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Reviewed September 2006 

NORTHERN IRELAND GUARDIAN AD LITEM AGENCY

POLICY ON PROVISION OF HOSPITALITY/GIFTS

1. INTRODUCTION AND PURPOSE

1.1 In the interests of promoting acceptable standards of propriety and consistent


practice throughout the Agency, the purpose of this policy is to give clear
guidance on the provision of hospitality. It clearly defines when and to whom it
can be extended, the type and scale of hospitality allowed and the procedures to
be followed when authorising hospitality.

1.2 For the purposes of this policy the management team made up of the Executive
Director, Assistant Directors, Quality Assurance and Training Manager and
Business Manager are known as authorising officers and they are reminded of
their accountability for hospitality extended under their authority.

2. DEFINITION OF HOSPITALITY

2. 1 Hospitality refers to refreshments and entertainment of any type provided out of


public funds to anyone, be they a public servant/official, representative of a
public/private body or organisation, or a private individual. Convenience
hospitality, such as working lunches, should pose no problem, especially if there
is some official means of reciprocity and provided this is limited to isolated
occasions and its acceptance is in the interests of the Agency.

Hospitality which is not acceptable would include invitations to more expensive


social functions, where there is no direct link to official business, such as sporting
events, theatre etc. particularly those which involve travel, hotel or other
subsistence expenses. For further clarification in relation to this, please refer to
the below table. Occasionally acceptance of meals or tickets to sporting or social
events may be accepted if attendance is in the Agency’s interests. However the
individual and their Line Manager must demonstrate same.
Reviewed September 2006 
Offers of Hospitality Checklist 

Type of gift/hospitality  Approval required 

1.   Modest conventional hospitality  No 
(eg working lunch). 

2.   More formal lunch or dinner,  by  Prior approval required from Executive Director. 


prior invitation. 
3.   Hospitality for a team  Prior approval required from Executive Director. 
4.  Commemorative  or  similar  Prior approval required from Executive Director. 
occasion  organised  by 
contractor,  consultant  or 
supplier  (eg  to  celebrate  an 
anniversary,  opening  or 
handover. 
5.   Trade promotion on company’s  Prior approval required from Executive Director. 
premises with meals or drinks. 
6.   Annual dinner of Professional  Prior approval required from Executive Director. 
Institute or Association:
· where the officer is a guest 
of  the  Institution  or 
Association
· where the officer is a guest 
of  a  particular  consultant, 
contractor or supplier. 

7.  Overseas  visits  to  inspect  Prior approval required from Executive Director. 


manufacturers’ 
products/premises. 

Form A1: Gifts and Hospitality Approval Form and Gift and Hospitality Register must be completed 
on all occasions. 

Examples where hospitality may not be accepted (not a prescriptive list) 

*Leisure Events  * Complimentary Tickets 

*Sporting Events  *Weekend breaks or holidays, whether paid for or not. 

(very occasional acceptance of meals or tickets may be accepted ­ see paragraph 2.21) 

3. JUSTIFICATION FOR HOSPITALITY AND RECIPIENTS

3. 1 A fundamental consideration governing the justification for expenditure by the


agency at public expense is that on every occasion the hospitality extended
should be in the direct interest of the Agency.
Reviewed September 2006 

4. SCALE OF HOSPITALITY

4.1 Official entertainment should be, and should be seen to be, unostentatious and
on a modest scale. It should not provoke adverse public comments about
“wining and dining at the taxpayers' expense”, or about public servants
benefiting from arrangements that exist primarily for the purpose of extending
hospitality to others.

4.2 When choosing venues for meals the more expensive and luxurious hotels and
restaurants should be avoided unless there are compelling reasons such as the
availability of particular facilities.

4.3 Where practicable, functions should take the form of lunch rather than dinner.

4.4 Where entertainment involves a meal in a hotel, a fixed price menu should
normally be agreed in advance. If no service charge were included in the bill a
tip of up to 10% would be reasonable.

4.5 Where the entertainment takes the form of an evening meal the cost of drinks,
including aperitifs and wines should not exceed one third of the cost of the meal.
With the exception of tea/coffee, beverages should not normally be provided
with lunches.

5. RECIPIENTS OF HOSPITALITY

5.1 Hospitality, including working meals, should only be extended to officials or


public servants where officials form a minor and necessary proportion of the total
guests. Normally public servants should not number more than 2 to 3 guests,
and should not normally exceed the number of visitors.

