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Policy Statement
The following outlines the ODA’s overall approach to gifts and hospitality. All
employees should read it carefully, and any questions should be directed to your HR
Manager.
It is imperative that the acceptance of gifts and hospitality by ODA employees can
stand up to public scrutiny. As a rule of thumb, gifts should be declined wherever
possible, and any offers should be reported to your line manager. Where it would be
ungracious or otherwise difficult not to accept, you should inform your line manager
of the gift, the estimated value and the donor. You must take personal responsibility
to ensure that a record is placed in the hospitality register of the ODA which is kept
by the Head of Legal. Similarly, care should be taken that no extravagance is
involved with working lunches and other social occasions.
ODA staff should not receive benefits of any kind from a third party which might
reasonably be seen to compromise their personal judgement and integrity. ODA’s
employees are only permitted to accept and keep token gifts of very low value such
as pens, diaries and small promotional items (but not even these from third parties
involved in active tenders).
In the rare circumstances where declining the gift is likely to cause major offence
(e.g. gifts from foreign dignitaries or religious leaders), the gift may be accepted and
then donated to Charity.
The ODA trusts its employees to use their judgement when accepting business meal
hospitality from third parties (i.e. that the appropriateness of the meal or the
frequency of such hospitality is ‘reasonable’ and can be ‘justified’). If an employee is
in any way uncomfortable with the ‘lavishness’ of the meal hospitality (or the motives
of the third party) the subject should be raised with your line manager. All hospitality
should be recorded in the Register within five working days of receipt of the offer
unless it falls into an excluded category as set out in the Guidelines below.
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 recorded in the Register and approval sought from your
line manager.
All gifts offered and declined (or returned) in addition to those accepted and then
donated (or where perishable, shared with staff) must be recorded in a register. This
record is to protect employees by providing a record of which organisations or
individuals are offering gifts to the ODA and where the gift has gone. Please ensure
you record in the Register [by informing the Head of Legal] all details of 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.
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The detailed guidance and rules that follow and accompanying annexes are ODA
policy. The guidelines and rules are therefore mandatory for all employees (including
secondees, fixed term contract staff and temporary staff) and cover:
Employees are required to familiarise themselves with this Note and the
accompanying annexes.
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Please note that working lunches with colleagues from LOCOG, GLA, LDA, TfL and
English Partnerships are not regarded as hospitality for the purposes of this policy.
The general rule is that Standard and Premium Corporate Hospitality may only be
accepted by an employee if authorised by an ODA Director in advance. Please note
that special rules apply during tendering.
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There should be clear rules specifying the circumstances in which staff should seek
management advice about the advisability of accepting invitations and offers of
hospitality.
The ODA has adopted these recommendations and the main principles outlined in
HM Treasury’s Guidance Note 55: Ethics in Procurement. To ensure consistency
across the organisation, the accompanying Annex 1 (Guidelines for the Receipt of
Corporate Hospitality, Gifts, Guest Speaker Fees & Sponsorship) provides
mandatory guidance on accepting corporate hospitality, gifts and speaker fees;
permitted exemptions; and recording procedures (see Annexes 3 and 4) to ensure
compliance with Nolan Committee requirements.
Key Principles
The general test of caution is one of common sense:
Corporate hospitality, the sponsorship of events and exhibitions and the distribution
of promotional items are permissible as a tool to raise awareness of the ODA’s
activities, subject to the provisions of this policy and its accompanying annexes.
Employees and their immediate family are not permitted to receive any form of
hospitality or gifts (including working lunches) from any third party participating in an
active tender for ODA business. If employees discover they (or their immediate
family) have inadvertently breached this rule, they must notify their Director and the
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Director or the Director of Finance and Corporate Services immediately, who in turn
must seek advice from the Head of Legal.
The Register of Corporate Hospitality Received and Gifts (Annex 3 to this policy);
and the Register of Speaking Fees Received (Annex 4 to this policy); is held by the
Head of Legal. The Register of Gifts (Provided) (Annex 5 to this Note) is held by the
Head of Legal.
