Gifts and Hospitality Policy 68108

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GIFTS AND HOSPITALITY POLICY

Policy Statement The following outlines the ODA’s overall approach to gifts and hospitality. Allemployees should read it carefully, and any questions should be directed to your HRManager.

It is imperative that the acceptance of gifts and hospitality by ODA employees canstand up to public scrutiny. As a rule of thumb, gifts should be declined whereverpossible, and any offers should be reported to your line manager. Where it would beungracious or otherwise difficult not to accept, you should inform your line managerof the gift, the estimated value and the donor. You must take personal responsibilityto ensure that a record is placed in the hospitality register of the ODA which is keptby the Head of Legal. Similarly, care should be taken that no extravagance isinvolved with working lunches and other social occasions.

ODA staff should not receive benefits of any kind from a third party which mightreasonably be seen to compromise their personal judgement and integrity. ODA’semployees are only permitted to accept and keep token gifts of very low value such

as pens, diaries and small promotional items (but not even these from third partiesinvolved in active tenders).

In the rare circumstances where declining the gift is likely to cause major offence(e.g. gifts from foreign dignitaries or religious leaders), the gift may be accepted andthen donated to Charity.

Where it is impractical to decline or return a perishable gift (or to donate it to acharity) under these circumstances alone and at the absolute discretion of anappropriate Director, the perishable goods may be kept by the ODA, to be openedand shared with employees at a suitable staff gathering (for example at a pre-Christmas party gathering or a lunch time briefing session). Employees are not

permitted to make use of such goods solely for their own use and therefore theraffling or distribution of gifts to staff and their families is not permitted.

The ODA trusts its employees to use their judgement when accepting business mealhospitality from third parties (i.e. that the appropriateness of the meal or thefrequency of such hospitality is ‘reasonable’ and can be ‘justified’). If an employee isin any way uncomfortable with the ‘lavishness’ of the meal hospitality (or the motivesof the third party) the subject should be raised with your line manager. All hospitalityshould be recorded in the Register within five working days of receipt of the offerunless it falls into an excluded category as set out in the Guidelines below.

Where the nature of the meal invitation also includes additional hospitality (such as a

post-meal visit to a club or entertainment venue), all the received hospitality(including the meal) must be recorded in the Register and approval sought from yourline manager.

All gifts offered and declined (or returned) in addition to those accepted and thendonated (or where perishable, shared with staff) must be recorded in a register. Thisrecord is to protect employees by providing a record of which organisations orindividuals are offering gifts to the ODA and where the gift has gone. Please ensureyou record in the Register [by informing the Head of Legal] all details of corporatehospitality received and gifts offered and declined (or accepted and donated tocharity) as soon as possible and ideally within five working days of receipt.

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The detailed guidance and rules that follow and accompanying annexes are ODApolicy. The guidelines and rules are therefore mandatory for all employees (includingsecondees, fixed term contract staff and temporary staff) and cover:

• the receipt by employees (and in certain cases their immediate family) ofbusiness meals, corporate hospitality, gifts, fees as a guest speaker andsponsorship; and

• the provision of corporate hospitality, gifts, guest speaker fees and thesponsoring of events or exhibitions by the ODA.

This policy and the accompanying annexes do not apply to:

• business and travel expenses properly incurred whilst attending events oroccasions sponsored or supported by the ODA;

• hospitality provided to employees who are permitted by the ODA to attendexternally organised courses, conferences, seminars and workshops paid forby the ODA (providing that in all cases such hospitality is open to all or a fairrepresentation of delegates or attendees as part of the attendance fee):

Employees are required to familiarise themselves with this Note and theaccompanying annexes.

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General Guidelines for the Receipt of Corporate Hospitality, Gifts, GuestSpeaker Fees and Sponsorship

A summary of when details should be recorded in the Register of CorporateHospitality Received and Gifts (Annex 3) by employees receiving hospitality or giftsappears in the table below.

Please note that working lunches with colleagues from LOCOG, GLA, LDA, TfL andEnglish Partnerships are not regarded as hospitality for the purposes of this policy.The general rule is that Standard and Premium Corporate Hospitality may only beaccepted by an employee if authorised by an ODA Director in advance. Please notethat special rules apply during tendering.

Receipt of Corporate Hospitality and Gifts Summary Table

Type of hospitality / gift received Record in Annex 3

Register?

