Policy on Gifts and Hospitality

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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 show favour or disadvantage to any individual or organisation or influence the judgement of that person. 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 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. 1.1. Business Gifts You should not normally accept business gifts other than items of very low value, normally under 15. 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. 1.2. 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. How often and how much hospitality we accept should not be significantly greater than SFT would be likely to provide in return. 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. Page 1 of 8

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. If in any doubt advice should be sought from the SFT Chief Executive. 2. Relationship to Procurement It is an offence under the Prevention of Corruption Act 1906 for those employed by contracting authorities in their official capacity corruptly to accept any gift or consideration as an inducement or reward for doing, or refraining from doing, anything or showing favour or disfavour to any person. Under the Prevention of Corruption Act 1916, any money, gift or consideration received from a person or organisation holding or seeking to obtain a contract will be deemed by the courts to have been received corruptly unless proved to the contrary. It is therefore 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. Any offer of gifts or hospitality from such an organisation should be notified to the Chief Executive for specific consideration. Page 2 of 8

Hospitality and Gift Register 1 October to 31 December 2010 Date Received / 1 October 2010 Barry White (Chief EPEC Annual All Members Meeting Dinner, Cercle Munster, Luxembourg EPEC 6 October 2010 Grant Robertson (Associate Business Council for Sustainable Development Dinner, Scottish Parliament Gerry Brannigan, AECOM 60 6 October 2010 John Hope (Associate Golf Day, Dalmahoy Kris Flanagan, Robert Half 11 October 2010 Barry White (Chief 11 October 2010 Sir Angus Grossart (Chairman) Dinner with Neil Baxter and David Dunbar of RIAS, The Grain Store, Dinner with Neil Baxter and David Dunbar of RIAS, The Grain Store, Neil Baxter, RIAS 50 (est.) Neil Baxter, RIAS 50 (est.), but later unable to attend 13 October 2010 Barry White (Chief Scottish Property Federation Post- Conference Dinner, Caledonian Hilton Hotel, Gail Hume, Scottish Property Federation 70 (est.) Page 3 of 8

/ 14 October 2010 James King (Associate Academicals FP vs. Stewarts Melville FP lunch plus hospitality Drysdale Graham, McGrigors LLP 60 15 October 2010 Barry White (Chief Scottish Sports Awards 2010, Hilton Hotel Glasgow Stewart Harris, sportscotland 100 (est.) 15 October 2010 Barry White (Chief The Yorkhill Dinner, Radisson Hotel, Glasgow Jacqueline Speirs, Currie & Brown 100 (est) 18 October 2010 Tony Rose (Infrastructure Tickets and Reception for Scotland vs New Zealand Rugby @ Murrayfield Gary Easton, Turner & Townsend Cost Management, 100 (est) 18 October 2010 Gemma Gordon (Associate Mace Drinks Reception, EICC Robbie Smith, Mace, 18 October 2010 Barry White (Chief Mace Drinks Reception, EICC Robbie Smith, Mace, but later unable to attend 18 October 2010 Tony Rose (Transport Mace Drinks Reception, EICC Robbie Smith, Mace, Page 4 of 8

/ 20 October 2010 Claire Blake (Associate Mace Drinks Reception, EICC Robbie Smith, Mace, 29 October 2010 Barry White (Chief Aedas Chairman s Dinner, Blythswood Square Hotel, Glasgow Elsie Mundell, AEDAS 70 (est.) 29 October 2010 Colin Proctor (Accommodation Aedas Chairman s Dinner, Blythswood Square Hotel, Glasgow Elsie Mundell, AEDAS 70 (est.) 29 October 2010 Colin Proctor (Accommodation Wooden Spoon Charity Dinner, Prestonfield House Hotel, David McLeod, Rybka 1 November 2010 Barry White (Chief Deloitte discussion on the future of Scotland s public sector (inc. light supper), Saltire Court, Angela Mitchell, Deloitte 4 November 2010 Peter Reekie (Director of Finance & Structures) McGrigors Discussion Dinner Identifying s Economic Priorities Michael Watson, McGrigors 5 November 2010 Barry White (Chief PPP Forum lunch, Marsh Ltd, Queensferry Road, Robert Ure, Marsh Ltd Page 5 of 8

/ 5 November 2010 Barry White (Chief Scottish Property Federation Reception, Caledonian Hilton, Phil Miller, Scottish Property Federation 9 November 2010 Tony Rose (Infrastructure SCDI Scotland s International Awards Dinner, Thistle Hotel, Glasgow Brian Veitch, Director, Arup 100 (est.) 10 November 2010 Peter Reekie (Director of Finance and Structures) SCDI Scotland s International Awards Dinner, Thistle Hotel, Glasgow Brian Veitch, Director, Arup 100 (est.) 10 November 2010 Neil Grice (Associate Scottish Institution of Civil Engineers annual dinner, Sheraton Grand, Ian Courtney, Mott McDonald unknown 16 November 2010 Barry White (Chief The Scotland plc Awards, Hilton Hotel, Glasgow (20 April 2011) Frank Blin, Executive Chairman, PwC 100 (est) 18 November 2010 Peter Reekie (Director - Finance&Structures) The Scotland plc Awards, Hilton Hotel, Glasgow (20 April 2011) Frank Blin, Executive Chairman, PwC 100 (est) 22 November 2010 Neil Grice (Associate Miller Construction - drinks and canapés, National Museum of Scotland, Brian McQuade, Miller Construction Page 6 of 8

/ 22 November 2010 Clare Blake (Associate Miller Construction - drinks and canapés, National Museum of Scotland, Brian McQuade, Miller Construction 22 November 2010 Barry White (Chief Miller Construction - drinks and canapés, National Museum of Scotland, Brian McQuade, Miller Construction 22 November 2010 Barry White (Chief PPP Forum lunch, Malmaison Hotel, (speaking engagement Barry standing in for Peter Reekie) Drysdale Graham, McGrigors 22 November 2010 Barry White (Chief Housing, the Economy and City Change:Where Next? Lecture and Reception, St Andrews University Professor Duncan MacLennan (later declined due to bad weather) 23 November 2010 Barry White (Chief Brodies Christmas Debate, Atholl Crescent, Christine O Neill, Brodies 29 November 2010 Barry White (Chief The David Hume Institute Book Launch, National Library of Scotland Sir Ian Byatt, David Hume Institute 1 December 2010 Tony Rose (Infrastructure AIRMIC 2011 Conference and Dinner, The Jam House, Adrian Colosso, Heath Lambert 100 Page 7 of 8

/ 13 December 2010 Tony Rose (Infrastructure Scotland vs Wales rugby, Murrayfield Gary Easton, Turner and Townsend 100 22 December 2010 Peter Reekie (Director of Finance&Structures) McGrigors Burns Supper, Grand Central Hotel, Glasgow Susan Price, McGrigors LLP 22 December 2010 Donna Stevenson (Associate McGrigors Burns Supper, Grand Central Hotel, Glasgow Susan Price, McGrigors LLP Page 8 of 8