GIFTS AND HOSPITALITY POLICY
Background
Staff within UK Anti-Doping should conduct themselves with honesty and impartiality in the exercise
of their duties. As a result, they should not receive benefits from a third party that might be seen to
compromise their personal judgement or integrity, and which might give rise to the impression that
he or she has been influenced by a gift to show bias for or against any person or organisation while
carrying out official duties. UK Anti-Doping is committed to complying with the Bribery Act 2010, and
this policy should be read in conjunction with the Anti-Bribery Policy (QAP08-25)
The Bribery Act 2010 repealed previous corruption legislation and has introduced the offences of
offering and / or receiving a bribe. It also places specific responsibility on organisations to have in
place sufficient and adequate procedures to prevent bribery and corruption taking place. Under the
act, bribery is defined as “Inducement for an action which is illegal unethical or a breach of trust.
Inducements can take the form of gifts loans, fees rewards or other privileges.” Corruption is broadly
defined as the offering of the acceptance of inducements, gifts or favours, payments or benefit in
kind which may influence the improper action of any person; corruption does not always result in a
loss. The corrupt person may not benefit directly from their deeds; however, they may be
unreasonably using their position to give some advantage to another. To demonstrate that UK AntiDoping has in place sufficient and adequate procedures and to demonstrate openness and
transparency, all staff are required to comply with this Gifts and Hospitality Policy. For a more detailed
explanation, please see the Anti-Bribery Policy (QAP08-25). Should members of staff wish to report
any concerns or allegations they should contact the appropriate person identified within the
Whistleblowing Policy.
Gifts
The general principal is that all gifts should be refused or returned with a carefully worded covering
letter, especially where a contractor relationship is involved or is being contemplated.
Occasional seasonal or modest gifts, such as calendars, pens, diaries, etc, may be accepted. All
consumable gifts (such as chocolates, wine etc) must be passed over to the Director of Business
Support. These gifts, provided they are modest, will be shared across the staff group. If the gift is not
modest in nature then the Director of Business Support will return it to the donor.
Trade or discount cards, through which a member of UK Anti-Doping staff might personally benefit
from reduced prices, are classified as gifts and cannot be accepted.
Where the refusal or return of a gift is likely to offend or embarrass the donor, and dependent on the
nature, value and origin of the gift, discretion may be exercised as to the handling and retention of
the gift. Guidance should be sought from the Director of Business Support or Chief Executive, to
whom the acceptance of any such gift should be reported.
All gifts whether received or declined (what ever their value) should be recorded in the Gifts,
hospitality and entertaining register (QAP 08-18).
Hospitality
In determining whether or not is it proper to accept hospitality offered, each individual case should be
considered on its merits. Consideration will include the following:

Nature of the hospitality: For example, approval is generally not required for a working
lunch which is regarded as acceptable practice, whilst a more formal lunch or dinner by
prior invitation should be approved by the Chief Executive.

Acceptance to invitations to events should be approved in advance by the Chief
Executive or Director.
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
Could the offer and/ or acceptance of the hospitality be construd to be a form of bribery
(whether that is the case or not). Particular care should be taken with receipt of
hospitality from key suppliers, especially if we are in contract negogiation with them or
going through a tender process.

Representation: Care should be taken to ensure that UK Anti-Doping is not overrepresented when invited to formal events.

