Gifts, Hospitality & Donations Policy

1. Purpose and intent

Controls gifts, meals, travel, entertainment, sponsorships and charitable contributions to prevent improper influence. This policy is intended to provide a consistent reference for decisions, conduct and controls. It should be read alongside applicable laws, contractual obligations and relevant internal procedures. Where requirements differ, the applicable legal requirement and formally approved internal control take precedence.

2. Scope and application

Applies to personnel and representatives who offer, provide, request or receive gifts, hospitality, travel, sponsorships or donations in connection with organisational business.

Business partners are expected to observe equivalent standards where these are relevant to the services they provide or the activities they undertake on the organisation’s behalf. Application should be proportionate to role, activity, risk and applicable legal requirements.

3. Core principles

• No cash: cash and cash-equivalent gifts are prohibited.
• No influence: benefits must not influence or appear to influence a decision.
• Proportionality: value, frequency, timing and context must be reasonable.
• Transparency: approval and recording requirements must be followed.
• Enhanced caution: dealings involving public officials require heightened scrutiny and prior approval.

4. Minimum standards and controls

The following controls describe the expected minimum approach. Specific procedures, approval limits, forms and technical controls may be established separately and updated through controlled internal documents.

• Seek approval before offering or accepting benefits where required by internal limits.
• Decline benefits during active tenders, negotiations, inspections or approval decisions if impartiality could be affected.
• Record the giver, recipient, purpose, estimated value, date and approval.
• Conduct due diligence and document the purpose of sponsorships and donations.
• Escalate unusual requests, personal payments or benefits directed to family members.

5. Roles and accountability

Managers and designated approvers assess requests. Finance or compliance personnel maintain registers where assigned. Individuals must disclose benefits and decline or return anything that breaches this standard.

Any person who is uncertain about the application of this policy should seek guidance before taking action. No individual may override a legal obligation or approved control without appropriate authority and documented justification.

6. Reporting and escalation

Concerns, suspected breaches, control weaknesses and incidents should be raised promptly through the relevant management or designated reporting channel. Urgent threats to health, safety, the environment or the security of information must be escalated immediately. Reports should be handled fairly, sensitively and in accordance with applicable privacy and records requirements.

7. Monitoring, assurance and review

Registers, exceptions, approvals and reported concerns should be reviewed periodically. Breaches may be treated under the Anti-Bribery and Code of Conduct frameworks.

Where improvement actions are identified, they should be assigned to an accountable owner, given a proportionate target date and monitored to closure. Material changes in law, risk, organisational context or operating arrangements should trigger an earlier review.

8. Non-compliance

Failure to follow applicable requirements may result in corrective action, additional training, restricted authority, disciplinary measures, contractual remedies or referral to relevant authorities, depending on the circumstances and applicable law. Any response should be proportionate and follow fair process.

9. Related policies and standards

Anti-Bribery; Conflict of Interest; Procurement; Code of Conduct; Financial Controls.

Additional policy requirements

The following provisions expand the practical expectations set out in this policy. They should be applied in conjunction with applicable law, approved internal procedures, contractual obligations and the circumstances of each activity.

General test

Any gift or hospitality must have a legitimate business purpose, be proportionate, transparent, lawful and incapable of reasonably appearing to influence a decision. Cash and cash equivalents must not be offered or accepted.

Pre-approval and recording

Benefits should be declared and approved before acceptance or provision where required by internal thresholds or heightened risk. Registers should record the giver or recipient, value or reasonable estimate, purpose, date, business context and approval.

Public officials and sensitive decisions

Benefits involving public officials, procurement decisions, licensing, inspections, tenders, recruitment or contract awards require heightened scrutiny and may be prohibited. Where doubt exists, the benefit must not proceed until written guidance is obtained.

Travel and events

Travel, accommodation, conference invitations and entertainment must be necessary, modest and directly connected to a legitimate business purpose. Personal guests, leisure extensions and excessive hospitality should not be funded.

Charitable contributions

Donations and sponsorships must be made to legitimate recipients, for a documented purpose, with appropriate due diligence and approval. They must not be used as a conduit for improper influence or personal benefit.

Return, refusal and escalation

Improper or excessive benefits should be declined or returned where practicable. Where return may cause offence or is impracticable, the matter should be declared and handled under an authorised direction. Suspected bribery must be escalated under the Anti-Bribery Policy.

10. Document governance

This web page is a public policy statement. The controlled internal version, where formally approved, is maintained through the organisation’s document-control process. Approval status, document owner, effective date, review cycle and revision history must be confirmed in the controlled document register before this text is represented as a formally issued internal policy.