Gifts & Hospitality Standards

3. Key Control Requirements

3.1 Gifts and Hospitality Reporting

Control Objective: Ensures that the Bank has a record of all material Gifts (over £10) and Hospitality (over £25) that are accepted by Colleagues while on duty.

Rationale: All instances of G&H received/offered, subject to thresholds, must be approved and reported to Risk and Compliance who will maintain the Bank’s central register.

Control Activities:

1. The Bank must establish and maintain a Gifts and Hospitality register.
2. All Colleagues must record the receiving, declining and offering of Gifts and Hospitality in accordance with the procedures and limits set out in these Standards.
3. All Colleagues must conform to all relevant legal requirements and the Bank’s system of internal controls relating to Anti-Bribery and Corruption.
4. All expenses incurred on behalf of the Bank, including expenses associated with dealing with third party intermediaries, governments, or public officials (e.g., gifts, entertainment, hospitality (legitimately incurred travel/hotel expenses, etc.), must be properly documented and accurately recorded in accordance with the Bank’s Gifts and Hospitality Standards and Travel and Expenses Policy and Delegated Financial Authority.

3.1.1 The Principles of Propriety

The guiding principles governing the acceptance of Gifts and Hospitality are:

• You are responsible for your decisions on the acceptance of Gifts or Hospitality and for ensuring that any Gifts or Hospitality accepted can stand up to public scrutiny and do not bring the Bank into disrepute;
• Your conduct should not create suspicion of a conflict between your Bank duty and your private interest;
• You should not put yourself in a position where you could be influenced by a Gift or Hospitality;
• If in doubt about whether you should accept a Gift or offer of Hospitality, you should refuse it.

These principles are not intended to stop you accepting occasional trivial Gifts or working lunches. However, an offer of a more substantial Gift or Hospitality should not be lightly accepted. You should consult your line manager or the Risk and Compliance team if you are unsure whether or not to accept a Gift or offer of Hospitality.

3.1.2 Gifts

It is the responsibility of the recipient of the Gift to provide a best estimate of its value. It is acknowledged that in some cases, it will be difficult to determine the value of a Gift, however you should provide a “best guess” (an internet search for the item may also help to determine its approximate/average value).

If the value is between is between £10 - £100 you may, with the agreement of your Senior Leadership Team (SLT) member, keep the Gift or share it among Colleagues. If the estimated value is greater than £100 you must seek authorisation from your SLT member and the Chief Risk Officer (CRO) or delegate. The CRO or delegate will discuss with your SLT member whether it should be surrendered to the Bank. 

All Gifts with a value of £10 or more must be declared using the Gifts and Hospitality portal.

Gifts may be displayed in the office with the consent of your SLT member. If a Gift is displayed in the office, the Risk and Compliance team will record the Gift and its location in the Gifts and Hospitality Register. The same rules apply to Gifts received from foreign governments, government organisations or international organisations.

The table below provides a summary of the approval levels required, based upon the value of the Gift:

* for ExCo/SLT member’s submissions the approver will be the CEO; for CEO submissions the approver will be the CRO

3.1.3 Deciding whether to accept a Gift

If you decide that it would not be proper to accept a Gift, reward or benefit, you should politely refuse it. If refusing will cause misunderstanding or offence to the donor, you should consider accepting the offer or Gift. If you are in any doubt, you must discuss the matter with your line manager or the Risk and Compliance team.

If you decline the offer of a Gift with a value above £10 you must still declare this, using the Gifts and Hospitality Portal.

3.1.4 If you accept the Gift

Any Gift with a value of £10 or more must be registered with the Risk and Compliance team using the Gifts & Hospitality portal.

If you and your line manager decide that the right course of action is to accept a Gift, you must consider what should then be done with it. If the Gift is from a commercial organisation, you should consider the implications particularly carefully.

If you do not wish to keep a Gift (but it was inappropriate to refuse it) you may share it among Colleagues or raffle it off and donate the money to Charity.

3.1.5 Offering Gifts to Counterparties

You are not expected to offer Gifts as part of your duties for the Bank. Any offer or presentation of Gifts (including tickets to events) to Counterparties must be declared using the Gifts and Hospitality portal and specifically approved by the CRO or delegate.

3.1.6 Hospitality

Colleagues must not solicit Hospitality and must not accept Hospitality that might be seen to compromise personal judgement or integrity.