Additional comments

Working lunch at a third party'soffice

No

Out of office meal paid by thirdparty

Yes Must be "reasonable"

Standard Corporate Hospitality Yes See Annex 1 examples

Premium Corporate Hospitality(avoid)

Yes See Annex 1 examples

Any / all hospitality valued £50 Yes Director of Financeinformed

Token gifts No Limited items onlyOther gifts (decline or accept anddonate only)

Yes Record all occurrences

Gifts (even if declined) valued £50 Yes Director of Financeinformed

A summary of when details should be recorded in the Register of Speaking Feesreceived (Annex 4) by employees receiving fees appears in the table below:

Receipt of Speaking Fees Summary Table

Received Record in Annex 4Register?

Additionalcomments

Speaking fees (avoid fees if possible) Yes Fees go to the ODA

Gift in lieu of speaking fees (gift rulesapply - see Annex 1)

No Record in Annex 3instead

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Receiving Corporate Hospitality, Gifts, Guest Speaker Fees and SponsorshipIn its first report on Standards in Public Life, the Nolan Committee noted thatalthough corporate hospitality guidance for public servants was implemented viacurrent policy documents, further improvements were recommended, namely acentral or local record of invitations and offers of hospitality accepted should be keptin all departments and agencies. There should be clear rules specifying the circumstances in which staff should seekmanagement advice about the advisability of accepting invitations and offers ofhospitality.

The ODA has adopted these recommendations and the main principles outlined inHM Treasury’s Guidance Note 55: Ethics in Procurement. To ensure consistencyacross the organisation, the accompanying Annex 1 (Guidelines for the Receipt ofCorporate Hospitality, Gifts, Guest Speaker Fees & Sponsorship) providesmandatory guidance on accepting corporate hospitality, gifts and speaker fees;permitted exemptions; and recording procedures (see Annexes and 4) to ensure

compliance with Nolan Committee requirements.

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Providing Corporate Hospitality, Gifts, Guest Speaker Fees and SponsorshipAs a public sector organisation, the ODA operates under tight constraints in its abilityto

• provide gifts and corporate hospitality to third parties;• in its sponsorship of external events or occasions; and;• in its provision of guest speaker fees.

To further ensure consistency across the organisation, the accompanying Annex 2(Guidelines for the Provision of Corporate Hospitality, Gifts, Guest Speaker Fees &

Sponsorship) provides comprehensive guidance on this subject and proceduralinformation on event briefing; evaluation; and recording procedure for gifts given (seeAnnex 5).

Key Principles The general test of caution is one of common sense:

• Would the public question the appropriateness of hospitality or gifts receivedby an ODA employee?

• Would a reasonable person, assessing the hospitality, sponsorship or any giftprovided by the ODA, judge that it was appropriate and represented

reasonable value for money to the public purse?

Best Practice and General Rules Employees are required to adhere to the guidance as set out in this policy and itsannexes and, where directed, to retain a proper record of their activities for justification purposes. Failure to do so may result in disciplinary action.

Corporate hospitality, the sponsorship of events and exhibitions and the distributionof promotional items are permissible as a tool to raise awareness of the ODA’sactivities, subject to the provisions of this policy and its accompanying annexes.Employees and their immediate family are not permitted to receive any form ofhospitality or gifts (including working lunches) from any third party participating in an

active tender for ODA business. If employees discover they (or their immediatefamily) have inadvertently breached this rule, they must notify their Director and the

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Director or the Director of Finance and Corporate Services immediately, who in turnmust seek advice from the Head of Legal.

Subject to the exceptions detailed in Annex 1, employees will be required to recordthe receipt of all corporate hospitality (except business meals); details of giftsdeclined, received and donated; and details of any fees received as a guest speakerat conferences and the like.

The Register of Corporate Hospitality Received and Gifts (Annex 3 to this policy);and the Register of Speaking Fees Received (Annex 4 to this policy); is held by theHead of Legal. The Register of Gifts (Provided) (Annex 5 to this Note) is held by theHead of Legal.

Annex 2 provides examples of hospitality and sponsorship activities that:

• usually will comply with the ODA objectives;• do not comply as they are considered excessive, novel, contentious or are

repercussive proposals

The Annex 2 examples should also be considered when assessing theappropriateness of purchasing and the distribution of promotional items. Providing and Receiving Corporate HospitalityIn choosing to accept or provide corporate hospitality, employees must consider ifattendance at an event is appropriate in the light of our current business and ourrelationships with external organisations and or individuals. If there is any concern asto the propriety or value for money of provision of corporate hospitality, the mattershould be referred to the Head of Governance for a decision. A rule of thumb shouldbe to err on the side of caution. The following rule of thumb should be applied when

considering if the acceptance of corporate hospitality needs to be recorded in theRegister of Corporate Hospitality Received & Gifts. Where the ODA does not directlypay for all or part of the event that is being attended, the details must be recorded inthe Register. There are only limited exceptions to this rule.