The obligation which acceptance might appear to place on an officer in terms of
reciprocal hospitality, business dealings, etc.
Where refusal of an invitation or offer of hospitality may cause embarrassment or appear
discourteous, prior guidance should be sought from the Chief Executive.
Corporate entertaining
UK Anti-Doping permits modest corporate entertainment provided that it is:•
•
•
for the purpose of establishing or maintaining good business relationships;
to improve the image and reputation of UK Anti-Doping; or
to present UK Anti-Doping’s services effectively;
provided that it is:
•
•
arranged in good faith, and
not offered, promised or accepted to secure an advantage for UK Anti-Doping or any of its
employees or associated persons or to influence the impartiality of the recipient.
UK Anti-Doping will authorise only reasonable, appropriate and proportionate entertainment
expenditure. This principle applies to employees and associated persons, whether based in the UK or
overseas.
All corporate entertaining should be approved in advance by the relevant Director or Chief Executive.
Employees are required to set out in writing:
•
•
•
•
the objective of the proposed client entertainment or expenditure;
the identity of those who will be attending;
the organisation that they represent; and
details and rationale of the proposed activity.
UK Anti-Doping will approve business entertainment proposals only if they demonstrate a clear
business objective and are appropriate for the nature of the business relationship. UK Anti-Doping
will not approve business entertainment where it considers that a conflict of interest may arise or
where it could be perceived that undue influence or a particular business benefit was being sought
(for example, prior to a tendering exercise).
Gifts, hospitality and entertaining Register
The designated person responsible for keeping the Register of Gifts and Hospitality is the Business
Support Administrative Officer with the Quality and Risk Manager having overall control. This will
cover all invitations and offers of hospitality extended to staff within UK Anti-Doping and the board.
All gifts, hospitality received and client entertainment provided should be recorded. Working lunches
should be included to ensure that they do not become a regular occurrence. The provision or receipt
of refreshments (e.g tea, coffee, biscuits) in the normal course of business would not need to be
recorded.
This register shall be reviewed on a quarterly basis by the Chief Executive and Director of Business
Support. Such a review will be documented.
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Guidelines for offers of Hospitality
The overleaf table provides guidance in dealing with the approval and records required for the
acceptance of offers of hospitality.
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Hospitality Occasion
Modest conventional
Hospitality (Working Lunch)
More formal Lunch or Dinner
by prior invitation
Commemorative or similar
occasion organised by
contractor, consultant or
Supplier e.g. to celebrate an
anniversary, handover or
opening
Trade promotion on
company’s premises with
meals or drinks.
Prior Approval?
Further Action?
No
Record in Gifts and Hospitality
Register
Yes, from Director or Chief
Executive
Prior approval required from
Director or Chief Executive if
occasion takes the form of a
formal lunch or dinner by prior
invitation; otherwise no
approval required
Prior approval required from
Director or Chief Executive
Record in Gifts & Hospitality
Register, Check level of
representation
Record in Gifts and Hospitality
Register
Record in Gifts and Hospitality
Register. Check level of
representation.
Annual dinner of Professional
Institute or Association:
a)
b)
where officer is a
guest of the
Institute/Association
where officer is the
guest of a
consultant,
contractor or
supplier
Cultural or sporting event as a
guest.
Overseas visit to inspect
manufacturers’ products.
QAP08-24 Gifts and Hospitality Policy
Record in Gifts and Hospitality
Register
No
Record in Gifts and Hospitality
Register
Prior approval required from
Director or Chief Executive
Prior approval required from
Director or Chief Executive.
Not to be accepted.
Not protectively marked
Record in Gifts and Hospitality
Register
Not required.
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Expenditure on Gifts, hospitality and client entertaining
The expenditure of taxpayers’ money on official hospitality is a sensitive matter which can lead to
public criticism, and care must therefore be taken to avoid exposing the individual or UK Anti-Doping
to allegations of impropriety or extravagance.
Expenditure on official hospitality should only be incurred where it can be shown to be in direct
support of UK Anti-Doping’s business. The scale of hospitality should be appropriate to the needs of
the UK Anti-Doping and the status of the guests.
Managers should always consider the justification for any hospitality to be offered and should
exercise economy in incurring expenditure for this purpose.
Authority for approving expenditure on refreshments for committees, meetings, etc may be delegated
as appropriate to the budget holder.
Guidelines:
a)
b)
Hospitality offered to visitors outside UK Anti-Doping

UK Anti-Doping will normally meet expenditure for the provision of lunch/dinner to visitors (or
to other public sector bodies) or for a working lunch where a benefit will accrue to UK AntiDoping or where such an UK Anti-Doping liaison allows for the conduct of urgent business. In
such circumstances, expenditure may be authorised within the following guidelines:

Approval should not be granted when only UK Anti-Doping staff are in attendance. In cases
where UK Anti-Doping staff out-number external visitors, then prior approval should be sought
from a Director or Chief Executive.

The number of people invited should be kept to a minimum.

Any hotels or restaurants used should be appropriate to the purpose, and UK Anti-Doping
resources should be used where possible.

Any meal should be on a modest scale.

Where no service charge is included, a tip of 10% is considered reasonable.

No spouses or guests of UK Anti-Doping staff are eligible to receive official hospitality other
than in exceptional circumstances and with the specific agreement of the Chief Executive
Officer.

Except where such hospitality constitutes UK Anti-Doping business, funds are not available
for visits to theatres or other forms of public entertainment.
Working lunches and refreshment for official committees and other ad hoc meetings:

The provision of lunch at public expense will be acceptable only where it is impossible to
accommodate urgent meetings other than at lunch time and:

There is a need to make provision for non-UK Anti-Doping guests;

It is necessary for participants to remain together during lunch; or

Pressure of work is likely to be such as to make it impractical to allow a break long enough to
give participants reasonable time to obtain lunch elsewhere.

The nature of the lunch should be appropriate to the purpose, with costs kept to a minimum.
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
c)
If morning or afternoon breaks are warranted, light refreshments (tea, coffee, bottled water,
biscuits) may be provided; approval of this may be delegated to the budget holder.
Hospitality offered during training courses, conferences, workshops, etc

Residential (i.e. where at least one night’s accommodation is being provided and paid for as
an integral part of the course):

The cost of meals and light refreshments (bottled water, biscuits etc) may be met.

Expensive hotels should be avoided.

The total cost of food and refreshment per person should be appropriate to the purpose and
costs should be kept to a minimum.
Non-residential:

Depending on the duration of the course/event, hospitality should be restricted to the
provision of morning and afternoon tea/coffee/bottled water with biscuits/scones. The
provision of snacks or a buffet-style lunch will be at the discretion of the relevant Senior
Manager. Where lunch and light refreshments are available, subsistence expenses will not be
payable.

UK Anti-Doping premises should be considered as a first choice of venue and expensive
hotels should be avoided.
Expenditure on official Gifts:
Expenditure on Gifts can only be authorised by the Chief Executive.
Transparency
As part of UK Anti-Doping’s commitment to transparency and anti-bribery we will publish our gift,
hospitality and entertaining register (for all entries over a value of £50) on our website on a quarterly
basis.
Related Documents
QAP 09-22 Financial Procedures
QAP 08-18 Gifts, hospitality and entertaining Register
Process 14.13 Declaring a Gift
Approval and review
Author:
Approver:
Approval Date:
Review Date:
Paul Evans
Andy Parkinson
November 2011
December 2012
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