Corporate Governance Framework
Gifts and hospitality
57. We encourage Commissioners to build an understanding of the sector. This includes developing contacts with a range of organisations, for example consumer groups, trade bodies, operators and investors. In doing so, you should maintain high standards of honesty and integrity.
58. Key to this is compliance with rules on the acceptance of gifts and hospitality. As well as complying with the requirements of this Code of Conduct, you should also be aware of the provisions of the Bribery Act 20106 and ensure that your actions do not place you or the Commission at risk of any accusation that the law has been breached. If you are in any doubt about this, you should contact the Governance Team in the first instance.
59. To avoid any suggestion of impropriety, Commissioners must not accept any gifts, however modest, unless there are political (for example, dealing with a foreign government) or cultural reasons where refusal would be regarded as offensive. If you accept a gift for this reason, you should advise the Governance Team. Any such gifts remain the property of the Commission, not of individual Commissioners.
60. These requirements do not apply to low-value, practical items which are given out freely, such as bags, pens or stationery items provided as part of attendance at a conference.
61. A common sense approach should be taken to offers of hospitality. In a number of settings, such as routine meetings, establishing new contacts, or undertaking wider stakeholder engagement, acceptance of hospitality would not be problematic. For example, lunch or light refreshments, where these are incidental to engagement with stakeholders.
62. The questions you should consider are whether acceptance of hospitality creates, or could be perceived to create, an obligation, and whether a reasonable person might think that your acceptance of hospitality could influence your judgement in relation to a regulatory or other decision. It could be unwise, for example, to accept hospitality from prospective contractors or suppliers to the Commission. You are not permitted to accept hospitality that might generally be regarded as unduly lavish, such as preferential access to cultural or sporting events.
63. If you have any doubts about issues around giving or receiving hospitality, you should speak with the Governance Team in the first instance. No gift or hospitality should be accepted if it would place you under any obligation, or compromise you in any way, or if it might appear to do so. To be clear, a subsequent offer to pay for any such gift or hospitality does not put right the situation if you should not have accepted in the first place. Whether or not your actions would be acceptable in another sector is not a material factor.
64. It is your personal responsibility to ensure that a record is paced in the gifts and hospitality register of the Commission to list any gifts or hospitality received, usually by asking a member of the Governance Team to do so.
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Last updated: 27 February 2023
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