University Gifts and Hospitality Policy

The University’s Policy for Gifts and Hospitality can be found here.

Policies relevant to the application of this Policy include:

• Disclosure and Conflicts of Interest Policy
• Travel and Expenditure Policy (staff access only)
• Counter Fraud and Bribery Policy
• Financial Regulations (staff access only)
• Public Interest Disclosure (“Whistleblowing”) Policy
• Equality and Diversity Policies
• Staff Code of Conduct and Disciplinary Procedures for Staff and Senior Post-Holders (staff access only)

The Gifts and Hospitality Policy does not apply to philanthropic gifts and donations to the University, which are managed via the University’s Philanthropic Gifts and Donations Policy, which is managed by Marketing. 

The offer and acceptance of gifts and hospitality - a normal business courtesy - can be fraught with difficulty, particularly in light of the requirements of the Bribery Act 2010.  Guidance in this area cannot cover all scenarios. Following the key principles outlined in this Policy should assist in making sound decisions.

•  In the course of University activities, staff may offer and receive gifts and hospitality which are reasonable and proportionate to the business being undertaken, and the circumstances in which it is offered and received;
• Care is required to avoid gifts or hospitality being seen as an inducement and to avoid allegations of misconduct and impropriety;
• It is important that the giving or receiving of gifts and hospitality can stand up to internal and public scrutiny;
• Care must be taken in the receipt of a gift or hospitality from an individual organisation that hopes to, or has the potential to, have a business relationship with the University;
• Staff must obtain approval from their Faculty PVC or Service Director before certain gifts and/or hospitality are offered or received (see Approvals section below);
• All spend on gifts and hospitality, even those which do not require approval, is still subject to value for money considerations and the normal approvals required by the Principal Budget Holder for the Faculty or Service;
• Staff have a duty to declare gifts and hospitality offered and received (even if declined) by recording it in the appropriate Gifts and Hospitality Register;
• In circumstances where declining a gift or hospitality may cause offence (e.g. gifts from foreign dignitaries or religious leaders), the gift or hospitality may be accepted but this should be recorded in the appropriate Gifts and Hospitality Register; such gifts would normally be donated to, or raffled in aid of, charitable causes which should also be recorded in the Register. 

The Policy principles apply to all staff, governors and third parties acting on behalf of the University and to all University activities undertaken in the UK or overseas.

Gifts may range from token gifts of little value to a substantial gift of higher value. Typical modest gifts given or received include business branded stationery, flowers, confectionery, new USBs and other promotional items. 

Typical hospitality includes lunches, dinners, accommodation or entertainment, and range from token hospitality of little value such as providing food and drink (e.g. a working lunch) to high value activities such as a ticket and entertainment for a sporting event or concert.

Approvals

Approval is required for any gifts or hospitality:

• intended for a foreign public official (e.g. Government ministers, diplomats, embassy staff and international border officials), irrespective of value and whether provided in the UK or abroad*;
• where the value of the gift or hospitality exceeds £50 (NB: for hospitality purposes, this means £50 per person)

• multiple gifts or hospitality to/from the same third party, whether simultaneously or in close succession,  which exceed a value of £200 within a 12 month period.

 *It is a specific offence under the Bribery Act 2010 to offer an inducement to a foreign public official anywhere in the world so particular care is required when offering gifts and/or hospitality. 

 Retrospective approval should be in exceptional circumstances only.

 The following items should NOT be accepted or offered: 

• Any gifts or hospitality, where it might be perceived that:
  • your integrity or professionalism may be compromised, or ethical standards may be questioned or compromised, and/or that this may bring the University into disrepute (even where doing so is not unlawful)
  • decisions may be influenced as a result of their receipt or offer;
  • they are inconsistent with the University’s values and ethical standards, Northumbria Attributes (including Acting with Integrity) and the Seven Principles of Public Life of selflessness, integrity, objectivity, accountability, openness, honesty, transparency, and leadership;

  • legislation may be contravened, including the Equality Act 2010 or which may reasonably be perceived to contravene the University’s value of inclusivity as set out in the University Strategy 2018-23.

