Hospitality, Gifts and Bribery Policy

Transcription

1 POLICY DOCUMENT Hspitality, Gifts and Bribery Plicy LAST UPDATED (by) Rachel Lawsn 6 th Nvember 2018 LAST REVIEWED (by) POLICY TYPE REVIEW FREQUENCY Vluntary Every tw years RESPONSIBLE Leadership Team Gverning Cmmittee APPROVED UPDATED: Shared Drive Website Rachel Lawsn Resurces Cmmittee Apprved by Resurces Cmmittee 21 st Nvember st Nvember 2018 Mnday 19 th Nvember 2018 At Newlands we create cnfident and respnsible yung wmen equipped with the skills they need fr the twenty first century. We empwer all students t realise their ptential as part f a sustainable cmmunity cmmitted t lifelng learning. 1

2 Intrductin The principle f integrity requires that staff shuld nt place themselves under an bligatin that might influence, r be perceived t influence, the cnduct f their duties. This means that the receipt f hspitality and gifts must be subject t clear restrictins and that any that are accepted must be declared and recrded. The prcess set ut in this plicy and prcedure is designed t safeguard emplyees frm any misunderstanding r criticism. This plicy takes int cnsideratin the requirements under the UK Bribery Act 2010, which came int effect 1 July The Ministry f Justice has published guidance which prvides the basis fr inclusin in this plicy. This guidance is under sectin 9 f the act. The Chair f Gvernrs is respnsible fr ensuring cmpliance with Plicies and Prcedures. This prcedure applies t all staff. Gifts Yu must nt accept cash, r persnal gifts with a significant mnetary value, under any circumstances, althugh items f nminal value (apprximately 25 r belw) r free prmtinal pens, calendars, diaries r similar items may be accepted. Gifts which are intended fr as an academic bdy can be accepted but must nt be retained by the individual wh receives them. Such gifts shuld be depsited with the Finance Office, fr use by Newland Girls Schl. Persnal gifts may nt be slicited under any circumstances. When yu have t decline a gift, yu shuld be curteus but firm, and draw the attentin f the persn making the ffer t the existence f this plicy and the UK Bribery Act All gifts received must be recrded in s gifts and hspitality register, which is maintained by the Finance Officer/ Accuntant. Supplier Special Offer Gifts Gifts are smetimes ffered by the suppliers with the purchase f items. All special ffer gifts are the prperty f and must be turned int the Finance ffice fr use by the Schl. Hspitality Yu shuld never accept lavish hspitality that culd be interpreted as a way f exerting an imprper influence ver the way yu carry ut yur duties. Nr shuld yu ffer such hspitality t thers n behalf f. The timing f hspitality in relatin t prcurement r a purchasing decisin that Newlands Girls Schl may be taking is especially sensitive. Yu shuld never slicit hspitality. As a general rule, yu shuld nt accept hspitality that the Schl wuld nt reciprcate in similar circumstances. Staff attendance at sprting and cultural events at the invitatin f suppliers, ptential suppliers r cnsultants is nt nrmally acceptable. Where it is cnsidered that there 2

3 is a benefit t in a member f staff attending a spnsred event, the attendance shuld be frmally apprved by the Headteacher. If necessary, yu shuld pay yur share f any csts and claim these in the usual way by fllwing the Expenses Plicy. When yu have t decline hspitality, yu shuld be curteus but firm, and draw the attentin f the persn making the ffer t the existence f this plicy and the UK Bribery Act Yu may accept mdest wrking meals and light refreshments withut making any declaratin. All ther hspitality must be recrded in the schl s gifts and hspitality register which is maintained by the Finance Officer/ Accuntant. Other hspitality may be accepted where: Yu are representing in the cmmunity r are imparting infrmatin abut t the public. An event is clearly part f the life f the cmmunity r where Newlands Girls Schl shuld be seen t be represented. The hspitality cncerns attendance at a relevant cnference r curse where it is clear the hspitality is crprate rather than persnal. Staff Entertainment In the event that the schl decides t cntribute twards a staff scial event this must be apprved in advance by the Gvernrs f the Finance Resurces Cmmittee and shuld cmply with HMRC guidelines. All expenditure f this kind will cme frm the Schls Unrestricted funds and nt GAG funding frm the EFA. Expenses Claims Where hspitality is t be prvided by this shuld be apprved in advance by a member f the Leadership Team. The Headteacher r Bursar shuld review the hspitality in light f the UK Bribery Act Hspitality is nt prhibited by the Act but shuld be cnsidered in light f it. Any hspitality prvided shuld nt be extravagant. Claims fr reimbursement f expenses shuld be made n the relevant frm and receipts shuld always be included. PROVEIT Test 3

4 Please use the fllwing guideline t determine whether an ffer f a gift r hspitality is acceptable: PURPOSE-Tken, thanks r seeing a favur? (tken/thanks= yes; favur= n) RULES- What are they? Des this situatin cnfrm? OPENESS- Is the ffer transparent? VALUE- Expensive r inexpensive? ETHICS- Des the ffer fit with Schl s ethics? IDENTITY Wh has made the ffer? TIMING Are yu abut t make a decisin affecting the giver? UK Bribery Act 2010 It is an ffence under Sectin 7, which can be cmmitted by a cmmercial rganisatin which fails t prevent persns assciated with them frm bribing anther persn n their behalf. Facilitatin Payments, payments t induce fficials t perfrm rutine functins they are therwise bligated t perfrm, are bribery under the Act. Trustees and Senir Leadership d nt tlerate Bribery in any frm. Senir Leadership cnsiders all rganisatins which the schl des business with, in rder t cnsider the risk. Senir Leadership cnsiders all persns r rganisatins which act n behalf f the schl r prvide services fr the schl, in rder t cnsider the risk. Actins f suppliers f gds d nt create a risk fr the schl under the UK Bribery Act As risk f bribery can ften be greater in verseas transactins, all verseas transactins must be apprved in writing n the purchase rder by the Headteacher r the Chair f Gvernrs, regardless f the value f the transactin. Signed: (Chair f Gvernrs) 4

5 Register fr Gifts and Hspitality Emplyee Name Nature f Gift/ hspitality Value Name f Cmpany r individual Date Headteacher Apprval 5