employees and Consultants working within their Directorate. Each Executive Director holds a Register of Corporate Hospitality Received & Gifts and this record should be completed on a timely basis. If Employees and Consultants are unclear where the Register is held or the recording process, please contact the appropriate Director’s personal assistant. A sample Register is provided at Appendix 2 of this guidance.
6.2 Subject to the exceptions listed in this guidance, prior to acceptance of any corporate hospitality an appropriate approval is required. EP also requires Employees and Consultants to record in the Register the details of any corporate hospitality received and gifts offered and declined (or accepted and donated to charity) as soon as possible and ideally within five working days of receipt. The individual(s) who approved in advance the acceptance of the hospitality should endorse the Register record by signing in the appropriate place. Please note that the holder of the Register is required to report all corporate hospitality outlined in section 4.2 were there is an estimated value of more than £75 to the Chief Operating Officer (or in the case of that EMB Director, the Chief Executive).
6.3 Employees and Consultants should also note that they will be required to periodically self-certify that their personal Register records are up to date. Failing to self certify when requested, or failing to record corporate hospitality received or gifts declined (or accepted and donated to charity) may be subject to disciplinary action.
7. Fees for speaking engagements
7.1 Offers of fees for speaking engagements are usually discouraged. Fees may only be accepted on the basis that they are payable to EP to cover associated costs and expenses. EP prefers to arrange and pay for its own travel, accommodation and subsistence arrangements wherever possible.
7.2 All Directorates should maintain a Register of Speaking Fees Received (a copy of which is provided in Appendix 2 of this guidance) alongside the Register of Corporate Hospitality Received & Gifts.
7.3 Where the payment for a speaking engagement is a gift of any description, the usual rules on accepting gifts apply. However, the details of such a gift in lieu of payment need only be recorded in the Register of Corporate Hospitality Received and Gifts.
8. Receiving sponsorship
8.1 Employees, Consultants and their families are not permitted to receive 'personal' direct sponsorship from third parties providing (or tendering for) services, works or supplies to EP. EP does not usually sponsor its Employees or Consultants for fund raising events. Further guidance and examples are contained within Appendix 1.
8.2 EP does not endorse services or products from private sector organisations or charities unless such endorsement is by way of association (such as where the Agency is a shareholder in a joint venture partnership or other similar delivery vehicle). Sole sponsorship by the private sector of any EP event is usually inappropriate and rarely permitted.
8.3 Offers of sponsorship from more than one private sector organisation; or a request to buy exhibition space during EP organised exhibitions or conferences; or a request for sole sponsorship by a public body must always be submitted for approval to the Corporate Marketing Manager, who will determine the appropriateness of the sponsor / exhibitor for the event, whilst bearing in mind the aims and objectives of EP.
Appendix 2 - Templates for recording corporate hospitality and gifts and speaker fees.
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