It is acknowledged and accepted that some Colleagues will be expected to attend events where Hospitality is offered as part of the role that they fulfil for the Bank i.e. investor dinners ahead of a board meeting or Limited Partner Committee and as a consequence, the instances of Hospitality declarations will be higher for some business units (UK Networks, BPC etc) than in others.

It is for each Colleague to decide whether an offer of Hospitality should be accepted in accordance with the requirements of these Standards (excluding Corporate Hospitality). Before accepting, you should be satisfied that the Hospitality is normal and reasonable in the circumstances. If in doubt, you should consult your SLT member or the Risk and Compliance team.

The following guidelines are intended to help you and your SLT member come to a decision:

Is it in the Bank’s or any of its subsidiaries’ interests? For Hospitality to be in the Bank’s interests there will normally need to be a business benefit to Bank e.g. an opportunity to discuss business. This generally rules out invitations to sporting or cultural events unless the CRO or delegate is satisfied that attendance would offer valuable networking opportunities that are in the interest of the Bank, or that the Bank needs to be represented at the event (see below for further guidance on Corporate Hospitality). In these cases you should also check with your SLT member or the Risk and Compliance team, to make sure that the Bank is not over-represented and that the estimated value of the Hospitality offered is normal and reasonable in the circumstances.

The value: Is this enough to give rise to criticism? You should always consider the perceived value as well as the actual cost.

The frequency: Is it more frequent or regular than would be regarded as normal or reasonable, taking into account the nature of the event(s)? Acceptance of frequent or regular offers of low value Hospitality is not in the spirit of these Standards. If accepted, such offers of Hospitality should be aggregated and declared using the Gifts and Hospitality Portal.

The potential for embarrassment: Is the person or organisation offering the Hospitality under investigation or have they been criticised by the Government or anyone acting on its behalf?

The nature of any relationship with the Bank: Even if you are not involved in financial, contractual or regulatory matters connected with the person or body concerned, the acceptance of an invitation could be open to misconstruction or misrepresentation.

You need to bear in mind that these guidelines are not just intended to safeguard the Bank’s position; they are framed to help you to avoid personal embarrassment and criticism, however misplaced.

3.1.7 Hospitality Declarations

If the estimated value of the Hospitality offered is less than £25, you do not need to declare it so long as you abide by the guidelines above. If the estimated value is between £25 and £100 you must declare it using the Gifts and Hospitality portal. This can be done in retrospect i.e. where hospitality may have been offered following a meeting, however, where the colleague has advance notice of the offer of hospitality / event, this should be declared prior to the event. You must select your SLT member from the drop-down list on the portal and the declaration will be sent directly to that member for review and to request approval. For ExCo / SLT member’s declarations the approving officer will be the CEO. If the estimated value is greater than £100, this must be declared using the Gifts and Hospitality portal and you must seek authorisation from your SLT member, and the Bank’s Chief Risk Officer or delegate prior to acceptance. When completing the details of the Gift or Hospitality declaration on the Gifts and Hospitality Portal Colleagues must ensure that they provide the name of the organisation that is offering the Gift or Hospitality.

Attendance at a work-related conference (paid for by a third party) that doesn’t include an overnight stay and/or dinner should only be declared where you estimate the value of combined lunch/drinks/other refreshments to be greater than £25.

The table below provides a summary of the approval levels required, based upon the value of the Hospitality:

* for ExCo/SLT member’s submissions the approver will be the CEO; for CEO submissions the approver will be the CRO

If you decline the offer of Hospitality with a value above £25, you must still declare this, using the Gifts and Hospitality Portal.

3.1.8 Valuation of Hospitality

It is acknowledged that in some cases, it will be difficult to determine the value of the Hospitality, however you should provide a “best guess” which could be based upon the type of event e.g. black tie dinner, or information on the venue’s website which may help to determine the value of Hospitality received.

3.1.9 Offers of Hospitality (from the Bank to counterparties)

Any Offer of Hospitality made by the Bank to a Counterparty between £25 and £100 must be declared using the Gifts and Hospitality portal. This can be done in retrospect i.e. where hospitality is offered following a meeting, however, where the colleague is aware in advance that they will be offering hospitality, this should be declared prior to the event.

Any offer of Hospitality over an estimated value of £100 per head by a Bank colleague to Counterparties must be declared using the Gifts and Hospitality portal and then approved by the Bank’s Chief Risk Officer or delegate, together with SLT approval, in advance.

