Gifts and Hospitality Policy. Director of Integrated Governance. 06 October The Governing Body or GCCG Executive

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1 Gifts and Hospitality Policy Author(s) Director of Integrated Governance Version 1.1 Version Date 22 September 2016 Implementation/Approval Date 06 October 2016 Review Date September 2019 Review Body The Governing Body or GCCG Executive Policy Reference Number 003 1

2 Version Author Date Reason for review 1.0 Angelique Kempton June 2013 Inaugural Governing Body Policy Statutory requirement 1.1 Anna English Sept 2016 Minor changes in line with Refresh in Statutory requirement Page 2 of 6

3 1.0 Summary NHS Staff must conduct their business in accordance with HSG (93)5, 'Standards of business conduct for NHS staff; copy available from the Director of Integrated Governance. It is the responsibility of all staff to ensure that they are not placed in a position which risks, or even appears to risk, conflict between their private interests and their NHS duties. It is an offence, moreover, under the Prevention of Corruption Act 1916 for employees, to accept any gift or consideration as an inducement or reward for: doing, or refraining from doing, anything in their official capacity showing favour/disfavour to any person in their official capacity Breaching the above Act renders staff liable to loss of employment and pension rights in the NHS, prosecution, fine and possible imprisonment. The CCG wishes to encourage anyone having reasonable suspicions of fraud or corruption to report them. To this end, the CCG s Whistleblowing Policy encourages staff not to turn a blind eye or to remain silent but to accept their responsibilities for the CCG s interests and to voice genuinely held concerns about Fraud and Corruption. All instances of fraud and corruption will be dealt with in accordance with the CCG s Counter Theft, Fraud and Corruption Policy. A gift is defined as any item of cash or goods, or any service, which is provided for personal benefit, free of charge or at less than its commercial value. All gifts of any nature offered to CCG staff, governing body and committee members and individuals within GP member practices by suppliers or contractors linked (currently or prospectively) to the CCG s business should be declined, whatever their value. The person to whom the gifts were offered should also declare the offer to the team or individual who has designated responsibility for maintaining the register of gifts and hospitality so the offer which has been declined can be recorded on the register. Gifts offered from other sources should also be declined if accepting them might give rise to perceptions of bias or favouritism, and a common sense approach should be adopted as to whether or not this is the case. The only exceptions to the presumption to decline gifts relates to items of little financial value (i.e. less than 10) such as diaries calendars, stationery and other gifts acquired from meetings, events or conferences, and items such as flowers and small tokens of appreciation from members of the public to staff for work well done. Gifts of this nature do not need to be declared to the team or individual who has designated responsibility for maintaining the register of gifts and hospitality, nor recorded on the register. Any personal gift of case or cash equivalents (e.g. vouchers, tokens, offers of remuneration to attend meetings whilst in a capacity working for or representing the CCG) must always be declined, whatever their value and whatever their source, and the offer which has been declined must be declared to the team or individual who has designated responsibility for maintaining the register of gifts and hospitality and recorded on the register. Page 3 of 6

4 To this end, staff should, in general, politely decline all offers of gifts, hospitality and entertainment. This particularly applies to a person or organisation holding or seeking to obtain a contract with the Governing Body. If you are in any doubt seek the advice of your line manager or Director. The Governing Body maintains a Register of Gifts and Hospitality for the recording of all gifts/services offered, regardless of whether accepted. If an offer is made to you please collect a form from the Director of Integrated Governance. Staff should also be aware that donations can be made to the Greenwich Charitable CCG Fund. Where, for example, relatives or patients wish to show their appreciation to a particular member of staff or team they should be encouraged to consider making their contribution by way of a donation. This can either be to one of the national or local charities of their choice or to the Greenwich Charitable Trust Fund. These are currently administered on behalf of the Governing Body by Queen Elizabeth Hospital, and where a donation is to be made cheques should be made payable to Greenwich Charitable CCG Fund, and sent to Greenwich Park Street, Greenwich SE10 9LR, with a written note of acknowledgement. This policy applies to the Governing Body members as well as to the staff of the CCG. Page 4 of 6

5 Appendix 1 - Equality & Equity Impact Assessment Checklist This is a checklist to ensure relevant equality and equity aspects of proposals have been addressed either in the main body of the document or in a separate equality & impact assessment (EIA)/ equality analysis. It is not a substitute for an EIA which is required unless it can be shown that a proposal has no capacity to influence equality. The checklist is to enable the policy lead and the relevant committee to see whether an EIA is required and to give assurance that the proposals will be legal, fair and equitable. The word proposal is a generic term for any policy, procedure or strategy that requires assessment. Challenge questions Yes/ What positive or negative impact do you assess there may be? 1. Does the proposal affect one group more or less favourably than another on the basis of: Race Pregnancy and Maternity Sex Gender and Gender Re-Assignment Marriage or Civil Partnership Religion or belief Sexual orientation (including lesbian, gay bisexual and transgender people) Age Disability (including learning disabilities, physical disability, sensory impairment and mental health problems) 2. Will the proposal have an impact on lifestyle? (e.g. diet and nutrition, exercise, physical activity, substance use, risk taking behaviour, education and learning) 3. Will the proposal have an impact on social environment? (e.g. social status, employment (whether paid or not), social/family support, stress, income) 4. Will the proposal have an impact on physical environment? (e.g. living conditions, working conditions, pollution or climate change, accidental injury, public safety, transmission of infectious disease) 5. Will the proposal affect access to or experience of services? (e.g. Health Care, Transport, Social Services, Housing Services, Education) Policy Author Anna English Date Signature: Equalities Lead (Carol Berry) Date Signature: Page 5 of 6

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