3.1.1 The offer or provision of gifts and hospitality by University staff or associated persons shall only occur when the purpose is:
(a) to promote the values and reputation of the University for academic, professional or charitable purposes; or
(b) to aid the establishment and maintenance of academic, collaborative, professional or business relationships with partners and supporters of the University; or
(c) to provide a small token of thanks to University staff, associates or supporters for their contribution to the work of the University;
and, in every case, when all of the following criteria apply:
(d) the purpose is not to influence individual recipients or bodies improperly, nor solely to provide personal entertainment;
(e) the gift or hospitality offered is appropriate and the value is reasonable and proportionate to the circumstances; and;
(f) provision is in accord with all applicable University policies, governmental legislation and, to the extent it can be reasonably determined, the rules and policies of the recipient organization.
3.1.2 Gifts and hospitality shall always be offered and provided openly, without any degree of secrecy attached.
3.1.3 University staff and associated persons are expressly prohibited from personally offering or providing any gifts or hospitality:
(a) of money or of a monetary nature;
(b) to induce an individual or organization improperly to provide particular services or preferential treatment;
(c) in expectation of or reward for an individual or body not performing their work in a proper or impartial manner; and/or
(d) to any individual or organization responsible for a formal application, tendering or procurement process immediately prior to or during that process.
3.1.4 Charitable and philanthropic gifts or donations made by or on behalf of the University must conform with the principles set out above but are subject to separate procedures, as defined in section 3.3 of Financial Regulations.
3.1.5 The University does not make political donations. University staff and associated persons are expressly forbidden to provide any donation or gift to political parties or foundations on behalf of the University or in association with their work for the University.
3.2.1 Gifts and hospitality that are in complete accord with the standards set out above may be authorized for offer and provision as follows where the approver also has the necessary budgetary authority to permit expenditure:
(a) Gifts or hospitality up to £100 total value.
(b) Gifts or hospitality up to £500 total value.
(c) Gifts or hospitality up to £1,000 total value.
Head of Department
(d) Gifts or hospitality exceeding £1,000 total value.
Head of Division
Note – when applied to situations outside the UK these value thresholds should be considered in terms of equivalent sterling value.
3.2.2 Gifts and hospitality in excess of £1,000 must also be reported to the Registrar who will notify the Chair of Audit and Scrutiny Committee; the Chair may at his or her discretion report the gift to the Audit and Scrutiny Committee itself.
3.2.3 Gifts and hospitality offered to public officials must be treated with particular care to ensure compliance with anti-bribery legislation. For this reason, all gifts and hospitality offered to public officials exceeding £50 total value may only be authorized by the Head of Department or higher.
3.2.4 There is no exemption in principle in respect of the offer of promotional gifts or hospitality (for example, branded items, items or events provided as part of a marketing or sales campaign) – these must conform with the standards set out above, although practically the majority of items are unlikely to exceed £50.
3.3 Gifts and hospitality offered to staff
3.3.1 The provision of gifts and hospitality by the University to its own staff and associated persons is covered by this policy but is also subject to the processes set out in the University Expenses and Benefits Guide.
3.3.2 In particular, gifts or hospitality must not be provided to any University staff or associated persons if there is any possibility that they might influence, or appear to influence, that individual improperly.
3.4.1 Subject to the exceptions set out at (c) below, a formal record must be kept of gifts and hospitality provided where:
(a) any single gift or act of hospitality is offered to an individual, group or organization (whether as private individuals or in an official capacity) with a value exceeding (or estimated to exceed) £100 total; or
(b) any series of gifts or hospitality not otherwise recorded is offered to the same individual, group or organization and the cumulative total value exceeds (or is estimated to exceed) £100 in any rolling 12-month period.
Exceptions – the following are not required to be recorded:
(c) any gift or act of hospitality up to an actual or estimated value of £250 that is directly connected with teaching or research where:
(i) what is offered is reasonable and proportionate to the circumstances; and
(ii) there is clearly no intention, or appearance, of undue influence being exerted upon the recipient(s); and
(iii) the offer is not, or cannot be construed as, anti-competitive; and
(iv) the offer does not create any conflict of interest;
3.4.2 A template Gifts & Hospitality register is provided for departments to record all required details, which must be done within 28 days of the provision concerned. Departments are expected to keep the content of the Register under constant review and will be requested to forward copies of the records made annually to the Registrar, or a nominated delegate. Records must be maintained in a complete, up-to-date, and accurate manner. The information may be published at the discretion of the University, requested for review by Internal Audit, or made available under the provisions of the Freedom of Information Act.