All other offers of Hospitality less than £25 per head must be approved by the relevant budget holder as per the Travel and Expenses Policy.

All offers of Hospitality must be declared using the Gifts and Hospitality portal.

The following principles must be adhered to when offering Hospitality to counterparties:

• Hospitality may be offered to external Bank office visitors, where required.
• In these circumstances, the authoriser should consider whether the Hospitality is appropriate. Factors to consider may include the cost of the refreshments, the length of the visitors commute, the timing and length of the meeting, and whether any offence would be caused by not providing refreshments.
• Hospitality offered outside the offices e.g., dinner in a restaurant must be associated with Bank activity and care should be taken to ensure that any Hospitality given to a counterparty could not give rise to criticism or compromise the Bank’s integrity.

3.1.10 Corporate Hospitality

Colleagues should not accept Corporate Hospitality from Counterparties e.g., attending sports events, concerts, dinners, or company-sponsored outings, unless there is a valid business reason for attendance. The Bank’s Chief Risk Officer or delegate must approve any offers of Corporate Hospitality prior to acceptance. Approval must be sought by declaring this through the Gifts and Hospitality portal.

Corporate Hospitality events and/or dinners organised by the Bank to promote government policy must be approved by the Bank’s CEO or the Bank’s CFO. 

The following principles must be adhered to when offering Corporate Hospitality to external counterparties: 

• The meeting sponsor should set out why the Corporate Hospitality is required and the estimated cost of the proposal.
• As a 100% Government owned entity, care should be taken to ensure that Corporate Hospitality provided to external counterparties could not give rise to criticism or be considered disproportionate to the promotion of the Bank’s policies.

Where a Corporate Event organised by the Bank includes hospitality being offered to its attendees, this should be proportionate and appropriate for the type of event being held. There is no requirement in these circumstances, for the hospitality element of the Corporate Event to be declared via the G&H Portal as it is recorded during the approval process for the Corporate Event itself. All Corporate Hospitality events must promote the Bank’s policies.

3.1.11 Non-Executive Board Members

These Standards apply to all members of the Bank and subsidiary Boards in circumstances where they are fulfilling their duties to the Bank. They should use the Declaration Form in Appendix 1 but forward it to the Bank Company Secretariat who must then send to the Risk and Compliance team so that the declaration can be captured in the central Gifts and Hospitality register. The approver for these declarations will be General Counsel.

In the event members of any Board receive or give Gifts or Hospitality in relation to responsibilities connected with positions in other organisations, they should adhere to the policies of those other organisations.

3.1.12 Exceptions

Purely social offers of Gifts and Hospitality, where there is no connection to the Bank, do not fall under the scope of these Standards. However, it is expected that Colleagues and Board members will exercise reasonable and sensible judgment in determining whether something is purely social, taking into account the principles and guidelines in Sections 4, 5 and 6 above.

3.1.13 Records of Gifts and Hospitality

All material Gifts (over £10) and Hospitality (over £25) that you accept or decline while on duty must be registered with the Risk and Compliance team using the Gifts and Hospitality portal. A Gifts and Hospitality Register is maintained by the Risk and Compliance team to record all Gifts and Hospitality received and offered. The register will be maintained in accordance with the Bank’s Records Management Policy and Standards.

3.1.14 Publication of Gifts and Hospitality

Details of all Gifts and Hospitality received (accepted or declined) or offered by Senior Leadership Team / Executive Committee and Board members will be published on the Bank’s internet on an annual basis covering the previous financial year. The details that will be published include;

• name, description of the Gift / Hospitality including the organisation offering / receiving the gift or hospitality and their relationship with the Bank,
• the reason for the offer including details on the business benefit to Bank of accepting or offering the gift or hospitality,
• the value and whether this was accepted / offered.

3.1.15 Awards and Prizes

If you are approached by an outside organisation about the offer of an award or prize which is connected with your Bank duty, you should discuss with your SLT member whether it would be appropriate to keep it. If your SLT member is unsure then speak to the Risk and Compliance team.

You will normally be allowed to accept the award or prize provided that it:

• Is given to recognise special merit or achievement;
• Is not, or does not look like, a Gift, inducement, or payment.
• Enhances the reputation of the Bank

Any Gift or prize that could be viewed as detrimental to the Bank’s reputation should be declined.