Gifts and Hospitality Policy
Purpose of Document
In terms of accountability it is important for an organisation to have in place a written policy that regulates the relationship between the Company, its staff and the external environment. This policy provides a safeguard for the Company by providing clarity about the standards the organisation sets and what is expected of its employees.
The acceptance of gifts and offers of hospitality can give rise to suspicion of improper conduct, particularly if offered by individuals or companies that are undertaking, or hoping to undertake, business with the organisation.
As a consequence, Communisis has developed its Gifts & Hospitality Policy to assist employees in complying with the standards set by the organisation. The Gifts & Hospitality Policy lays down the underlying principles of accepting and refusing gifts and hospitality, as well as providing a methodology for the recording of such instances.
This policy lays down the accepted amounts for staff with regard to gifts and hospitality and employees must ensure that any hospitality is recorded. This policy applies to all personnel associated and employed by Communisis plc.It applies on an equal basis to all employees.
In general, all gifts should be refused. However, in cases where refusal is likely to offend, some discretion may be exercised. The offer of a gift should be reported to the General Manager of Communisis Sourcing who will decide based on the nature, volume and origin of the gift whether it should be refused or accepted.
Staff may accept occasional seasonal gifts of a low value such as calendars, diaries and pens. It is not necessary to ascertain the exact value of such gifts but anything that appears to be worth more than £25 should not be accepted. Staff should exercise careful judgement in such cases.
Working lunches provided on a modest scale and on an occasional basis are part of normal business practice and staff are not required to obtain formal approval to attend them. However if staff receive a prior invitation to a more formal lunch or dinner, they must declare their intention to attend to their line manager.
As with gifts, the refusal of any invitation may cause embarrassment and this must be taken into account by anyone considering or approving such an invitation. Individuals must also take account of the timing of the invitation in relation to decisions which Communisis may be taking effecting those offering the hospitality.
Invitations to other events such as launches, conferences, arts or sporting events etc. should be subject to the same scrutiny as above.
Invitations to attend all-expenses paid study tours, site inspections or product demonstrations must have prior approval from the appropriate Director particularly if overseas travel is involved.
In order to counter any accusation or suspicion of improper conduct, Communisis will maintain a central register of gifts and hospitality. This register will be maintained by the General Manager of Communisis Sourcing
All gifts (except seasonal gifts of low value) and offers of hospitality (except to modest working lunches) should be recorded on the gift and hospitality form and forwarded at the earliest opportunity. This applies whether they have been accepted or declined.
The register will be inspected annually.