Policy on Gifts and Hospitality
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1 Policy on Gifts and Hospitality 1. General No gift or hospitality should be accepted by SFT Board members or employees which could give rise to an inference that a member or employee might show favour or disadvantage to any individual or organisation or influence the judgement of that person. You must never canvass or seek gifts or hospitality. Any gifts and hospitality offered, whether or not accepted, with a monetary value greater than 50 must be recorded and a record made available for public inspection. SFT maintains a Hospitality Register which is regularly published on the company website. Details of any gifts or hospitality offered must be submitted to the Office Manager within 7 days for inclusion on the register. You should also consider whether there may be any reasonable perception that any gift received by your spouse or cohabitee or by any company in which you have a controlling interest, or by a partnership of which you are a partner, can or would influence your judgement Business Gifts You should not normally accept business gifts other than items of very low value, normally under 15. Appropriate gifts may be accepted as a thank-you for a speaking engagement or similar, with any such gift over the value of 50 recorded. Where possible, an offer of a gift other than one of a very low value, should be politely declined. Where this is not possible, for example gifts given at a public event or gifts received through the post, then the gift may be returned if possible cost effectively and without causing embarrassment, or donated for charitable purposes. The term gift includes benefits such as relief from indebtedness, loan concessions, or provision of services at a cost below that generally charged to members of the public Hospitality Accepting modest hospitality is part of a business relationship. However, anyone accepting hospitality must be aware of the risk of being perceived by others to have been influenced in making a business decision as a result of accepting such hospitality. How often and how much hospitality we accept should not be significantly greater than SFT would be likely to provide in return. Hospitality should not be accepted at periods that may be considered sensitive i.e. shortly before an award of contract or conduct of a tender procedure, either by SFT or in respect of a project where SFT is involved,which may involve the party offering the hospitality. Page 1 of 5
2 Hospitality which involves the provision of overnight accommodation or has a monetary value greater than 50 must be registered in the Register of Hospitality. You must not accept repeated hospitality from the same source except isolated gifts of a trivial character or inexpensive seasonal gifts such as a calendar or a diary, or gifts received on behalf of SFT. If in any doubt advice should be sought from the SFT Chief Executive. 2. Relationship to Procurement It is an offence under the Prevention of Corruption Act 1906 for those employed by contracting authorities in their official capacity corruptly to accept any gift or consideration as an inducement or reward for doing, or refraining from doing, anything or showing favour or disfavour to any person. Under the Prevention of Corruption Act 1916, any money, gift or consideration received from a person or organisation holding or seeking to obtain a contract will be deemed by the courts to have been received corruptly unless proved to the contrary. It is therefore particularly important to be aware of gifts and / or hospitality from organisations that may be bidders, or associated with bidders on projects or programmes over which SFT has an influence. Any offer of gifts or hospitality from such an organisation should be notified to the Chief Executive for specific consideration. Page 2 of 5
3 Hospitality and Gift Register 1 January to 31 March 2012 Date Received Recipient (name & position) 10 January 2012 Barry White 10 January 2012 Colin Proctor 10 January 2012 Gordon Shirreff 10 January 2012 Colin Proctor 10 January 2012 John Hope 10 January 2012 Peter Reekie 11 January 2012 Andrew Bruce Item Burns Supper (speaker), Pinsent Masons offices, London From (name & company) Brian McQuade, Miller Construction Jack Quick, Jack Quick, Colin Smith, Turley Associates Colin Smith, Turley Associates Stuart Barr, Pinsent Masons LLP Brian McQuade, Miller Construction Estimated Value / January 2012 Gemma Gordon 12 January 2012 Barry White 16 January 2012 Neil Grice 23 January 2012 Tony Rose (Infrastructure Director) Partnership Awards 2012,London Hilton, Park Lane, London Chinese New Year Dinner, Grand Central Hotel, Glasgow Scotland V England Rugby Murrayfield, Ann MacLean, Thomas & Adamson Kirsty Wilson, Partnerships Bulletin Pauline Parke, Davis Langdon Clare Lacey, Quayle Munro 75 (BW is part of the judging panel for the awards) Page 3 of 5
4 31 January 2012 Neil Grice 31 January 2012 Peter Reekie (Finance Director) 2 February 2012 Colin Proctor 7 February 2012 Colin Proctor 9 February 2012 Barry White 20 February 2012 Barry White 20 February 2012 Peter Reekie (Director of Finance & Structures) 23 February 2012 Barry White 23 February 2012 Barry White 7 March 2012 Barry White South East Hubco Dinner The Bonham, South East Hubco Dinner The Bonham, Chinese New Year Dinner Grand Central Hotel, Glasgow Royal Society of (RSE), Infrastructure Lecture and Dinner, George Street, Scott Moncrieff, Drinks & Canapés, National Museum of Scotland Scott Moncrieff, Drinks & Canapés, National Museum of Scotland Scottish Renewables/PwC Dinner, Hotel du Vin, Interact Lunch, New Club, Discounted rate for 2 nights accommodation at Grosvenor Square Hotel, London part of judging panel at Partnerships Awards and speaking at The Big Five conference. (Hotel is venue for conference and adjacent to awards dinner venue.) Tracy McAdam, Galliford Try Tracy McAdam, Galliford Try Pauline Parke Davis Langdon Laura Kinnear, JM Architects Dr William Duncan, RSE Nick Bennett, Scott Moncrieff Nick Bennett, Scott Moncrieff Louise Gallagher, Scottish Renewables Brian Thomson, JM Architects Kirsty Wilson, Partnerships Bulletin 80 (rate reduced to 120 per night) (PR is a Director of this Company). Dinner later cancelled. Page 4 of 5
5 9 March 2012 Peter Reekie 14 March 2012 Barry White 15 March 2012 Barry White 15 March 2012 Peter Reekie McGrigors ETAPE, Cycling event, lunch & dinner, Gleneagles Hotel Currie&Brown, Post-budget Lunch, venue tbc Scottish Business Achievement Award Trust Lunch, Prestonfield House Hotel, Association of Consulting Engineers Annual Dinner, The Western Club, Glasgow Kay Auld, McGrigors LLP Margaret Wilson, Currie&Brown Jim McIntyre, Robertson Construction James Tod, ACE Scotland but later unable to attend 22 March 2012 Barry White 22 March 2012 Vicky Shorrock (PA to Chief Executive) Blue Sky event, Hopetoun House, South Queensferry Blue Sky event, Hopetoun House, South Queensferry James England, Blue Sky James England, Blue Sky 23 March 2012 Peter Kearns 23 March 2012 James King 27 March 2012 Neil Grice 28 March 2012 Barry White 28 March 2012 Peter Reekie (Director of Finance & Structures) IPFA Event (Speaker) followed by dinner, The Honours Restaurant, Partnership Awards 2012 dinner, London Hilton, Park Lane, London Partnership Awards 2012 dinner, London Hilton, Park Lane, London Susan D aish, WSP Richard Cantlay, Mott Macdonald Andrew Orr, Macroberts Stephen Gordon, Capital Stephen Gordon, Capital Page 5 of 5
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