Entertaining, Hospitality & Gifts Policy

ENTERTAINING, HOSPITALITY & GIFTS POLICY

June 2017

Author: James Platts

The University of Bradford and all other public sector and quasi-public funded organisation’s are under increasing pressure to ensure that all products and services are purchased with the consideration and proof of value for money. UoB must be able to evidence that all expenditure is justifiable as business critical, in an environment where external scrutiny and public interest via FOI request are becoming frequent and business as usual.

Contents

1.Business Entertaining

2.Working Lunches

3.Externally Sourced Food

4.Staff Events & Parties

5.Alcoholic Drinks

6.Reciprocal Hospitality

7.Gifts

8.Festive & Celebratory Cards

INTRODUCTION

The Bribery Act 2010 received Royal Assent in April 2010 and came into force on the 1st July 2011. The Act makes radical changes to existing UK legislation on bribery and corruption and the impact will be felt across all UK companies including the Education Sector. The University of Bradford is committed to ensuring that the organisation adopts a policy and procedures that introduces a zero-tolerance policy towards bribery and corruption, this policy extends to all employees/ representatives/third parties/ business partners or agents of the University

• The University of Bradford is committed to the highest standards of openness, integrity and accountability. It seeks to conduct its affairs in a responsible manner, having regard to the principles established by the Committee on Standards in Public Life. For many organisations gifts and hospitality are part of building relationships and in some societies, they are required behaviour.
• This policy is designed as an adequate procedure to prevent expenditure being used as a potential bribe and extends to all parties within the organisation or dealing with the University. Furthermore, it is illegal under the provisions of the Act where payments are made with the intent to influence a foreign public official with the aim of retaining or obtaining an advantage in the conduct of business and if they confer an advantage directly or indirectly. The University is committed to the following values:The University prohibits the offer or receipt of gifts, hospitality or expenses whenever they could affect or be perceived to affect the outcome of business transactions and are not reasonable and bona fide.

Good practice permits promotional expenditures where they are transparent, proportionate, reasonable and bona fide within the confines of this policy.

1.Business Entertaining

1.1It is recognised that there is a legitimate business need, on occasions, for representatives of the University to entertain or provide hospitality for key stakeholders, sponsors, customers, potential customers and or other external persons to the University.

1.2The level of this provision is to be clearly identified within the Faculty/Directorate budget and any expenditure against this budget must be authorised in accordance with the Financial Regulations of the University.

1.3It is good practice when entertaining, that the representation from the University should not be disproportionate to that of those being entertained. This applies, whether entertaining on the University’s premises or at external venues. For example there should typically be, at least, an equal ratio of external guests to University employees unless there is a sound justification for doing otherwise e.g. lunches for Honorary Graduates and External Examiners. Ideally there should be more external guests than University employees at any one function or event.

1.4Generally purchasing or giving gifts for/to key stakeholders, sponsors, customers, potential customers or other external persons to the University is not allowed unless the goods are distributed with the aim of advertising to the general public. Exceptions to this rule may be;

• Visiting VIPs, dignitaries or lecturerswho have agreed to waive their normal fee
• Visits or occasions where it is customary to exchange gifts

The value of the gift in these instances should not be excessive or more than any waived fee. The value should not exceed £30, and in all cases should be logged stating the reason for the gift, who the recipient is and what their role is in relation to UoB, Prior approval is required from the Director of Finance or the Associate Director of Procurement for any gift that is above the £30 limit stated.

1.5In all cases of business entertainment, the names of the individuals and if applicable, their organisations should be recorded onto either the Catering booking form, an expense claim form for UK based business entertaining expense claim form for business entertaining outside of the UK the relevant invoice.These will be retained by Finance for any subsequent internal or external audit of the expenditure.

2.Working Lunches

The University hospitality policy does not allow for “working lunches” unless

2.1The “working lunch” is part of business entertaining, where there are external visitors and there is not disproportionate representation from the University.

2.2The “working lunch” is taken whilst travelling on University business.

The “working lunch” is for an internal meeting where there is a valid justification to support it. For example: when requested attendees are unavailable to attend the meeting at any other time, these types of meetings should be infrequent.

The requester of hospitality will need to indicate their justification for all catering requests for University of Bradford which will be processed by BaxterStorey. For a request to supply catering, please make enquiries through hospitality line (ext4901) or email A completed CI form will need to be submitted to confirm your order.

Failure to give a valid justification may in the event of an Inland Revenue audit give rise to a benefit in kind charge to any individuals concerned.

NOTE: To align with Inland Revenue guidelines, access to “working lunches” cannot be determined by the status or role of an employee.

3.Externally Sourced Food

The University does not permit its employees to purchase externally sourced food for consumption within business meetings.