All meals, hospitality and gifts, either given or received, will be open to public
scrutiny. If you have any doubts as to the appropriateness of accepting specific
hospitality or gifts, you must seek advice from the Head of Governance or the
Director of Finance and Corporate Services.
All employees with responsibility for sponsorship are required to adhere to the
guidance in this policy and the accompanying Annexes 1 & 2 and to retain a proper
record of their activities for justification purposes. Failure to do so may result in
disciplinary action. Provision of sponsorship must be demonstrably linked to the
ODA’s current business and considered in the light of our relationships with other
partner organisations. Attention should also be given to the potential for the
sponsorship to be considered novel, contentious or repercussive. If there is any
concern as to the propriety of the provision of sponsorship, the matter should be
referred to the Head of Governance for a decision.
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Human Resources
March 2007
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Annexes
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Annex 1
The Sponsorship section in this Annex applies only to circumstances where the ODA
(or individual employees or their relatives) are offered sponsorship opportunities from
other organisations or individuals. Employees are reminded that the General Rules
detailed in the accompanying Corporate Hospitality, Gifts, Guest Speaker Fees &
Sponsorship Best Practice and General Rules section above apply to this Annex.
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The ODA seeks to protect employees from allegations of impropriety by ensuring that
the acceptance of all forms of corporate hospitality is transparent, approved and,
where appropriate, recorded. The main risk of challenge is acknowledged to be
when employees receive standard or premium forms of corporate hospitality, rather
than modest business meals provided by third parties.
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 recorded in the Register and approval sought from the
Director.
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As a rule of thumb, if the ODA is directly paying for all or part of the event, the
employee is not required to record the details in the Register.
Employees should note that the holder of the Register is required to report all
corporate hospitality with an estimated value of more than £50 to the Director of
Finance and Corporate Services (or in the case of that Director, the Chief Executive).
Receiving Gifts
ODA employees are only permitted to accept and keep the following gifts:
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• token gifts of very low value such as pens, diaries and small promotional
items (except from third parties involved in active tenders).
• "written off” ODA promotional stock.
• modest floral tributes (or similar) approved by the ODA for employees or their
relatives.
Accepting and keeping all other gifts is not generally permitted. In the rare
circumstances where declining the gift is likely to cause major offence (e.g. gifts from
foreign dignitaries or religious leaders), the gift may be accepted and then donated to
charity (with a record noted in the Register). However, special rules apply to
perishable gifts and these are listed below.
Employees should note that the holder of the Register is required to report all gifts
offered to or accepted by staff (even when declined) with an estimated value of more
than £50 to the Director of Finance and Corporate Services.
The ODA maintains a Register of Speaking Fees Received (Annex 4), held by the
Head of Legal alongside the Register of Corporate Hospitality Received & Gifts.
Where the payment for a speaking engagement is a gift of any description, the usual
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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.
Receiving Sponsorship
This section of the Guidelines covers sponsorship offered to ODA employees and
their families, as well as general sponsorship offered by third parties to support ODA
events. Annex 2 provides guidance for the sponsorship and support of third party
organised events.
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Annex 2
Corporate Hospitality, Gifts, Guest Speaker Fees & Sponsorship Policy
Scope
This annex paper sets out best practice policy for all staff who provide corporate
hospitality, give gifts or sponsor events and exhibitions on behalf of the ODA. The
guidelines have been prepared in line with ODPM / HM Treasury practice. These
Guidelines are mandatory for all ODA employees (including secondees, fixed term
and contract staff).
This Annex includes all events or occasions organised by the ODA (including those
for third parties) and those staged by outside organisations for which the ODA
provides part or complete funding. This Annex also covers the sponsorship of
materials such as publications and websites and the provision of gifts by the ODA to
third parties and to the ODA staff or their relatives.
All such events should be outlined in detail (consistent with information required in an
Events & Exhibitions Briefing Document - sample attached to this Annex). Corporate
hospitality events arising during the course of the year should be agreed with that
team’s Head of Department / Director and approved by the Head of Governance.
