Policy on Gifts and Hospitality

Transcription

1 Policy on Gifts and Hospitality 1. General No gift or hospitality should be accepted by SFT Board members or employees which could give rise to an inference that a member or employee might be induced to act improperly in the performance of their activities. You must never canvass or seek gifts or hospitality. Any gifts and hospitality offered, whether or not accepted, with a monetary value greater than 50 must be recorded and a record made available for public inspection. SFT maintains a Hospitality Register which is regularly published on the company website. Details of any gifts or hospitality offered and whether it is accepted or declined must be submitted to the Office Manager within 7 days for inclusion on the register. You should also consider whether there may be any reasonable perception that any gift received by your spouse or cohabitee or by any company in which you have a controlling interest, or by a partnership of which you are a partner, can or would influence your judgement. If in any doubt advice should be sought from the SFT. 2. The Bribery Act 2010 The Bribery Act 2010 makes it an offence to request, agree to receive or accept a financial or other advantage, with the intention of inducing improper performance by the recipient. What constitutes an advantage could, in principle, include gifts and corporate hospitality and improper performance is a breach of the expectation that our activities are performed in good faith and impartially by virtue of the fact that SFT is in position of trust. Page 1 of 12

2 2.1. Business Gifts You should not normally accept business gifts other than items of very low value, normally under 15. However, regardless of their value, you should always consider whether the gift is intended to induce improper performance. Appropriate gifts may be accepted as a thank-you for a speaking engagement or similar, with any such gift over the value of 50 recorded. Where possible, an offer of a gift other than one of a very low value, should be politely declined. Where this is not possible, for example gifts given at a public event or gifts received through the post, then the gift may be returned if possible cost effectively and without causing embarrassment, or donated for charitable purposes. The term gift includes benefits such as relief from indebtedness, loan concessions, or provision of services at a cost below that generally charged to members of the public Hospitality Accepting modest hospitality is part of a business relationship. However, anyone accepting hospitality must be aware of the risk of being perceived by others to have been influenced in making a business decision as a result of accepting such hospitality. Hospitality should always be reasonable and proportionate and the more lavish the hospitality and the higher the expenditure, the greater the risk is that it may be considered a bribe. How often and how much hospitality we accept should not be significantly greater than SFT would be likely to provide in return. Hospitality which involves the provision of overnight accommodation or has a monetary value greater than 50 must be registered in the Register of Hospitality. You must not accept repeated hospitality from the same source except isolated gifts of a trivial character or inexpensive seasonal gifts such as a calendar or a diary, or gifts received on behalf of SFT. Page 2 of 12

3 3. Relationship to Procurement It is particularly important to be aware of gifts and/or hospitality from organisations that may be bidders, or associated with bidders on projects or programmes over which SFT has an influence. Gifts and/or hospitality should not be accepted at periods that may be considered sensitive i.e. shortly before an award of contract or conduct of a tender procedure, either by SFT or in respect of a project where SFT is involved, which may involve the party offering the hospitality. Any offer of gifts or hospitality from such an organisation should be notified to the for specific consideration. Page 3 of 12

4 Hospitality and Gift Register 01 July 2014 to 30 September 2014 Date Received 01 July July July July July July July July July July 2014 John Hope Hub Director Andrew Bruce Head of Project Finance Gemma Boggs Schools Programme Director Alison Wilson Financial Controller John Hope Hub Director Glasgow 2014 Commonwealth Games Rugby Sevens on 26th July Glasgow 2014 Commonwealth Games Rugby Sevens on 26th July Lighthouse Club Scotland (East) Annual Dinner Drinks Reception Drinks Reception Official Opening of Aberdeen Health Care Village Dinner at Noble Grossart Bottle of Champagne (sent to all keynote speakers at CPD event June 2014) Harper MacLeod Harper MacLeod S Morwood Graham Construction Scott Craig Scott-Moncrieff Scott Craig Scott-Moncrieff Heather Kelman NHS Grampian Sir Angus Grossart Noble Grossart Tom White RICS / Concert event Jools Holland Sir John Elvidge Evening Drinks Reception Robert Carr Anderson Strathern Page 4 of 12

