Hospitality PolicyPublished: 04 September 2023
Freedom of information class: About Registers of Scotland
Purpose and scope
This policy sets out RoS stance on whether hospitality can be accepted or offered.
This policy applies to all colleagues.
This policy covers accepting hospitality and gifts, alcohol consumption and purchase, and providing hospitality.
Hospitality and gifts
Developing and maintaining effective working relationships with customers and stakeholders is essential to our ability to deliver our corporate objectives. This may on occasions require RoS staff to offer or be offered hospitality. Hospitality is part of the normal conduct of both public and private business. However, it must be remembered that as civil servants it is essential that we display high standards in matters of propriety, impartiality, and appropriateness.
Accepting or providing hospitality or gifts either in person or virtually that are inappropriate would breach the required standards of conduct and could be punishable under Bribery.
It is not possible to list conclusively what is an appropriate gift or level of hospitality so you should seek guidance/approval from your line manager if you are in any doubt.
A record of all hospitality is monitored by RoS Secretariat on an ongoing basis and by EMT quarterly. You are responsible for ensuring that all hospitality whether it is accepted or declined is recorded with as much detail as possible and submitted well in advance of the event on the hospitality form (link). This official record forms part of the annual review of hospitality and gifts received, declined, and reviewed by our audit committee. The contents of the hospitality register can be requested under Freedom of Information.
Attendance at an event such as a formal lunch or dinner may be difficult to justify and invitations to these types of events must be approved in writing, in advance by your line manager and a hospitality form completed on RoSnet (link). If you decline the hospitality this form should also be completed.
Invitations involving entertainment e.g., theatre or sporting events, are not acceptable. Where it is likely that more than one representative from RoS has been invited to an event, RoS secretariat in discussion with EMT will recommend who should represent RoS. Again, if accepting or declining this hospitality a form must be completed.
Working lunches or other meals provided as an alternative to claiming subsistence allowances is acceptable and is not considered hospitality, providing it is a reasonable means of doing an effective job or promoting the interests of RoS. Meals provided as part of a conference or seminar where the organisers provide meals as part of a package are also not considered as hospitality.
Alcohol consumption and purchase
When permission is given to attend an event, you must remember that you are representing RoS and the civil service. This requires that you keep the consumption of alcohol to a minimum and alcohol should not be consumed at lunchtime. This is in line with our alcohol policy and the expectation of civil servants in general.
Under the agreement to hold a GPC card, alcohol and hospitality should not be purchased unless prior approval is given by a member of EMT. If there is a need to purchase alcohol (as goods rather than part of hospitality) then prior approval should also be sought from Procurement well in advance of the event. Whichever payment method is used for hospitality, the offering hospitality form must be completed and submitted to ensure appropriate records are kept of who has received hospitality from RoS.
Members of staff required to book venues for hospitality should avoid those perceived or designated as luxury or 5-star, except in carefully considered extenuating circumstances. Even if these venues offer competitive rates, there is rarely the opportunity to demonstrate this before reputational damage is done.
The provision of hospitality must be appropriate to the occasion and to an organisation within the civil service. There are special circumstances where alcohol may be offered as part of the hospitality, either externally or served on our premises e.g., special events to mark important milestones / achievements or were RoS is hosting an out of hours event. At such events the quantity of alcohol supplied must be appropriate for the numbers attending and soft drinks must also be available.
For example, for dinner no more than half a bottle of wine should be purchased per person. Apart from official receptions, it is unlikely that permission will be given to fund the provision of hospitality for RoS staff as this is rarely appropriate. Any such event must have the prior approval of a member of EMT. (This does not include catering for meetings.)
Inexpensive, token, or promotional gifts may be accepted by employees, providing they have no commercial resale value. This is likely to include promotional items containing a corporate brand or logo such as water bottles, phone stands and laptop bags etc. Any item that potentially has a commercial resale value should be considered as a gift and should be formally considered and
recorded. You should report an offer of any gift or benefit to your line manager, who will decide whether it can be accepted or declined. In either case, an entry must be recorded using the form below, and submitted to HR.
For gifts, the normal response will be to refuse or return them. However, it may be appropriate to accept the gift when to refuse would be discourteous or damaging to business relations. This is particularly relevant to gifts from overseas visitors where refusal may cause offence.
If it is decided to accept the gift, your line manager should decide whether it should be:
- retained by you
- used or disposed of by RoS.
In all cases where a decision is taken to accept the gift, HR should be informed so that receipt of the gift can be recorded. You will also need to tell the Inland Revenue when you are allowed to keep a gift worth more than £100 as you may be liable for tax on it.
|26 January 2022
|Suitable for publication