All meals, hospitality and gifts, either given or received, will be open to publicscrutiny. If you have any doubts as to the appropriateness of accepting specifichospitality or gifts, you must seek advice from the Head of Governance or theDirector of Finance and Corporate Services.

Providing and Receiving SponsorshipThe Annex 2 guidelines apply to whole or part sponsorship of an event staged by anoutside organisation. As a public sector organisation, the ODA operates under tightconstraints in its ability to provide sponsorship. Annex 1 also provides guidance toemployees on the receipt of sponsorship from other parties. All employees with responsibility for sponsorship are required to adhere to theguidance in this policy and the accompanying Annexes 1 & 2 and to retain a properrecord of their activities for justification purposes. Failure to do so may result indisciplinary action. Provision of sponsorship must be demonstrably linked to theODA’s current business and considered in the light of our relationships with otherpartner organisations. Attention should also be given to the potential for thesponsorship to be considered novel, contentious or repercussive. If there is any

concern as to the propriety of the provision of sponsorship, the matter should bereferred to the Head of Governance for a decision.

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ODA Events - Briefing and EvaluationTo ensure all ODA events are appropriately resourced, branded and collated on acentral database, an Events & Exhibitions Briefing Document should be completed.Similarly, all staff attending ODA sponsored exhibitions and events should completean Events and Exhibitions Report Document to evaluate success and return these tothe Head of PR and Media. Copies of both of these documents may be foundattached to the accompanying Annex 2.

Providing and Receiving GiftsThe Head of Legal holds the Register of Gifts (see accompanying Annex 5). Gifts tothird parties or to ODA employees (or their relatives) are not a normal aspect of ODAexpenditure. However, any gift approved by the ODA will be recorded in thisRegister to ensure compliance with ODPM requirements. With the exception of tokengifts detailed in Annex 1, employees and their families are not permitted to acceptgifts from third parties working for the ODA (or those seeking work from the ODA). External Communication and Implementation

This policy and the accompanying annexes will be placed on the ODA PublicationScheme (Freedom of Information) and open to public inspection. Employees arereminded to ensure that their records are kept up to date as the ODA may berequired to disclose information from the Register of Corporate Hospitality Receivedand Gifts under the Freedom of Information Act provisions or to our SponsorDepartment or auditors without warning.

Human ResourcesMarch 2007

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Annexes

•

Annex 1 – Guests, Speaker Fees and Sponsorship;

• Annex 2 – Guidelines for the Provision of Corporate Hospitality, Gifts,Guest Speaker Fees & Sponsorship;

• Annex 3 – Register of Corporate Hospitality Received and Gifts;

• Annex 4 – Register of Speaking Fees Received;

• Annex 5 – Register of Gifts (Provided)

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Annex 1

Corporate Hospitality, Gifts, Guest Speaker Fees & Sponsorship PolicyThese Guidelines provide best practice policy for employees that receive or areoffered corporate hospitality, gifts, guest speaker fees or sponsorship in connectionwith their duties at the ODA. The Guidelines in this Annex have been prepared in linewith the Nolan Report and HM Treasury guidance. The ODA endorses the mainprinciples outlined in HM Treasury’s Guidance Note 55: Ethics in Procurement.These Guidelines are mandatory for all the ODA employees (including secondeesand fixed term contract staff). This annex does not apply to:

• the provision by the ODA of corporate hospitality, gifts or general sponsorship(see Annex 2 Guidelines for the Provision of Corporate Hospitality, Gifts &Sponsorship of the accompanying Best Practice Note on this subject).

• business and travel expenses properly incurred by employees whilstattending events or occasions sponsored or supported by the ODA (see

Business Expenses in the Employee Handbook in relation to reimbursementof employees costs).

• hospitality provided to employees who are permitted by the ODA to attendexternally organised courses, conferences, seminars and workshops whichare paid for by the ODA providing that in all cases such hospitality is open to:all delegates or attendees as part of the attendance fee; or in the case of verylarge events is open to a fair representation of attendees.

