Gift Policy

We would like to clarify the position on ordering and receiving gifts for staff. We have clarified this because of the position with HMRC and so that individuals do not have to incur additional tax burdens via P11D’s.

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This policy sets out the procedure for gift purchases and the events it will cover.

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GIFTS FROM SUPPLIERS

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All offers of gifts and hospitality, regardless of value, must be declared and authorised by Directors whether accepted or declined. Offers of gifts and hospitality may include items ranging from diaries, wall charts, and boxes of chocolates, days out or hospitality, food or drinks.

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It is your responsibility to ensure that you are not placed in a position that risks, or appears to risk, compromising your role or Wilson Vales statutory duties under the bribery act. You should not be seen to be securing valuable gifts and hospitality by virtue of your job. You should not accept or provide any gift or hospitality if acceptance/provision will give the impression that you have been influenced/are deemed to be influencing while acting in an ‘official capacity’.

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This Policy also applies to spouses, partners or other associates if it can be argued or perceived that the gift or hospitality is in fact for the benefit of the individual.

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Directors may decide that the following may happen with gifts:

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• Share the gift with all staff

• Raffle the gift for charity

• Donate the gift to charity

• Make a donation to charity and keep the gift

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ACCEPTING OFFERS OF HOSPITALITY – GENUINE BUSINESS REASONS

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Hospitality offered should only be accepted where there is a direct link to working arrangements and a genuine business reason can be demonstrated.

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It is recognised that, in the course of carrying out your duties, you will need on occasion to ensure good relationships with existing and future contractors and stakeholders and that this may involve for example, the receipt of modest working lunches and dinners. These are acceptable where there is a genuine business reason.

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Hospitality invitations to events which are purely social events should be considered very carefully before accepting; in such circumstances it may be much more difficult to substantiate a genuine business reason. Authorisation from a Director will be necessary before attending an event.