IMPORTANT NOTE: Non-conformance of these legal requirements, in certain circumstances, where an outbreak of food poisoning has occurred, can lead to prosecution of the individual (employee), where either a fine and or custodial sentence could be applied.

3.1If the University’s Catering Contractor is unable to provide hospitality (which would need to be evidenced) and external Caterers are to be engaged to provide food and service for specific functions and or meetings they must be reputable and also hold the necessary relevant certifications and or licences

3.2The University and or appointed Catering Contractor cannot take any responsibility for any food that is sourced externally and brought onto the University’s premises for consumption. This also includes the provision of resources, such as assistance for service and or the use of any light or heavy catering equipment.

4.Staff Events, Parties and Gifts

4.1Food and non-alcoholic drinks may be provided at events and presentations to celebrate work related activities and achievements. Such events are subject to approval by the Dean or Director, in accordance with the Financial Regulations of the University.

4.2University hospitality cannot be used to pay for Staff parties or private functions. These will need to be paid for by the individuals concerned. The University will allow the use of its premises and facilities for such functions, subject to prior consent and approval being given by the relevant Deans or Directors and in line with the guidance provided within this policy.

The University Catering Contractor Baxter Storey, will provide food and services at preferential rates for individual staff members, to private functions as and when required. For full details go to: The University can not accept any liability or responsibility whenever such arrangements are made.

4.3The University would prefer that its Catering Contractor is used for private functions but if external Caterers are to be engaged, the individual will need to carry out their own necessary due diligence. The University and its Catering Contractor cannot accept liability or responsibility whenever an external caterer is used and will not allow the provision of the use of certain resources or equipment.

4.4University hospitality cannot be used to pay for gifts to staff this includes festive, birthday, leaving, and anniversary gifts or flowers for individuals who fall ill. It is normal practice for this to be provided by private collections from concerned staff. Agreed exceptions to this rule are gifts provided under the long service award schemeand flowers for death in service. Any further exception to this rule will be discussed and agreed with the Director Finance and HR and part of the University reward strategies.

5.Alcoholic Drinks

5.1Alcoholic drinks should not be provided for consumption, either at business meetings or at private functions.

5.2It is acknowledged that in certain business critical circumstances the provision of alcoholic drinks when taking VIPs, guests and hosts for meals is acceptable.

IMPORTANT NOTE: It is imperative to remember that whilst working on behalf of UoB, staff are representing the university and responsible for the conveying appropriate behaviour at all times.

6.Reciprocal Hospitality

6.1University staff and lay members may accept meals or equivalent hospitality only in the course of business. Offers of hospitality, which may unduly influence, or be deemed by others to unduly influence, the actions of an individual in favour of the provider of the hospitality, or which are on scale significantly greater than the University would provide in return, should be refused.

6.2All offers of hospitality over £30 should be reported in writing to the Associate Director of Procurement in Finance where a register of such offers will be kept and reported to the Audit Committee on an ad-hoc basis for reasons of transparency.

IMPORTANT NOTE: Where business trips are being sponsored by 3rd parties for academic activities, such as delivering lectures, research papers, speeches; these need not be reported but must be authorised in accordance with the Financial Regulations of the University.

7.Gifts from third parties

7.1University staff and lay members should generally decline all offers of gifts, other than those of a very small intrinsic value or on occasions where it is customary to exchange gifts with a host.

7.2Gifts of money must always be refused.

7.3All offers of gifts with a value of greater than £25 should be reported in writing to theFinancial Compliance & Risk Accountant in Financewhere a register of such offers will be kept and reported to the Audit Committee on an ad-hoc basis for reasons of transparency.

8.Festive & Celebratory Cards

8.1Corporate Communications will design and source a University branded Festive & Celebratory card and electronic e-card for sending to external contacts and organisations. The cost of printing is to be borne by the requester.

8.2It is not permitted to send the University branded Festive & Celebratory card or electronic e-card to fellow colleagues, Schools or Departments of the University. The exception to this being the Chair of Council and the Vice-Chancellor.

ADDITIONAL GUIDANCE

If you require any additional information or guidance in relation to the contents of this policy and your responsibilities please contact The Associate Director of Procurement, James Platts, e-mail telephone 01274 233132 in the absence of the Responsible Officer, Mr Stuart Mckinnon-EvansChief Finance Officer 01274

This policy should be read in association with the following University finance policies:

• Financial Regulations
• Code of Practice on Serious Financial Misconduct and Irregularities
• Anti Money Laundering Policy
• Public Interest Disclosure Policy(Whistleblowing)
• Purchasing Policy

These policies can be found on the University’s website at:

The University and its management are committed to a zero tolerance policy and will not accept any forms of bribery or corruption taking place within its organisation or representatives/third parties/ business partners or agents of the University.

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