• gifts or incentives provided by recognised business 'frequent traveller' loyaltyschemes and awarded during travel paid for by the ODA.

• vouchers or financial compensation awarded due to delays during travel paidfor by the ODA.

This Annex therefore applies to:• all other events and occasions staged by external organisations and attended

by the ODA employees free of charge or at a discounted rate; and businessmeals, drinks, lectures, workshops and similar networking opportunitiessponsored or paid for by all external third parties (including suppliers andcontractors).

• gifts offered to employees.• payment for speaking engagements.

The Sponsorship section in this Annex applies only to circumstances where the ODA(or individual employees or their relatives) are offered sponsorship opportunities from

other organisations or individuals. Employees are reminded that the General Rulesdetailed in the accompanying Corporate Hospitality, Gifts, Guest Speaker Fees &Sponsorship Best Practice and General Rules section above apply to this Annex. The Register of Corporate Hospitality Received and Gifts The Head of Legal holds a Register of Corporate Hospitality Received & Gifts (theRegister). A sample Register is provided in Annex 3. Details of the holdersresponsible for maintaining the Register are also listed on the 'Checklist' section.Subject to the exceptions listed in these Guidelines, the ODA requires employees torecord in the Register all details of corporate hospitality received and gifts offeredand declined (or accepted and donated to charity) as soon as possible and ideallywithin two working days of receipt.

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The Register record should be passed to an appropriate individual for endorsement(for example the employee's line manager, a Head of Department, or a Director). Theholder of the Register is required to report all corporate hospitality with an estimatedvalue of more than £50 to the Director of Finance. Employees should note that theyare required to periodically self-certify that their personal Register records are up todate. The procedure for complying with this requirement will be notified to employeesannually. Employees failing to self certify when requested, or failing to recordcorporate hospitality received or gifts declined (or accepted and donated to charity)may be subject to the ODA disciplinary procedures. Receiving Corporate Gifts and Hospitality Employees and their families are not permitted to receive any form of gift orhospitality (including working lunches) from any third party participating in an activetender for the ODA’s business. This rule also applies where existing panelconsultants or suppliers are tendering for the ODA business outside their existingpanel or supply contract. Where existing panel consultants are involved in activeinter-panel competitive quotations, employees should use common sense to

determine if accepting a business meal, other forms of hospitality or gift from them islikely, or may be perceived as potentially affecting, the ODA’s impartiality in awardingthe contract. If in doubt, the meal or hospitality should be declined.

The ODA seeks to protect employees from allegations of impropriety by ensuring thatthe acceptance of all forms of corporate hospitality is transparent, approved and,where appropriate, recorded. The main risk of challenge is acknowledged to bewhen employees receive standard or premium forms of corporate hospitality, ratherthan modest business meals provided by third parties. Working Lunches at a Third Party's Office The occasional office-based working lunch provided by a third party to an ODA

employee during a business visit requires no previous approval and need not berecorded in the Register.

Out of Office Business Meals The ODA trusts its employees to use their judgement when accepting business mealhospitality from third parties (i.e. that the appropriateness of the meal or thefrequency of such hospitality is ‘reasonable’ and can be ‘justified’). Although priorapproval to attend a business meal is not required, employees should whereverpossible make their line manager aware of the business meal and should record it inthe Register. This is to protect employees from challenges by others who may not beaware that the meal is deemed to be ‘reasonable’ and ‘justified’. If an employee is inany way uncomfortable with the ‘lavishness’ of the meal hospitality (or the motives of

the third party) the subject should be raised with their Director.

Where the nature of the meal invitation also includes additional hospitality (such as apost-meal visit to a club or entertainment venue), all the received hospitality(including the meal) must be recorded in the Register and approval sought from theDirector.

Standard Corporate Hospitality As mentioned previously, employees are not required to record in the Register detailsof hospitality provided and paid for (or sponsored) by the ODA. Similarly, a Registerrecord is not required for any hospitality provided whilst attending a work-relatedconference, lecture, seminar or similar educational event organised by a third party,but where attendance is paid for by the ODA (providing such hospitality is open to all,or in the case of very large events, is open to a fair representation of attendees).

