Financial and Commercial Services
ENTERTAINING, HOSPITALITY & GIFTS POLICY
January 2013
Author: Keith Waddingham
Contents
1.
Business Entertaining ........................................................................................................... 2
2.
Working Lunches .................................................................................................................. 3
3.
Externally Sourced Food....................................................................................................... 3
4.
Staff Events & Parties ........................................................................................................... 4
5.
Alcoholic Drinks .................................................................................................................... 5
6.
Reciprocal Hospitality ........................................................................................................... 5
7.
Gifts ...................................................................................................................................... 5
8.
Festive & Celebratory Cards ................................................................................................. 6
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INTRODUCTION
The Bribery Act 2010 received Royal Assent in April 2010 and came into force on the 1st July
2011. The Act makes radical changes to existing UK legislation on bribery and corruption and
the impact will be felt across all UK companies including the Education Sector. The University of
Bradford is committed to ensuring that the organisation adopts a policy and procedures that
introduces a zero tolerance policy towards bribery and corruption, this policy extends to all
employees/ representatives/third parties/ business partners or agents of the University

The University of Bradford is committed to the highest standards of openness,
integrity and accountability. It seeks to conduct its affairs in a responsible manner,
having regard to the principles established by the Committee on Standards in Public
Life. For many organisations gifts and hospitality are part of building relationships and
in some societies they are required behaviour. This policy is designed as an adequate
procedure to prevent expenditure being used as a potential bribe and extends to all
parties within the organisation or dealing with the University. Furthermore, it is illegal
under the provisions of the Act that no payments are made with the intent to
influence a foreign public official with the aim of retaining or obtaining an advantage in
the conduct of business and if they confer an advantage directly or indirectly. The
University is committed to the following values: The University prohibits the offer or
receipt of gifts, hospitality or expenses whenever they could affect or be perceived to
affect the outcome of business transactions and are not reasonable and bona fide.
Good practice permits promotional expenditures where they are transparent, proportionate,
reasonable and bona fide within the confines of this policy.
1. Business Entertaining
1.1 It is recognised that there is a legitimate business need, on occasions, for
representatives of the University to entertain or provide hospitality for key stakeholders,
sponsors, customers, potential customers and or other external persons to the
University.
1.2 The level of this provision is to be clearly identified within the School or Departmental
budget and any expenditure against this budget must be authorised in accordance with
the Financial Regulations of the University.
1.3 It is good practice when entertaining, that the representation from the University should
not be disproportionate to that of those being entertained. This applies, whether
entertaining on the University’s premises or at external venues. For example there
should typically be, at least, an equal ratio of external guests to University employees
unless there is a sound justification for doing otherwise e.g. lunches for Honorary
Graduates and External Examiners. Ideally there should be more external guests than
University employees at any one function or event.
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1.4 Generally purchasing or giving gifts for/to key stakeholders, sponsors, customers,
potential customers or other external persons to the University is not allowed unless the
goods are distributed with the aim of advertising to the general public. Exceptions to this
rule may be;

Visiting VIPs, dignitaries or lecturers who have agreed to waive their normal fee