5 22 July July July July July July July July July July 2014 Colin Proctor Asset Management Director Viv Cockburn Low Carbon Director Andrew Bruce Head of Project Finance Scottish Futures Trust Claire Robertson PA to Director of Finance and Fringe Festival event Aye or Naw Summer Barbeque Aye or Naw Summer Barbeque Energy Efficiency Lunch- Drinks reception Double Tree by Hilton, Edinburgh Traditional Chinese craftwork book Traditional Chinese craftwork book BDG Festival fireworks event Tie Breakfast reception Ben Walker Livingston James Bernadette Coyle Currie & Brown Bernadette Coyle Currie & Brown Alan Pratten Arthur J Gallagher / Rutherford Cross Tifeng Gu Chinese Ministry of Finance Tifeng Gu Chinese Ministry of Finance Robyn McCartney BDG Tifeng Gu Chinese Ministry of Finance Zoja Bazarnic US Consulate Page 5 of 12

6 04 August August August August August August August 2014 Christa Reekie Commercial Director Paul Moseley Associate Director Kerry Alexander NPD Programme Director Colin Proctor Asset Management Director Kerry Alexander NPD Programme Director Pinsent Masons ETAPE Brodies LLP Fizz on Fourth 17 September 2014 Brodies Evening Reception 17 th September 2014 Brodies LLP Fizz on Fourth 17 September th Anniversary Party 18 th September th Anniversary Party 18 th September 2014 Radio Lollipop Ball - 3 October 2014 Roxburgh Hotel Edinburgh Michael Watson Pinsent Masons 75 / Chloe Richardson Brodies LLP Chloé Richardson Events & Seminars Coordinator Chloe Richardson Brodies LLP Thomson Gray Construction Consultants Thomson Gray Construction Consultants Ross Lovatt Thomson Gray 15 August August 2013 Joint RSE and Foundation debate on research and innovation in Scotland event PPP Infrastructure Conference and Reception, Brussels Dr Dougal Goodman Foundation for Science & Technology Cosette Canilao PPP Centre of the Philippines Page 6 of 12

7 20 August August August September September September September September September September 2014 Colin Proctor Asset Management Director Viv Cockburn Low Carbon Director Anna Tozer Strategic Disposals Manager Nicola Barclay Strategic Disposals Manager Colin Proctor Asset Management Director Deputy and Director of Anna Tozer Strategic Disposals Manager Deputy and Invitation to Opening of the new RICS Scottish Headquarters Drinks Reception at King s Theatre Cocktail party Drapers Hall London Glentress Charity Cycle Day Glentress Charity Cycle Day Scottish Financial Enterprise (SFE) Annual Dinner, Glasgow Dinner invitation to Tower Restaurant, Museum of Scotland Cheese and Wine Tasting event Drinks & Canapes at Edinburgh Castle 30 th October 6pm-8.30pm Robert McAlpine Annual Reception / Lisa Mason RICS Scotland Marie MacKenzie Will Rudd Davidson Jo Saunders Hurleypalmerflatt Andrew Hill DTZ Andrew Hill DTZ Douglas Connell Turcan Connell Robert Holt Carillion Richard Cantlay Mott McDonald Kerry Hough DTZ Robert McAlpine and Family Page 7 of 12

8 Director of / 16 September September September September September September September September September 2014 Viv Cockburn Director of Corporate Services & Low Carbon Deputy and Director of Deputy and Director of Stephen Vere Senior Commercial Manager- Low Carbon Neil Rutherford Associate Director Colin Proctor Asset Management Director Paul Moseley Associate Director John Trower External Industry Advisor DTZ Scotland Directors: Drinks and Canapes at Edinburgh Castle Drinks & Canapes at Edinburgh Castle 30 th October 6pm-8.30pm Hub West Scotland s Annual Shareholder Dinner 30 th October Scottish Politician of the Year Awards 20 th November 2014 DTZ Kerry Hough DTZ Bill Matthews Chair Malcolm Buchanan RBS Still Game Event, SSE Hydro, 30 Sept CMS Still Game Event, SSE Hydro, 30 Sept CMS Chairman s Dinner 30 th October 2014 Scottish Danish District Heating dinner Elsie Mundell AHR Global Danish District Energy Partnership 50 Scotland IS Software Awards Event, EICC BT 40 Page 8 of 12

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