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An example not requiring recording in the Register would be a delegate-only cocktailparty or dinner during a conference where the ODA has specifically paid fees for anemployee to attend or where the ODA receives a set number of places as part of an'official sponsor' package deal. However, employees must record in the Register allother standard forms of corporate hospitality which are not financially supported bythe ODA, even when the employee is attending the event as an 'official'representative of the ODA. This policy ensures that there is complete transparencyas to what is being accepted from third parties and what is being paid for by theODA. For example, drinks receptions and launch parties promoted by either public orprivate sector organisations will require the details to be recorded by the employee inthe Register. Attending lectures, conferences, seminars or any other similareducational event or function as a guest of a third party and where the ODA is notfinancially supporting the event or paying for delegate places will always requirerecording in the Register. The examples here are not exhaustive and there willalways be grey areas. In all such cases employees should use common sense andwhere necessary err on the side of caution by recording details in the Register if they

are at all unclear if an event is paid for by the ODA.

As a rule of thumb, if the ODA is directly paying for all or part of the event, theemployee is not required to record the details in the Register.

Premium Corporate Hospitality Offers of premium corporate hospitality such as entertainment, participating in orattending sporting events, free trips, accommodation and other travel-relatedhospitality from external third parties, should be avoided.However, it is acknowledged that there are various events sponsored by the propertyand construction industry where attendance will produce good networkingopportunities for the ODA. Wherever possible the ODA will prefer to pay its own way

to attend appropriate events and will nominate relevant employees to attend.Where an invitation to attend such an event is only available from (and will be paid inpart or in full by) a third party, employees should not attend without seeking priorwritten approval from their Director or the Board. The employee will in all cases berequired to record full details of the hospitality in the Register.

Employees should note that the holder of the Register is required to report allcorporate hospitality with an estimated value of more than £50 to the Director ofFinance and Corporate Services (or in the case of that Director, the Chief Executive). Fact-finding or Business Review Visits Involving Contractors or Suppliers Employees are not generally permitted to receive from external third parties any paid

travel, accommodation or general subsistence (except for de minimis travel such astaxi sharing and the like) when conducting fact-finding investigations, businessreview visits or any such similar meeting. Accepting business meals during such avisit is permitted in accordance with the previous guidance in this annex. In rarecircumstances it may be impractical for the ODA to independently arrange travel oraccommodation (for example where the supplier provides on-site accommodation ina remote location). In all cases, prior approval will be required from the Director orthe Director of Finance and Corporate Services or the Chief Executive and detailsmust be recorded in the Register.

Receiving Gifts ODA employees are only permitted to accept and keep the following gifts:

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• token gifts of very low value such as pens, diaries and small promotionalitems (except from third parties involved in active tenders).

• "written off” ODA promotional stock.• modest floral tributes (or similar) approved by the ODA for employees or their

relatives.

Accepting and keeping all other gifts is not generally permitted. In the rarecircumstances where declining the gift is likely to cause major offence (e.g. gifts fromforeign dignitaries or religious leaders), the gift may be accepted and then donated tocharity (with a record noted in the Register). However, special rules apply toperishable gifts and these are listed below.

It is common in a number of industries to distribute alcohol and perishable goodssuch as chocolates and cakes to trading partners as a gesture of good will, especiallybefore Christmas. The ODA policy is that employees should decline or return thesegifts unless to do so would cause major offence. All non-perishable goods that areaccepted must be donated to an appropriate charity. Where it is impractical to decline

or return a perishable gift (or to donate it to a charity) under these circumstancesalone and at the absolute discretion of an appropriate Director, the perishable goodsmay be kept by the ODA, to be opened and shared with employees at a suitable staffgathering (for example at a pre-Christmas party gathering or a lunch time briefingsession). Under no circumstances are employees permitted to make use of suchgoods solely for their own use and therefore the raffling or distribution of gifts to staffand their families is not permitted. It should be noted that all gifts offered anddeclined (or returned) in addition to those accepted and then donated (or whereperishable, shared with staff) must be recorded in the Register. This record is toprotect employees by providing a record of which organisations or individuals areoffering gifts to the ODA and where the gift has gone.

Employees should note that the holder of the Register is required to report all giftsoffered to or accepted by staff (even when declined) with an estimated value of morethan £50 to the Director of Finance and Corporate Services.

Any attempt to undermine the impartiality of employees by the offer of substantialgifts or other inducements should be reported to the Head of Governance or theDirector of Finance and Corporate Services immediately. Donation of surplus items of equipment (e.g. redundant computers to an employeenominated school or registered charity) or the distribution of obsolete (written off)ODA stock to staff (e.g. old logo promotional items) will require the approval of therelevant Director or the Director of Finance and Corporate Services. In each case,the approver will be required to record the details of the beneficiary and the itemsdonated or distributed in the appropriate asset register (or such other recognisedsystem that may be in place to record stock disposal). Fees for Speaking Engagements Offers of fees for speaking engagements are usually discouraged. Fees may only beaccepted on the basis that they are payable to the ODA to cover associated costsand expenses. The ODA prefers to arrange and pay for its own travel,accommodation and subsistence arrangements wherever possible.