• Any gifts or hospitality given in secret; 

• Avoid offering or receiving gifts and hospitality around key decision milestones (e.g. student admissions, assessment or contract procurement, student awards);

• Gifts of money;

• Gifts of giftcards/vouchers (NB: these are sometimes used for payments to research participants and GEM Awards but are not classed as "gifts" hence this Policy does not apply to them);
• Gifts offered by the University should not exceed £100, as per the Travel and Expenditure Policy;

• Multiple gifts offered, whether simultaneously or in close succession, to/from the same third party which exceed a value of £200 within a 12 month period (NB: these require approval);

• Gifts and hospitality should not be provided for political campaigning purposes as this would breach the University’s charitable obligations;
• Meals, entertainment or accommodation which have no business purpose
• Excessive or lavish hospitality including substantial amounts of alcohol.

From 25th February 2019, the University expects all Northumbria staff and members of the Board of Governors to record all gifts and hospitality given to, or received from, third parties (including those declined) within the University's Gifts & Hospitality eRegister. 

Token or very low value gifts (e.g. estimated at less than £10 in value) do not need to be recorded on the eRegister unless it is perceived as a possible inducement or becomes a regular pattern of giving. 

 The eRegister promotes transparency around exchanges of gifts and hospitality, provides a robust audit trail and could assist individuals defend themselves against allegations of impropriety.  It may be used for reporting and disclosure purposes, including Freedom of Information requests. 

The information that will need to be recorded in the eRegister includes:

• Description and purpose of the gift or hospitality;
• Date Given/Received;
• Value/estimated value;
• The current location (gifts only);
• Name of the third party individual/organisation involved;
• Nature of relationship with the University;
• Whether the third party is a Foreign Public Official (e.g. Government Minister or official, MPs, diplomats, international border crossing guards etc);
• Whether the gift/hospitality was accepted or declined.

If you are unsure whether the gift or hospitality offered to you is a bribe, consider the following factors:

• Might there be a particular intent behind the gift/hospitality?

• Would you feel obliged, now or in the future, to act differently as a result of the gift/hospitality?

• Has the offer been made to others in your party or just one or two individuals?

 A good rule of thumb is to ask yourself if you would feel able to openly admit to accepting such an offer, e.g. to your line manager.

 If it is clear that the gift or hospitality offered to you IS a bribe OR if you are offered a gift or hospitality as a reward for a previous decision that you made in favour of the party offering the gift/hospitality:

•             You should refuse it and tell the person offering it that it is against our policies.

In such circumstances, you should report the incident immediately to your line manager and to the Head of Governance.  Record in the Gifts & Hospitality Register who offered you the bribe, what was offered, what was expected in return and that the offer was declined.

It is important to remain vigilant and report concerns related to suspicious activity.  Since the use of inducements or rewards are common in some countries, it is recognised that some concerns will arise from time to time.  All individuals are encouraged to use the process below to report any suspected fraud, bribery or other corrupt behaviour.

• University staff should report suspicions to their Line Manager and their Principal Budget Holder (i.e. their Faculty PVC or Service Director), who will notify the Finance Director, who will in turn notify the Head of Governance.
• Third parties (e.g. contractor staff) should notify their Line Manager of any concerns and/or the main University contact for the project or contract.  

Concerns should be communicated in writing but may be made orally in exceptional circumstances.  The report should provide details of who offered the bribe, what was offered, what was expected in return and that the offer was declined, including any evidence supporting the concern.

 If, for any reason, reporting via the Line Manager or main University contact is considered inappropriate (e.g. if the concern relates to them) or their response is considered to be unsatisfactory then a report may be made directly to the Head of Governance.  The concern will then be treated under the University’s Public Interest Disclosure (Whistleblowing) Policy.

For advice on the application of this Policy, please contact: 

• Georgina Bailes, Secretary to the Board and Head of Governance