Gifts & Hospitality Standards

3. Key Control Requirements

3.1 The Principles of Propriety for Gifts and Hospitality

 Colleagues must adhere to the following principles governing Gifts and Hospitality:

• 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 duties and your private interests or have scope to cause embarrassment either to yourself or to the Bank;
• You should not put yourself in a position where your personal judgement or integrity could be influenced by accepting or offering a Gift or Hospitality.
• Any Hospitality accepted should be in the Bank’s interests i.e. provide an opportunity to discuss business. This generally rules out Corporate Hospitality e.g. invitations to sporting or cultural events unless the CRO is satisfied that attendance would offer valuable networking opportunities or where the Bank needs to be represented at the event (and is not already over-represented by other Colleagues). Please see section on Corporate Hospitality at 3.10 for further details.
• You should always consider the perceived value of the Gift or Hospitality as well as the actual cost. The value must be normal and reasonable in the circumstances.
• The 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.

These principles are not intended to stop you from accepting occasional trivial Gifts or Hospitality for example, working lunches.  However, an offer of a more substantial Gift or Hospitality should not be lightly accepted as its acceptance could be misconstrued or open to misrepresentation even where you are not involved in financial, contractual or regulatory matters connected with the person or body concerned.

You should always consult your line manager or the Risk and Compliance team if you are unsure whether to accept or offer a Gift or Hospitality or if declining the offer might cause offence or misunderstanding.  If after this, you are still in doubt about whether you should accept a Gift or offer of Hospitality you should politely refuse it.

3.2 Value 

It is the responsibility of the recipient of the Gift or Hospitality to provide a best estimate of its value.  It is acknowledged that in some cases it will be difficult to determine this, however you should provide a “best guess” for example, using an internet search for the item or type of event.  

3.3 Declaration of Gifts

All Gifts with a value of £10 or more – whether accepted or declined - must be declared using the Gifts and Hospitality Portal.   Your SLT member will agree/disagree to the request through the portal and you will then receive an automated notification of their decision.  

Gifts that have a value of lower than £10 do not need to be declared as long as the Principles set out above in section 3.1 of these Standards have been followed.

The table below provides a summary of the approval levels required for Gifts:

Gifts

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

3.4 On Receipt of a Gift

By making your declaration through the Portal, your SLT member will decide whether you may keep the gift, share it amongst Colleagues or display in the office. Where the value of the Gift is over £100, this decision will be a joint one between your SLT member and the CRO.

If you decide that it would be improper to accept a Gift, you should politely refuse it.  However, if refusing it is likely to cause misunderstanding or offence, you should consider accepting the Gift and sharing it amongst Colleagues or raffling it off and donating the money to charity.  If you are in any doubt, you must discuss the matter with your line manager or the Risk and Compliance team.

3.5 Offering Gifts

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

3.6 Accepting Hospitality 

It is accepted that some Colleagues will be expected to attend events where Hospitality is offered as part of their role at the Bank (for example, investor dinners, ahead of a board meeting or Limited Partner Committees).

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 and if in doubt, you should consult your line manager or the Risk and Compliance team.

3.7 Hospitality Declarations

If the estimated value of the Hospitality is over £25 – whether offered or received, accepted or declined – you must declare it using the Gifts and Hospitality Portal.   Hospitality with a value of less than £25 does not need to be declared as long as the Principles in section 3.1 of these Standards have been followed. 

For Hospitality received with a value of £25-£100, the request for authorisation can be submitted retrospectively if the Hospitality was offered without advance notice for example, after a meeting.  For Hospitality with a value over £100 authorisation must be received prior to the acceptance.

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

Hospitality (Received or Offered)

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

3.8 Offering Hospitality

Hospitality, for example, dinner in a restaurant, may be offered to external Bank visitors where required as long as it is associated with Bank activity and is considered appropriate based on the Principles set out in section 3.1 of these Standards.

Where offering Hospitality to visitors in the office, in addition to the Principles in section 3.1 above, consideration should be given to factors such as the cost of the refreshments, length of the visitors’ commute, the timing and length of the meeting held and whether any offence would be caused by not providing refreshments.

3.9 Overlap with Travel and Expenses Policy

All offers of Hospitality less than £25 where you need to claim back the expense because you have paid for it yourself, must be approved by the relevant budget holder as per the Travel and Expenses Policy. If you have offered Hospitality over £25 and need to claim back the expense, this will subject to both the Travel and Expenses Policy and must also be declared under these Standards.

3.10 Corporate Hospitality  

Colleagues should not accept Corporate Hospitality, for example, attending sports events, concerts, dinners, or company-sponsored outings, unless there is a valid business reason for attendance.  The Bank’s CRO or their 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 must promote government policy and be approved by the Bank’s CEO and the CRO.  The meeting sponsor should set out why the Corporate Hospitality is required, the estimated cost and explain why it is proportionate and appropriate.

There is no requirement in these circumstances, for the Hospitality element of the Corporate Event to be declared via the Gifts and Hospitality Portal as it is recorded during the approval process for the Corporate Event itself.  

3.11 Non-Executive Board Members

These Standards apply to all members of the Bank and its subsidiary Board members in circumstances where they are fulfilling their duties to the Bank.  Non-Executive Board Members should use the Declaration Form in Appendix 1 (and also available in Diligent) but forward it to the Bank’s Company Secretariat who must then send it to the Risk and Compliance team so that the declaration can be captured in the Gifts and Hospitality Register. The approver for these declarations will be General Counsel. 

In the event members of any Board receives or offers any Gift or Hospitality in relation to their responsibilities or positions in other organisations, they should adhere to the policies of those other organisations.

3.12 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 including Board members will exercise reasonable and sensible judgment in determining whether something is purely social, taking into account the Principles set out in these Standards.  

3.13 Records of Gifts and Hospitality 

A Gifts and Hospitality Register is maintained by the Risk and Compliance team. The Register will be maintained in accordance with the Bank’s Records Management Policy and Standards.

3.14 Publication of Gifts and Hospitality

Details of all Gifts and Hospitality received - whether accepted, declined or offered - by Senior Leadership Team/Executive Committee and Board members will be published on the Bank’s website on an annual basis covering the previous financial year. Published details will 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 it was accepted, declined or offered.

3.15 Awards and Prizes 

If you are approached by an outside organisation about the offer of an award or prize which is in connection with your Bank duties, you should discuss with your SLT member whether it would be appropriate to keep it or not. If your SLT member is unsure, then you should speak to the Risk and Compliance team. All awards and prizes should also be declared through the Gifts and Hospitality Portal.  Any award or prize that could be viewed as detrimental to the Bank’s reputation should be declined.

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