The ODA maintains a Register of Speaking Fees Received (Annex 4), held by the

Head of Legal alongside the Register of Corporate Hospitality Received & Gifts.Where the payment for a speaking engagement is a gift of any description, the usual

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rules on accepting gifts apply. However, the details of such a gift in lieu of paymentneed only be recorded in the Register of Corporate Hospitality Received and Gifts. Receiving Sponsorship This section of the Guidelines covers sponsorship offered to ODA employees andtheir families, as well as general sponsorship offered by third parties to support ODAevents. Annex 2 provides guidance for the sponsorship and support of third partyorganised events.

Individuals Receiving Sponsorship Employees and their families are not permitted to receive 'personal' directsponsorship from third parties providing (or tendering for) services, works or suppliesto the ODA. The receipt of indirect sponsorship (for example a construction companyPartner sponsoring a school football team where an employee's child participates) ispermitted, providing the sponsorship has not been brokered in the first place by theODA. It should be noted that the ODA rarely sponsors individual employees or theirfamilies to participate in charity events or sports activities. However, where an ODA

team is participating in an event, any specific requests should be addressed to theHead of PR and Media.

The ODA Receiving Sponsorship or Exhibitor Fees The ODA does not endorse services or products from private sector organisations orcharities unless such endorsement is by way of association. Sole sponsorship by theprivate sector of any ODA event is usually inappropriate and rarely permitted.Offers of sponsorship from more than one private sector organisation; or a request tobuy exhibition space during ODA organised exhibitions or conferences; or a requestfor sole sponsorship by a public body must always be submitted for approval to theHead of PR and Media, who will determine the appropriateness of the sponsor / exhibitor for the event, whilst bearing in mind the aims and objectives of the ODA.

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Annex 2Corporate Hospitality, Gifts, Guest Speaker Fees & Sponsorship Policy

Scope This annex paper sets out best practice policy for all staff who provide corporatehospitality, give gifts or sponsor events and exhibitions on behalf of the ODA. Theguidelines have been prepared in line with ODPM / HM Treasury practice. TheseGuidelines are mandatory for all ODA employees (including secondees, fixed termand contract staff).

This Annex includes all events or occasions organised by the ODA (including thosefor third parties) and those staged by outside organisations for which the ODAprovides part or complete funding. This Annex also covers the sponsorship ofmaterials such as publications and websites and the provision of gifts by the ODA tothird parties and to the ODA staff or their relatives.

This Annex does not cover:• expenses incurred whilst attending events or occasions sponsored or

supported by the ODA (see Business Expenses section in the EmployeeHandbook in relation to reimbursement of staff costs).

• ODA staff receiving corporate hospitality, gifts, sponsorship or payment forspeaking engagements (see Annex 1 Receipt of Corporate Hospitality, Gifts,Guest Speaker Fees & Sponsorship Guidelines).

• the purchase of promotional items of modest value as approved by the Headof PR and Media featuring the ODA logo and distributed at recognised ODAevents.

Employees are reminded that the General Rules detailed in the accompanyingCorporate Hospitality, Gifts, Guest Speaker Fees & Sponsorship Best apply to this

Annex.

Providing corporate hospitality and gifts Corporate hospitality can be provided as a tool to raise awareness of theorganisation’s activities, normally within the following range of objectives:

• To promote the ODA’s work to key partners and stakeholders• To assist in the general marketing of the work of the ODA• To promote a specific site as a development or occupation opportunity• To mark project milestones• To launch a new publication, programme or initiative•

To facilitate community awareness and participation

All such events should be outlined in detail (consistent with information required in anEvents & Exhibitions Briefing Document - sample attached to this Annex). Corporatehospitality events arising during the course of the year should be agreed with thatteam’s Head of Department / Director and approved by the Head of Governance. Appropriateness of Corporate Hospitality and Value for Money All corporate hospitality events should have a demonstrable link to the work of theODA and represent good value for money. Sporting and artistic events unrelated tothe ODA’s areas of operation would not normally be appropriate. A request toparticipate in an unrelated event should always be addressed in the first instance to

the Head of PR and Marketing.