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Corporate hospitality must not be provided for party political activity or events that
conflict with our own objectives or the objectives of our sponsoring department or
partners.
To represent value for money, the investment should not only be in proportion to the
value of the project or initiative to the organisation (i.e. budget or receipts) but should
also be within a reasonable level of expenditure per head.
• The hosting of sit-down meals for large numbers of guests, where, for
example, the meal is unrelated to an activity such as an ODA conference.
• The purchase of tickets for sporting and artistic events, where these events
are unrelated to our areas of operation.
• The provision of inappropriate levels of entertainment for a public sector
organisation, e.g. expensive equipment or luxury leisure pursuits.
• The hire of unreasonably expensive venues in relation to market rates,
relevant audience and public sector expenditure considerations.
• Payments on behalf of third parties enabling them to attend luxury events
provided by third parties.
• Novel, contentious or repercussive proposals (apart from the examples given
above) could be activities where:
• The expenditure is out of proportion to the ODA’s activities and budgets.
• Value for money is not demonstrable via a link to our activities or a
reasonable expectation of increased business or receipts.
• The per head cost exceeds a reasonable value for money threshold in
relation to the nature of the event.
• Events are related to party political activity, conflict with the ODA’s objectives
or conflict with the objectives of our Sponsor Department or partners.
Similarly, all staff attending ODA sponsored exhibitions and events should complete
an Events and Exhibitions Report Document to evaluate success and send these to
the Head of PR and Media. Copies of both the above mentioned forms are attached
to this Annex.
Each department should ensure that their events are given individual cost codes to
monitor actual spend versus projected spend and to allow a full value for money
assessment to be made of the event.
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in any financial year). The Register of Gifts (Provided) and Special Payments is held
by the Head of Legal (see Annex 5).
The Head of Governance will be responsible for setting the ODA policy on the
provision of corporate gifts, however, it is up to each budget holder to justify in writing
why they have approved expenditure to purchase the gift and attach this to Annex 5.
Where appropriate, modest floral tributes (or similar) may be presented to staff, their
relatives or other third party business contacts on behalf of the ODA or the Board to
show the organisation’s appreciation, congratulations or sympathy. Payment for
such tributes should be authorised by an appropriate Director and charged by
accounting staff through the Petty Cash system to 'Sundries', or such other
procedure as authorised. For the avoidance of doubt, the purchase of approved
promotional items of modest value which feature the ODA logo and distributed to
visitors or guests at recognised ODA events are not considered to be gifts within
these guidelines.
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relation to the value of the project or initiative to the organisation (i.e. budget, receipts
or overall awareness and profile).
All sponsorship proposals for high-profile events and materials (e.g. televised events,
magazine special issues, newspaper supplements and websites) should be raised
with the Head of PR and Media. As with corporate hospitality, no sponsorship should
be provided for party political activity or events that conflict with our own objectives or
the objectives of our Sponsor Department or partners.
Offers of sponsorship from more than one private sector organisation; or a request to
buy exhibition space during ODA organised exhibitions or conferences; or a request
for sole sponsorship by a public body must always be submitted for approval to the
Head of PR and Media, who will determine the appropriateness of the sponsor /
exhibitor and the event bearing in mind the aims and objectives of the ODA.
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Annex 3
Code abbreviations:
• H (hospitality received)
• HD (hospitality declined)
• GRD (gift received and then donated)
• GD (gift declined)
N.B. Holders of this Register are required to report all recorded hospitality or gifts
with a value of £50 or higher to the Director of Finance and Corporate Services.
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Annex 4
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Annexe 5
REGISTER OF GIFTS (PROVIDED)
Sponsor department delegated authority permits the ODA to purchase and provide
gifts up to a maximum value of £1,000 per gift item and a total gift purchase
delegation of £10,000 in any one financial year.
All gifts provided by (or on behalf of) the ODA must be justified in writing and
approved in advance by the budget holder and recorded in this Register to ensure
the Sponsor Department delegations are not breached.
Any gift or payment with a value of more than £50 must also be authorised in
advance by the Chief Executive.
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