Gifts, hospitality and sponsorship

Giving of gifts and hospitality

This guidance does not prohibit Colleges and Services giving normal and appropriate hospitality to third parties.

The giving of gifts and hospitality is acceptable provided the following requirements are met:

  • it is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits
  • it complies with local law (if given outside the United Kingdom)
  • it is given in the name of the University of Exeter
  • it does not include cash or a cash equivalent (such as gift certificates or vouchers)
  • it is appropriate in the circumstances (for example, in the UK it is customary for small gifts to be given at Christmas time)
  • taking into account the reason for the gift, it is of an appropriate type and value and given at an appropriate time
  • it is proportionate, both in its frequency and scale, to the relationship with the beneficiary, taking account of the nature of their relationship with the University and any hospitality previously given by the beneficiary to representatives of the University
  • it is given openly, not secretly. To meet this requirement, a record of gifts and hospitality given above a above ‘token value’ (ie greater than £20) should be maintained by the College/Service in accordance with regulations issued by the Chief Financial Officer and be available for internal audit
  • appropriate records of expenditure are maintained in accordance with the University’s Financial Regulations and Expense Regulations

Gifts should not be offered to government officials or representatives, or politicians or political parties, without the prior approval (in writing) of the Registrar or the Chief Financial Officer.

It is not acceptable for any employee of the University or other person or organisation acting on behalf of the University to:

  • give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given
  • give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to "facilitate" or expedite a routine procedure

Receiving gifts and hospitality

  • The Code of Conduct requires staff to report to their College Registrar/Director of Professional Service (or other notified manager) any gifts or hospitality offered or accepted which are above ‘token value’ (ie greater than £20).
  • The Code of Conduct also encourages staff to seek advice from their line manager if they are offered or receive gifts or hospitality of higher value; or they receive a succession of small gifts or hospitality within a short period of time; or otherwise have any concern that there is an intention to influence them to change their behaviour or act improperly.

Colleges/Services should therefore ensure that line managers are aware of their responsibilities if they are approached by a member of their team seeking advice about the offer of a gift or hospitality.

In particular, line managers should be able to advise staff on whether, depending on the circumstances, they should:

  • accept and keep the gift or hospitality;
  • accept the gift or hospitality but raffle it among colleagues and donate the money to charity;
  • accept the gift or hospitality but share it with colleagues;
  • politely decline the gift or hospitality; or
  • make clear to the donor that the recipient of the gift or hospitality will not be involved in decision making relating to business relations between the University and the donor.

Colleges/Services should ensure that staff know to whom they should report any gifts or hospitality, where this is required by the Code of Practice.

Colleges/Services must maintain a register of reports of gifts or hospitality offered and/or accepted made by their staff. The registers must comply with any requirements issued by the Chief Financial Officer and be available for internal audit.

It is not acceptable for any employee of the University or other person or organisation acting on behalf of the University to:

  • accept payment from a third party that the individual knows or suspects is offered with the expectation that it will obtain a business advantage for them;
  • accept a gift or hospitality from a third party the individual knows or suspects that it is offered or provided with an expectation that a business advantage will be provided by the University in return;

The University’s procurement standards do not permit the acceptance of gifts and/or hospitality from a prospective supplier during a procurement exercise.

Sponsorship

Where an outside organisation wishes to sponsor or is sought to sponsor an activity of the University, whether by invitation, tender, negotiation or voluntarily, the basic principles concerning acceptance of gifts or hospitality apply. Particular care must be taken when dealing with contractors or potential contractors.

See Bribery Act examples for further guidance on accepting and giving gifts and hospitality.

Return to contents of Prevention of bribery and other improper conduct: Guidance for Colleges and Services