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Corporate hospitality must not be provided for party political activity or events thatconflict with our own objectives or the objectives of our sponsoring department orpartners.

To represent value for money, the investment should not only be in proportion to thevalue of the project or initiative to the organisation (i.e. budget or receipts) but shouldalso be within a reasonable level of expenditure per head. Examples of corporate hospitality provision, which would be considered excessive,are:

• The hosting of sit-down meals for large numbers of guests, where, forexample, the meal is unrelated to an activity such as an ODA conference.

• The purchase of tickets for sporting and artistic events, where these eventsare unrelated to our areas of operation.

• The provision of inappropriate levels of entertainment for a public sectororganisation, e.g. expensive equipment or luxury leisure pursuits.

• The hire of unreasonably expensive venues in relation to market rates,relevant audience and public sector expenditure considerations.

• Payments on behalf of third parties enabling them to attend luxury eventsprovided by third parties.

• Novel, contentious or repercussive proposals (apart from the examples givenabove) could be activities where:

• The expenditure is out of proportion to the ODA’s activities and budgets.• Value for money is not demonstrable via a link to our activities or a

reasonable expectation of increased business or receipts.

• The per head cost exceeds a reasonable value for money threshold inrelation to the nature of the event.

•

Events are related to party political activity, conflict with the ODA’s objectivesor conflict with the objectives of our Sponsor Department or partners.

Corporate Hospitality Briefing and Evaluation To ensure all corporate hospitality events are appropriately planned, resourced,branded and collated on a central database, an Events & Exhibitions BriefingDocument should be completed by the organiser and sent to the Head of PR andMedia. Similarly, all staff attending ODA sponsored exhibitions and events should completean Events and Exhibitions Report Document to evaluate success and send these tothe Head of PR and Media. Copies of both the above mentioned forms are attached

to this Annex. Each department should ensure that their events are given individual cost codes tomonitor actual spend versus projected spend and to allow a full value for moneyassessment to be made of the event. The Provision of Gifts Gifts to third parties or to ODA employees (or their relatives) are not a normal aspectof ODA expenditure. However, where a gift is specifically purchased for a third party(or an employee) these Guidelines will always apply. Any gift with a value of morethan £50 must also be authorised in advance of purchase by the Chief Executive.Every gift (regardless of value) must be recorded in the Register of Gifts (Provided)

and Special Payments to ensure compliance with Sponsor Department guidance(currently a maximum value of £1,000 per gift item and a total delegation of £10,000

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in any financial year). The Register of Gifts (Provided) and Special Payments is heldby the Head of Legal (see Annex 5).

The Head of Governance will be responsible for setting the ODA policy on theprovision of corporate gifts, however, it is up to each budget holder to justify in writingwhy they have approved expenditure to purchase the gift and attach this to Annex 5. Where appropriate, modest floral tributes (or similar) may be presented to staff, theirrelatives or other third party business contacts on behalf of the ODA or the Board toshow the organisation’s appreciation, congratulations or sympathy. Payment forsuch tributes should be authorised by an appropriate Director and charged byaccounting staff through the Petty Cash system to 'Sundries', or such otherprocedure as authorised. For the avoidance of doubt, the purchase of approvedpromotional items of modest value which feature the ODA logo and distributed tovisitors or guests at recognised ODA events are not considered to be gifts withinthese guidelines.

Donation of surplus items of equipment (e.g. redundant computers to an employeenominated school or registered charity) or the distribution of obsolete (written off)ODA stock to staff (e.g. old logo promotional items) will require the approval of therelevant Head of Department / Director or the Director of Finance and CorporateServices. In each case, the approver will be required to record the details of thebeneficiary and the items donated or distributed in the appropriate asset register (orsuch other recognised system that may be in place to record stock disposal). Payment of Speaker Fees The ODA will reimburse reasonable expenses paid to guest speakers attendingconferences and events it organises or supports. The Head of PR and Media mustapprove all payments prior to final agreement with the guest speaker. It is standard

practice in the public sector to engage keynote and guest speakers who provide theirservices free of charge. However from time to time a paid keynote speaker may be justifiable and written permission will be required from the Head of Governancebefore contractual terms are agreed. Sponsorship of Exhibitions and Events Provision of SponsorshipThere must be not only a demonstrable link to our business for the provision ofsponsorship, but also a proper business case and the event should represent goodvalue for money. An expected return on the investment must be specified in eitherqualitative or quantitative terms, i.e. increased awareness by a particular audience oran increased number of enquiries for a particular site or initiative.

