Corporate report

Gifts and hospitality policy

Updated 14 January 2021

1. Introduction

The aim of the Gifts and Hospitality policy is to guard against the risk of allegations of impropriety by SSRO members or staff, however contracted, by providing advice on a number of key issues relating to the rules of regularity and propriety. The rules are based on the fundamental requirements of Parliament, HM Treasury and the National Audit Office.

Under the Bribery Act 2010, it is a criminal offence for employees in an official capacity to accept any gift or consideration as an inducement or reward for:

• doing or not doing anything; or
• showing favour or disfavour to any person.

The policy applies to everyone working for the SSRO or on SSRO’s behalf, including agency workers, secondees, interns, consultants and contractors. SSRO members and staff are not civil servants, and therefore the provisions of the Civil Service Code do not form part of their terms and conditions of employment. However, as members of a public body, SSRO members and staff are required to abide by the highest ethical standards. All members and staff must be seen to act with complete honesty and integrity, and must not put themselves in a position where they could be accused of acting improperly.

Members and staff are responsible for their decisions on the acceptance of gifts or hospitality and for ensuring that any gifts or hospitality accepted can stand up to public scrutiny and do not bring their public office and the SSRO into disrepute.

Members and staff should exercise the utmost care in accepting hospitality or gifts where there could be a real or perceived conflict with their official duties at the SSRO. Members and staff must not accept any gifts or hospitality from any of their employments which might, or might reasonably appear to, compromise their personal judgement or integrity or place them under an improper obligation. Members and staff must never canvass or seek gifts and hospitality.

2. Gifts

The acceptance of gifts from interested business parties could be presented as promoting a conflict of interest that might arguably have compromised the impartiality of members and staff in the decisions that they were required to make.

Offers of gifts should be reported to the Chief Executive and, if of any significant value, should be declined.

It is not possible to put forward hard and fast rules for when gifts may be accepted, since in practice this will depend upon the circumstances and business needs of individual areas of the SSRO.

The general principles for the acceptance of gifts are:

• The gift must be of a nominal or notional value. Typically, a gift should not be accepted if the cumulative value from any one organisation or individual exceeds £200 in any 12 month period or £50 for any one gift.
• The gift must be given for an appropriate reason.
• The gift must be given at an appropriate time (e.g. not in advance of the issuing of an opinion or determination, or in advance of the award of a contract).
• The gift must be of a “one-off” or irregular nature (i.e. that could not be viewed as a regular source of income by HMRC for personal taxation purposes).
• The details of all gifts accepted or declined should be fully recorded in the Gifts and Hospitality Register (see Appendix), which will be published on the SSRO’s website.

Exceptions

The Chief Executive may, in exceptional circumstances, override the above principles where members and staff are able to demonstrate that the business needs of the SSRO justify it. An example of this might be where a visiting foreign dignitary offers a gift, and to refuse it would cause offence. The Chief Executive’s approval of the acceptance of the gift should be sought as soon as the gift is offered. Another example is where a gift is of a low promotional value, for instance a company keyring from a stakeholder at a meeting with the SSRO.

Use of Accepted Gifts

Retention of accepted gifts by the recipient is at the discretion of the Chief Executive. In reaching their decision consideration should be given as to whether the gift should be put to another use (i.e. donated to a charity or a library, displayed in public offices etc) and the risks to the reputation of the SSRO associated with the retention of the gift by an individual. In no circumstances may an individual sell an accepted gift for monetary gain.

Making Gifts

Reciprocal gifting is not encouraged. However, there may be circumstances where the failure to give a gift would give offence. An example would be an official visit by foreign officials whose custom would be to give and/or receive a token of friendship or respect. In these circumstances authority from the Chief Executive must be sought.

Depending on the circumstances and nature of the gift, HM Treasury approval may be needed. In any case, the cost of the gift should be modest and not exceed the value of the gift received. Gifts of an unusual nature, or those valued over £100,000, must be approved by the Treasury in advance, either through the Estimate or in the form of a departmental minute. Advice on how to obtain this approval should be sought from the Chief Executive.

Any gifts given should also be entered in the Register. They need to be accounted for correctly as well.

Donations

Donations to the SSRO or a member or staff member, for example a fee for a speech or a presentation, should not be accepted. It should be requested they are donated to a charity or other cause instead. It would be a conflict of interest to accept a donation when performing a duty or role on behalf of the SSRO. Any queries on the subject of donations should be raised with the Chief Executive.

3. Hospitality

Members and staff should not encourage business contacts to provide hospitality to them, or indirectly to other colleagues, friends or relatives.

Offers of hospitality should be reported to the Chief Executive. Some examples of hospitality which should be refused are payments for lunch or dinner, and tickets to sporting or leisure events.

In the following circumstances, it may be considered appropriate to accept a working lunch, dinner or attendance at an annual stakeholder event, where it is:

• not lavish in nature;
• not a frequent occurrence; and
• there is no suspicion of a conflict of interest.

Such hospitality must be recorded in the Register. The details required in that form must be completed as fully as possible.

Providing hospitality (working lunches, refreshments etc.)

It is permissible to provide hospitality in the form of refreshments or working lunches for meetings with external partners such as industry and the MOD, suppliers or customers. However it should be noted that alcohol should never be provided as part of a working lunch.

In the vast majority of situations it is not considered appropriate to provide refreshments or working lunches at the SSRO expense for internal meetings. However, where the provision of such can be demonstrated in terms of value for money in the pursuance of SSRO objectives then this is permissible. You must consider the following factors in making your decision for each individual event:

• The scheduled length and formality of the meeting. It may be considered disruptive for meetings such as project boards scheduled to run for 2 or more hours, where no refreshment or working lunch was provided, to be interrupted for attendees to make their own refreshments.
• The number of attendees. Where the cost of a making tea for a number of attendees would exceed the cost of ordering from catering providers.
• The journey to and from a meeting by attendees. Where there is a long journey involved the provision of such refreshments or working lunches will facilitate a productive meeting.

4. Additional catering

Generally the conduct of the SSRO should not require catering additional to that prescribed above. It is essential always to err on the side of caution in this area, and seek the Chief Executive’s permission.

Members or staff may on occasions be expected to offer more than a working lunch for official visitors. Catering must be modest, and special arrangements are acceptable only where business cannot be advanced by any other suitable means, or where failure to offer would cause offence or embarrassment. All catering should always be clearly in the public interest, and demonstrate furthering our objectives, as a benefit to the public service.

In these circumstances it would be appropriate to provide modest additional catering such as a restaurant dinner from the SSRO budget. At such an occasion, it would be improper to invite other members of staff at public expense (unless they were fulfilling an essential support function).

It should be noted that under the subsistence policy the SSRO will not meet the costs of any alcoholic drinks. Costs should be kept to a minimum and itemised receipts must be provided.

Catering for SSRO teams

Generally it is not acceptable for managers to take their team out for lunch or evening activity at SSRO expense. Exceptional cases may be considered for team building away days. Applications for funding at such a team-building event should be sought from the Chief Executive in advance of the event.

Appendix 1 – Gifts and Hospitality Register template

Gifts received

Date	Member/staff	Gift from	Description	Value	Accepted/declined

Gifts provided

Date	Recipient	Description	Value

Hospitality received

Date	Member/staff	Invite from	Occasion	Accepted/declined

Hospitality provided

Date	Recipient	Location	Value