Gifts & Hospitality Policy 1

Last updated: April 2021

Gifts and Hospitality Policy

Policy Aims

The aim of this policy is to ensure that New Anglia LEP will not intentionally create an

obligation on either party as a result of hospitality, but that such occasions will be

used to enhance our professional working relationships.

Recommendation 32 of the Nolan Committee requires that: “…a record of invitations

and offers of hospitality should be kept. 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”.

Responsibilities

It is the responsibility of the Chief Executive Officer to ensure that:

• a hospitality register is maintained

• the register can provide the basis for the provision of information to partners

• employees are fully aware of the duty upon them to record gifts and

hospitality, and the procedures for doing so.

It must be emphasised that the intent of this policy is not to discourage or prevent the

acceptance of hospitality where this is helpful to further the interests of New Anglia.

The Nolan Committee accepted that there were advantages in officials continuing to

be free to accept invitations to working lunches and dinners and for those with a

representational role to attend other events.

Policy

The acceptance of any hospitality and/or gifts must be consistent with:

• the provisions of the Prevention of Corruption Acts, which make it a criminal

offence for employees in their official capacity, to accept any gift or

consideration corruptly as an inducement or reward for doing (or not doing)

anything or showing favour (or disfavour) to any person in their official

capacity

• the general principle that employees should not receive benefits of any kind

from a third party which might be seen to compromise their personal

judgement or integrity.

The guiding principles are that:

• employee’s conduct in a private capacity must not give rise to any suspicion

of conflict between their official duty and private interests

• employee’s conduct in an official capacity must not give the impression, to

any member of the public, to any organisation with which they deal, or to

colleagues, that they have been (or may have been) influenced by a gift or

consideration to show favour or disfavour to any person or organisation

• any gifts or hospitality should always be refused if the employee or the

company is in any doubts about the propriety of accepting.

Acceptability Assessment

Gifts, entertainment and hospitality include the receipt or offer of gifts, meals or

tokens of appreciation and gratitude, or invitations to events, functions, or other

social gatherings, in connection with matters related to the business. These activities

are acceptable provided they fall within reasonable bounds of value and occurrence.

Gifts & Hospitality Policy 2

Last updated: April 2021

In order to evaluate what is acceptable, the following process will be established:

• what is the intention – is it to build a relationship or is it something else?

• how would this look if these details were on the front page of a newspaper?

• what if the situation were to be reversed – would there be a double standard?

If it is difficult to answer one of the above questions, there may a risk involved which

could potentially damage the LEP’s reputation and business. The action could well

be unlawful.

Circumstances which are never permissible include examples that involve:

• a ‘quid pro quo’ (offered for something in return)

• gifts in the form of cash/or cash equivalent vouchers

• entertainment of a sexual or similarly inappropriate nature

• gifts offered during the time of a major bid, tender or transaction.

As a rule, the LEP will not provide gifts to, or receive them from a government official.

Report immediately to the Chief Executive Officer any overt or covert offer of a gift or

other inducement to some action pertaining to a contract.

Circumstances that are usually acceptable include:

• modest/occasional meals with someone with whom the LEP does business

• occasional attendance at ordinary sports, theatre and other cultural events

• gifts of nominal value, such as pens, or small promotional items.

If an example does not fall under the above categories, it is necessary to seek

guidance from a manager.

The Register

All gifts and hospitality accepted with a value of over £50 must be recorded in the

Hospitality Log and on the employee’s Register of Interests form (if applicable).