The Bribery Act 2010 has implications for the giving and receiving of gifts, advantages or hospitality. In the course of working for the Cornwall Federation of Women’s Institutes (CFWI) or in the role of Trustee, gifts, advantages or hospitality by those with whom contact is established because of positions or roles with CFWI may be offered. Such benefits come in various forms; they may be in the form of money, goods, free passages, or even hospitality outside individual roles with CFWI. It is the personal responsibility of employees and Trustees to guard against potential, actual or perceived conflicts of interest from anyone which might reasonably be seen to compromise personal judgment or integrity or that of CFWI. If gifts or hospitalities of any nature are offered the following should be considered:
- Is acceptance of the offer solely for the benefit of the recipient?
- Is the donor and the reason for providing known?
- Is this a justifiable use of employee/Trustee time (Hospitality)?
- Will acceptance be in the CFWI’s interest?
- Will acceptance help the recipient/CFWI do business better?
- Is the offer significant or does it look overly generous?
- Is accepting from one source more often than might be seen as reasonable?
- Would acceptance of the gifts/hospitality meet the objects of the WI?
Unless they are of an insignificant value/perishable nature or would cause serious offence, or acceptance has been approved by line management for employees at CFWI or by the Board for employees such offers should be declined.
Under circumstances that make it impossible to refuse, it is important to explain to the donor that acceptance is on behalf of CFWI and not in any personal capacity. This makes it clear to the donor, and anyone else, that the recipient will not gain any personal advantage.
Gifts may be retained for personal use if the value of the item is below £10.00. If a recipient wishes to retain the gift for personal use, they may do so by paying the difference between £10.00 and the estimated valuation price.
The gift may be retained for official purposes by CFWI. This is a suitable option where items
best be retained for display or representational use (e.g. china, silverware, decorative items, paintings, local artefacts). Display and use of such items demonstrates that they are treated with appropriate respect.
If any gift is not purchased or retained for CFWI use, they should be sold or auctioned and the proceeds benefitting CFWI.
Hospitality falls into two categories; hospitality in a representative capacity in pursuit of WI objects and in an official capacity to promote the WI agenda. Examples of hospitality include attendance at breakfasts/lunches/dinners, receptions or events.
It is impossible to anticipate all situations which may arise, but the most common forms of advantage include free travel, invitations to sporting events or other various forms of entertainment. The same considerations for refusal or acceptance of gifts and hospitalities apply and all offers must be recorded in the register.
RECORDING OF GIFTS OR HOSPITALITIES
All offers of gifts or hospitalities must be recorded in the Gifts and Hospitalities Register whether accepted or declined.