Corporate Governance Framework
Gifts and hospitality
43. It is an important part of our work to develop contacts and build good working relations with a range of outside organisations, for example, relevant trade associations and with individual licence holders. You are encouraged to develop such contacts appropriately. In doing so, however, you are expected to observe exceptionally high standards of personal honesty and integrity. Failure to comply with the Commission’s policies on the acceptance of gifts and hospitality will be regarded as a serious matter and may amount to gross misconduct. In particular, you should make yourself aware of the provisions of the Bribery Act 2010 (opens in new tab) and ensure that your actions do not place you and/or the Commission in a position where you and/or the Commission could be accused of being in breach of the provisions of that Act.
44. No gift or hospitality should be accepted if it would, or might, appear to place you under any obligation, or compromise your impartiality, or be otherwise improper. Subsequent payment for, or reciprocity of, any hospitality does not legitimise its unauthorised receipt. Prevailing practice in the private sector is not a justification for a breach of the standards required in the public sector.
45. Employees should not, therefore, accept any gifts however modest, or hospitality from actual or prospective licensees, or from current contractors or those seeking to become contractors. The only exception is light refreshments at a meeting, for example tea or coffee. Care must also be taken over acceptance of hospitality from trade associations and representative bodies.
46. If you have any doubts about the proper course of action to take when giving or receiving hospitality, it is your responsibility to discuss the issue with your manager in the first instance, or the Head of Finance.
Receipt of gifts or cash
47. Generally the offer of any gift, reward or benefit arising out of your duties as an employee of the Commission should be politely refused with the explanation that public servants are not permitted to accept such offers. Where refusal would clearly be impractical, or cause offence to the donor (for example a representative of a foreign government or similar) you should let the donor know that the gift is being accepted on behalf of the Commission for retention in the office. Such gifts must be handed into the Commission for office use or subsequent disposal.
48. Any gifts received should be returned with a polite letter of explanation. Where return of gifts would be expensive or otherwise difficult, the donor should be told that the gift cannot be accepted but will be donated to charity in their name.
49. These principles do not apply to isolated gifts, for example office accessories at a conference, or from a visitor which are worth less than £10, and which may be accepted for use at work.
50. Details of any gift you have accepted (including those with a value of less than £10) must be notified immediately to the Head of Finance on the standard Hospitality declaration form. A public register of gifts and hospitality will be maintained by the Head of Finance showing all notified gifts and hospitality accepted with a value greater than £10. Unsolicited gifts passed on to charity with the donor’s knowledge should also be notified to the Head of Finance.
51. Employees should not accept cash or other form of monetary payment under any circumstances from actual or prospective licensees, or from current contractors, or those seeking to become contractors. The only exception to this is the collection of fees which are received by the Finance team as part of their accounts receivable duties.
Receipt of hospitality
52. An element of modest hospitality plays an important part in the maintenance of a wide range of important business contacts and the acceptance of appropriate levels of hospitality is acceptable. It is essential, however, that you exercise careful judgment in deciding whether the acceptance of hospitality in particular circumstances is appropriate. In doing so, you should consider whether the offer and/or its acceptance would be normal and reasonable in the circumstances. If you have any doubt as to appropriateness, you should decline any offer of hospitality.
53. With the exception of modest hospitality invitations (with an estimated value of £10 or less) acceptance of hospitality invitations should first be cleared by a Director or Programme Director. As noted in paragraph 50, hospitality, even if modest, must not be accepted from actual or prospective licensees or from current contractors or those seeking to become contractors. Any working lunches, for example during a corporate inspection must be paid for. To ensure transparency in the Commission’s affairs, all hospitality received must be recorded in the Commission’s hospitality register. Any hospitality you have accepted (including that with a value of less than £10) must be notified immediately to the Head of Finance on the standard form Hospitality declaration form. The only exception is tea/coffee/soft drinks accepted in the course of a working visit.
Offer of hospitality by Gambling Commission employees
54. Senior employees at Director/Programme Director level may, occasionally, offer hospitality in line with the specific hospitality limits set out in the Commission’s expenses rules. These limits will only be varied by prior written agreement from a Director or the Chief Executive as appropriate. Without such prior agreement no reimbursement will normally be made.Previous section
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Last updated: 27 February 2023
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