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Policy statement

The purpose of giving or receiving gifts and hospitality in a commercial setting is to foster good working relationships. This policy clarifies when gifts and hospitality may be offered or accepted and the record-keeping requirements.

Who does this policy apply to?

This policy applies to all full and part-time employees , as well as temporary staff. It also applies to agents and other third parties acting on our behalf.

What types of gift/hospitality are never acceptable

Certain gift and/or hospitality should never be given or accepted such as :

  • Gifts and hospitality that have been requested by our clients or other third parties
  • Cash or cash equivalents (such as gift cards or gift vouchers)
  • Anything that is illegal, unsavoury or sexual in nature
  • Anything that is received on the basis of a quid pro quo (i.e. on the basis that it is conditional upon receiving something in return)
  • Anything that might give rise to a perception or suspicion that the recipient has been unduly influenced
  • Gifts or hospitality which are lavish or extravagant
  • Gifts or hospitality offered during a tender or bid process, to or from any party involved
  • Gifts or hospitality which is recurring, regular and/or could be part of a reciprocal arrangement.

What do we mean by “gifts” and “hospitality”

A “gift” is any item of value provided or offered for the personal benefit of the recipient or a close contact (family, friend or colleague) at no cost, or a cost that is less than its commercial value. Gifts can also include offers of employment to family members.

“Hospitality” is any offer of travel, accommodation, food, drink or an invitation to any event (e.g. concert, sporting event, either as a spectator or participant) in the company of a third party (including a client), which the recipient has received, or has themselves offered, as a result of their or their business’s employment by GEESYS. If a representative of the third party is not present at an event as the host, tickets for the event will be regarded as a gift and will be subject to the gifts value threshold and procedure stated below.

This policy does not apply to private gifts or hospitality between GEESYS employees, e.g. at Christmas or birthdays. That is at the discretion of the employees concerned.

What can we accept

Remember that the acceptance of any gift or hospitality requires careful judgement at all times. For employees involved in procurement, contract negotiation, tender/bid submission or those involved in the payment approval process, all gifts and hospitality (no matter how small) must be disclosed on a G&H Received Form and are subject to the approvals noted below.

Reporting and authorisation procedures

G&H Received and Given forms should be used to report appropriate gifts and hospitality offered or received. These forms shall be reviewed by management at regular intervals.

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