5.2 The same guests should not be offered hospitality on an automatically recurrent
or regular basis, or solely as a return gesture.

6. PERMISSIBILITY OF SPECIFIC CLASSES OF HOSPITALITY

6. 1 Internal and External Meetings

6.11 Although the general principle is that hospitality should only be offered to non­
public sector guests, or where public sector guests are in the minority, there is
some flexibility regarding expenses incurred by senior officers for refreshments
at meetings to which departmental colleagues, representatives from other
Reviewed September 2006
departments or persons outside the civil service are called for conference.

6.1.2 The extension of hospitality in these circumstances is permissible provided


refreshments are limited to tea/coffee and biscuits/scones and that the persons
present do not work under the direct control of the Chairman and are from a
different cost centre to the Chairman. Hospitality should not be extended at
internal agency meetings without the prior authorisation of a member of the
agency management team.

6.2 Training Courses / Away Days / Seminars / Conferences

6.2.1 Residential

It is normal practice for meals and light refreshments to be provided to delegates.


Beverages are permissible with evening meals up to one third of the total cost of
the meal.

6.2.2 Non­residential

Light lunch may be provided where it facilitates the running of the course or
where alternative provision is not available. Written approval must be sought in
advance. Unless part of a fixed price package, beverages (with the exception of
tea/coffee) should not normally be provided with lunches.

6.3 Hospitality involving meals or venues outside the agency

6.3.1 Prior approval should be sought from a Member of the Management Team
regarding:

Ø the appropriateness of extending hospitality;


Ø the type of hospitality proposed;
Ø the scale and cost of hospitality proposed;
Ø the guest list; and
Ø the venue.

6.4 Situations not specifically covered by Policy

6.4.1 It is recognised that there may be cases when, in the interests of the Agency,
flexibility in interpretation of the strict policy rules may be necessary.

6.4.2 However, approval for such situations must be obtained from a member of the
management team.
Reviewed September 2006

6.4.3 In addition to the normal information required at Paragraph 6.4.2, the request for
approval should clearly detail the following:

Ø why the request falls outside the boundaries of what is normally allowable;
Ø why it is considered necessary to provide such hospitality;
Ø how it will directly benefit the department; and
Ø the expected consequences of the request being refused.

7. AUTHORISING PAYMENT OF HOSPITALITY

7. 1 Authorisation procedures for payment of hospitality where the venue is outside


the agency and/or the refreshments are supplied by outside caterers are the
same as those for all others types of good and services as detailed in the agency
authorisation for supplies and services policy. A copy of which can be obtained
from the Business Manager

7.2 Where a price has been negotiated in advance there should be no variation
between the approved and actual cost. Where it has not been possible to
negotiate a fixed price and the actual cost varies by more than 10% or £30 from
the approved estimate (whichever is the lower), an explanation of the variation
should be forwarded to the Executive Director.

7.4 In each case the Personal Assistant responsible for Petty Cash should ensure that
the expenditure was properly approved and that the hospitality extended falls
within the terms approved.

7.5 The Personal Assistant responsible for Petty Cash should ensure that each Petty
Voucher is filled out appropriately detailing the amount spent, the date, who
attended the meeting and what it was for. The signatures of the person receiving
the money to make payment and the authorising officer (PA) should be recorded.
The receipt should also be stapled to the Voucher.

7.6 The Petty Cash Recoupment sheet should be completed by the Personal Assistant
responsible for Petty Cash when the balance is approximately £30. The
recoupment form should include a list of all expenditure within the detailed
timespan, amounts, dates, account codes and all attached vouchers. The total
amount spent and the balance in the petty cash box should be inserted in the
appropriate areas of the form. The form should then be signed and dated by an
Authorising Officer.

7.7 Officers who can approve hospitality at the relevant levels is detailed below:
Reviewed September 2006

Level Approved by
Chairman Executive Director
Executive Director Chairman
Board Members Chairman
Management Team Executive Director
Guardians ad Litem Assistant Directors
Administration Business Manager

8. RESPONSIBILITY OF APPROVING AND AUTHORISING OFFICERS

8.1 Approving officers are reminded of their responsibility for ensuring adherence to
the guidelines.

8.2 It is important that the Executive Director has a defence against charges that the
level of hospitality is excessive or that the Agency's staff are being entertained at
the taxpayers expense. Where there is doubt about any particular event,
approving officers should seek advice or err on the side of caution and reject the
request.