Visits or occasions where it is customary to exchange gifts
The value of the gift in these instances should not be excessive or more than any
waived fee. For guidance the value should typically not exceed £30
1.5 In all cases of business entertainment the names of the individuals and if applicable,
their organisations should be recorded onto either the Catering booking form, an
expense claim form EXPUK or EXPFOR or the relevant invoice. These will be retained
by Finance for any subsequent internal or external audit of the expenditure.
2. Working Lunches
The University hospitality policy does not allow for “working lunches” unless
2.1 The “working lunch” is part of business entertaining, where there are external visitors
and there is not disproportionate representation from the University.
2.2 The “working lunch” is taken whilst travelling on University business.
2.3 The “working lunch” is for an internal meeting where there is a valid justification to
support it. For example: when requested attendees are unavailable to attend the
meeting at any other time, these types of meetings should be infrequent and non
regular.
The requester of hospitality will need to indicate their justification for such on the Catering
booking Form C1. Failure to give a valid justification may in the event of an Inland Revenue
audit give rise to a benefit in kind charge to any individuals concerned.
NOTE: To align with Inland Revenue guidelines, access to “working lunches” cannot be
determined by the status or role of an employee.
3. Externally Sourced Food
3.1 The University does not recommend its employees purchase food themselves, from
external sources for consumption within business meetings, unless they can clearly
demonstrate that they (the employee) have conformed to the current Health & Safety
and Food Hygiene regulations.
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IMPORTANT NOTE: Non-conformance of these legal requirements, in certain
circumstances, where an outbreak of food poisoning has occurred, can lead to
prosecution of the individual (employee), where either a fine and or custodial sentence
could be applied.
3.2 If the University’s Catering Contractor is unable to provide hospitality and external
Caterers are to be engaged to provide food and service for specific functions and or
meetings they must be reputable and also hold the necessary relevant certifications and
or licences.
3.3 The University and or appointed Catering Contractor can not take any responsibility for
any food that is sourced externally and brought onto the University’s premises for
consumption. This also includes the provision of resources, such as assistance for
service and or the use of any light or heavy catering equipment.
4. Staff Events, Parties and Gifts
4.1 Food and non alcoholic drinks may be provided at events and presentations to celebrate
work related activities and achievements. Such events are subject to approval by the
Dean or Head of Department, in accordance with the Financial Regulations of the
University.
4.2 University hospitality cannot be used to pay for Staff parties or private functions. These
will need to be paid for by the individuals concerned. The University will allow the use of
its premises and facilities for such functions, subject to prior consent and approval being
given by the relevant Heads of Departments.
4.3 The University Catering Contractor will provide food and services at preferential rates for
individual staff members, to private functions as and when required. The University can
not accept any liability or responsibility whenever such arrangements are made.
4.4 The University would prefer that its Catering Contractor is used for private functions but
if external Caterers are to be engaged, the individual will need to carry out their own
necessary due diligence. The University and its Catering Contractor can not accept
liability or responsibility whenever an external caterer is used and as under condition 3.3
can not provide the use of certain resources or equipment.
4.5 University hospitality cannot be used to pay for gifts to staff this includes festive,
birthday, leaving, and anniversary gifts or flowers for individuals who fall ill. It is normal
practice for this to be provided by private collections from concerned staff. One
exception to this rule is gifts provided under the long service award scheme.
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5. Alcoholic Drinks
5.1 The University does not recommend that alcoholic drinks are provided for consumption,
either at business meetings or at private functions. For business meetings this is at the
discretion of the Dean / Head of Department. If alcohol is to be provided to a private
function, then prior notification of such should be given when seeking consent and
approval for the event.
5.2 Providing alcoholic drinks when taking VIPs, guests and hosts for meals is acceptable.
IMPORTANT NOTE: It is imperative to remember that when alcohol is provided to meetings
and or events that we have a duty of care to both our staff and external visitors who may then
return to their work place. Also careful consideration should be made as to how our staff and
external visitors will make their homeward journey.
6. Reciprocal Hospitality
6.1 University staff and lay members may accept meals or equivalent hospitality only in the
course of business. Offers of hospitality, which may unduly influence, or be deemed by
others to unduly influence, the actions of an individual in favour of the provider of the
hospitality, or which are on scale significantly greater than the University would provide
in return, should be refused.
6.2 All offers of hospitality over £30 should be reported in writing to the Financial
Compliance & Risk Accountant in Finance where a register of such offers will be kept
and reported to the Audit Committee on an ad-hoc basis for reasons of transparency.
IMPORTANT NOTE: Where business trips are being sponsored by 3rd parties for academic
activities, such as delivering lectures, research papers, speeches; these need not be reported
but must be authorised in accordance with the Financial Regulations of the University.
7. Gifts from third parties
7.1 University staff and lay members should generally decline all offers of gifts, other than
those of a very small intrinsic value or on occasions where it is customary to exchange
gifts with a host.
7.2 Gifts of money must always be refused.
7.3 All offers of gifts with a value of greater than £25 should be reported in writing to the
Financial Compliance & Risk Accountant in Finance where a register of such offers will
be kept and reported to the Audit Committee on an ad-hoc basis for reasons of
transparency.
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8. Festive & Celebratory Cards
8.1 Corporate Communications will design and source a University branded Festive &
Celebratory card and electronic e-card for sending to external contacts and
organisations. The cost of printing is to be borne by the requester.
8.2 It is not permitted to send the University branded Festive & Celebratory card or
electronic e-card to fellow colleagues, Schools or Departments of the University. The
exception to this being the Chair of Council and the Vice-Chancellor.
ADDITIONAL GUIDANCE
If you require any additional information or guidance in relation to the contents of this policy and your
responsibilities please contact The Financial Compliance and Risk Accountant – Mr Keith Waddingham, e-mail
k.waddingham@bradford.ac.uk telephone 01274 233132 in the absence of the Responsible Officer, Mrs Angela
Dobrucki Head of Finance 01274 233131 a.m.dobruki@bradford.ac.uk, is authorised to act as an alternate.
This policy should be read in association with the following University finance policies:

Financial Regulations

Code of Practice on Serious Financial Misconduct and Irregularities

Anti Money Laundering Policy

Public Interest Disclosure Policy(Whistleblowing)

Purchasing Policy
These policies can be found on the University’s website at:
www.brad.ac.uk/finance/financial-information/fin-regs-policies-procedures-and-guidelines/
The University and its management are committed to a zero tolerance policy and will not accept any forms of
bribery or corruption taking place within its organisation or representatives/third parties/ business partners or
agents of the University.
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