Sponsorship of events should be outlined in detail and budgeted as part of thenormal annual corporate Communications Strategy, and the Directorate BusinessPlanning cycles, as approved by the Board. Sponsorship opportunities arising duringthe course of the years should be agreed with that team’s Head of Department / Director and approved by the Head of Governance. Similar rules will apply to thesponsorship of publications and new media opportunities (for example web sites). Appropriateness of Sponsorship and Value for Money Except in exceptional circumstances sponsorship of sporting and artistic eventsunrelated to the ODA areas of operation would not normally be appropriate. On suchoccasions a request to participate should always be addressed in the first instance tothe Head of PR and Media. Value for money and avoidance of novel, contentious orrepercussive proposals should also be major factors in assessing sponsorshipopportunities. The investment in any sponsorship opportunity should be in direct

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relation to the value of the project or initiative to the organisation (i.e. budget, receiptsor overall awareness and profile). All sponsorship proposals for high-profile events and materials (e.g. televised events,magazine special issues, newspaper supplements and websites) should be raisedwith the Head of PR and Media. As with corporate hospitality, no sponsorship shouldbe provided for party political activity or events that conflict with our own objectives orthe objectives of our Sponsor Department or partners. The ODA Receiving Sponsorship or Exhibitor Fees The ODA does not endorse services or products from private sector organisations orcharities unless such endorsement is by way of association (such as where the ODAis a shareholder in a joint venture partnership or other similar delivery vehicle). Solesponsorship by the private sector of any ODA event is usually inappropriate andrarely permitted. Offers of sponsorship from more than one private sector organisation; or a request to

buy exhibition space during ODA organised exhibitions or conferences; or a requestfor sole sponsorship by a public body must always be submitted for approval to theHead of PR and Media, who will determine the appropriateness of the sponsor / exhibitor and the event bearing in mind the aims and objectives of the ODA. Sponsorship Briefing and Evaluation To ensure that all sponsored events are appropriately planned, resourced, brandedand collated on a central database, an Events & Exhibitions Briefing Documentshould be completed by the sponsor and sent to the Head of Press and PR forinclusion on the Corporate Calendar.All staff attending ODA sponsored exhibitions and events should complete an Eventsand Exhibitions Report Document to evaluate success and send these to the Head of

Press and PR.

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Annex 3

Corporate Hospitality, Gifts, Guest Speaker Fees & Sponsorship Policy

Code abbreviations:•

H (hospitality received)• HD (hospitality declined)• GRD (gift received and then donated)• GD (gift declined)

N.B. Holders of this Register are required to report all recorded hospitality or giftswith a value of £50 or higher to the Director of Finance and Corporate Services.

Register of Corporate Hospitality Received & Gifts

Code Datehospitality /giftreceived,declined ordonated

ODAemployee

Name oforganisationand/orindividualoffering orproviding thehospitality orgift. Contactdetails ofcharitiesreceiving adonated gift.

Describe thehospitality orgift and itsmonetaryvalue.

Whereaccepted:reason foracceptanceof gift/ hospitality

Authorisingofficer(Director)

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Annex 4

Corporate Hospitality, Gifts, Guest Speaker Fees & Sponsorship Policy

Register of Speaking Fees Received

Date ofpayment

Name ofemployee

Conferenceor eventorganiser

Details of theconference orevent includingsubject, locationand date

Feespaid

Authorisingofficer(Director)

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Annexe 5REGISTER OF GIFTS (PROVIDED)Sponsor department delegated authority permits the ODA to purchase and providegifts up to a maximum value of £1,000 per gift item and a total gift purchasedelegation of £10,000 in any one financial year.

All gifts provided by (or on behalf of) the ODA must be justified in writing andapproved in advance by the budget holder and recorded in this Register to ensurethe Sponsor Department delegations are not breached.

Any gift or payment with a value of more than £50 must also be authorised inadvance by the Chief Executive. Register of Gifts Provided

Dategiftgiven

Name ofemployeegiving thegift

Name of giftrecipient andtheircompany ororganisation

Describe giftand reasonswhy this isbeing given(attach justificationpaper whereappropriate)

Valueof gift

Dateapprovedby budgetholder

Signatureand name ofgiftauthorisingofficer (thebudgetholder)andthe ChiefExecutive ifover £50