8.3 Officers authorising payments are reminded of their responsibility to ensure that
the hospitality extended was properly approved.

9. DOCUMENTATION

9. 1 The purchase and payment for hospitality bought from outside must be
approved, authorised and documented in the same manner as the purchase of
any type of good or service.

9.2 In particular this documentation must include:

Ø Written request for permission to extend hospitality and for the type and scale of
hospitality proposed;

Ø Complete guests list, detailing employing organisations and, if not immediately


apparent, reasons for invitation;

Ø Written approval for the type and scale and estimated cost of hospitality
proposed, and for the guest list;

Ø If appropriate, evidence of having followed GPA guidelines and of having


sought the best "deal",
Reviewed September 2006 
Ø Receipts / invoices detailing separately the purchase of:
· food
· drink
· any other type of entertainment.

9.4 Copies of all documentation should be held in the appropriate branches available
for audit inspection.

10. HOSPITALITY AND SUBSISTENCE CLAIMS

10. 1 Staff should be reminded that they should not claim day subsistence allowance
where lunch was provided at a function.

11. CLASSIFICATION AND IDENTIFICATION OF HOSPITALITY


EXPENDITURE

11.1 All expenditure on hospitality should be clearly identified as such and charged to
the expense code for hospitality (89/19). It is not permissible to obscure the
purpose of expenditure on hospitality by subsuming such expenditure within
other expense codes. A hospitality budget is available.

Policy on Acceptance of Gifts

12. GUIDANCE ON THE ACCEPTANCE OF GIFTS

12.1 The NIGALA recognises that recipients of our service, may, on occasion, offer
gifts and hospitality to staff. This guidance sets out the principles governing the
acceptance of gifts and hospitality, reminding staff of their responsibility to
exercise judgement regarding offers of gifts and hospitality. The staff of
NIGALA should conduct themselves with honesty and impartiality in the
exercise of their duties and therefore should never receive benefits of any kind
from a third party which may compromise their personal judgement. The main
principle of this guidance is that no member of staff should do anything which
may give rise to the impression that they have been influenced by a gift or
hospitality to show bias towards any person or organisation while carrying out
work duties.
Reviewed September 2006
12.2 The NIGALA will maintain a Gift and Hospitality Register, which will prevent
any possible accusations or suspicions of breach of the guidance. The Register
shall be subject to FOI enquiries and staff should bear this in mind when
deciding on the acceptance of gifts or hospitality.

12.3 It is the Assistant Director’s responsibility to ensure all staff are aware of this
guidance and that registers are in place and maintained at all times.

13. ACCEPTANCE OF GIFTS

13.1 The general rule is that all gifts, invitations or hospitality offers should be
refused. However, seasonal or promotional gifts, such as calendars, pens etc,
which bear company names and have a value of less than £50, may be accepted
by staff members and do not require to be reported or approved. Acceptance of
any other gifts must be approved by senior management in advance and must be
recorded by the staff member, on the Gift and Hospitality Register.

13.2 More expensive gifts, with a value of £50 or more, cannot, in any circumstances,
be accepted. All gifts, of £50 or more must be recorded on the Gift and
Hospitality Register, even if they are declined and returned.

14. TRADE, LOYALTY OR DISCOUNT CARDS

14.1 Trade, loyalty or discount cards, by which a staff member may benfit from the
purchase of goods at a reduced price are considered gifts, and should be refused
and returned to the sender.

14.2 Flyer cards which are used by airlines can be used by staff to avail of special
departure lounges, priority bookings and check­in. Staff must not make personal
use of any flights or air miles which derive from flights paid for by the Agency.

15. STAFF INVOLVED IN THE PROCUREMENT OR MONITORING OF A


CONTRACT

15.1 With the exception of trivial promotional or seasonal gifts, no gifts or hospitality
of any kind should be accepted from anyone involved in the procurement or
monitoring of a contract.
Reviewed September 2006 
16. GIFTS RECEIVED IN RECOGNITION OF WORK DONE

16.1 If gifts, by way of gratuities for lectures or similar work are offered, then
acceptance should be based on how much of the prepatory work for the event
was done in the own staff member’s time, how much in work time and the extent
to which Agency resources, with the exception of Agency laptops, were used in
the preparation.

16.2 The following principles should also be adhered to:

a) If the work was carried out in the individuals own time and the event took
place outside normal working hours, with no expense incurred to the
Agency, it would be acceptable for the individual to accept the
token/gift/fee.

b) If the preparation was done in Agency time, with use of Agency resources,
no gifts or fees should be accepted unless the event is carried out outside
of normal working hours, when a gift up to the value of £50 is acceptable.

c) If the preparation was carried out and the lecture was delivered in the
own individuals time, but Agency facilities were used for typing,
preparing handouts etc. then a gift to the value of not more than £75 is
acceptable.

16.3 In either of the above scenarios, the Agency can, if they so wish, charge the
organisation a fee based on the salary of the individual and/or use of resources.
If a series of gifts from the same source exceed the values outlined above, the
same rules apply.

17. REPORTING GIFTS AND APPROVAL PROCESESS TO BE


FOLLOWED

17.1 If gifts (with the exception of trivial gifts, for which approval is not required) are
received, the approval of the Assistant Director’s should be sought using the
below form. In the case of gifts offered to Assistant Directors, the approval of the
Executive Director should be sought and similarly if gifts are offered to the
Executive Director, this must be discussed by the Board before acceptance. If the
recipient has or intends to reject the gift, details must be sent to their Line
Manager to be recorded on the Gift and Hospitality Register.

(Part 1 to be completed by recipient – part 2 overleaf to be completed by approving officer)
Reviewed September 2006 

GIFT/HOSPITALITY FORM A1 (Part 1) 
(AUTHORISATION/OFFER ACCEPTED/OFFER DECLINED) 

Name of recipient: 

Name of ultimate recipient  if not as 
above (ie if gift or hospitality passed 
on to someone else): 
Date of offer: 

Who made the offer: 

Description of offer: 

Why was the offer made: 

Estimated/actual value of offer: 

State whether offer was declined: 
Is  there  a current/potential  contract 
with  the  donor?    If  yes  provide 
details: 

Signature of recipient:  Signed: 
Date: 

PART 2 TO BE COMPLETED BY THE APPROVING OFFICER 

GIFT/HOSPITALITY FORM A1 (Part 2) 
(AUTHORISATION/OFFER ACCEPTED/OFFER DECLINED) 

Reasons  why  approval 


has/has not been granted: 

Is gift being returned?  If so, a 
letter  should  be  issued 
(template  at  Annex  B  to  be 
used) 
Has  the  gift  been  used  or 
disposed  of?  If  so  give 
details: 

Has  the  gift  been  donated  to 


a nominated charity?
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Has  the  Gifts  and  Hospitality 
register been updated? 

Signature  of  Approving  Signed: 


Officer:  Date: 

NB: FORM NOT VALID UNLESS BOTH PARTS 1 AND 2 HAVE BEEN COMPLETED

17.2 The Approving Officer (Line Manager) must decide in writing whether to:

§ Allow the recipient to accept the gift

§ Return the gift to the sender with a covering letter providing explanation as to
why the gift cannot be accepted. A template for this letter is shown below.

§ Use or dispose of it, if possible, in or by the Agency

§ Donate the gift to a nominated Charity.

17.3 The Approving Officer will ensure that the details of the case are recorded on the
Gift and Hospitality Register.
Reviewed September 2006 

Template for Return of Offer of Gift/Hospitality 

(The content of this template should be tailored to suit each circumstance) 

Contact name                                     Name of Business 
Name of company                               Manager/Head of Division: 
Address of company                           Office Address 

Date 

Dear 

The  Northern  Ireland  Civil  Service  operates  a  Gift  and  Hospitality  Policy  to  ensure  high 
standards of propriety in the conduct of its business. 

On account of public confidence, perception is as important as reality and because of this I 
am obliged to return your offer of INSERT: Name of gift / hospitality. 

This is not in any way meant to offend or to imply that your [gift/hospitality] was offered in 
anything  but  the  utmost good faith, but  is  designed to  protect  both  individual members  of 
staff  and  the  Northern  Ireland  Civil  Service.    I  hope  you  will  accept  our  response  in  that 
spirit and that we can look forward to continued effective working relationships. 

Yours …………

18. AWARDS OR PRIZES

18.1 Staff should consult their Line Manager if they are offered a prize or award in
connection with their official duties. They will normally be allowed to keep it
provided:

§ There is no risk of public criticism

§ It is offered strictly in accordance with personal achievement

It is not in the nature of a gift, nor can be construed as a gift, inducement or


payment.