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Gifts and hospitality

The long term business relationships we depend on are based on trust and respect.

Exchanging gifts and hospitality can build goodwill, but we should not give or accept them if they risk even appearing to create improper influence. This requires care and good judgement.

Gifts and Hospitality - mean anything of value that you give or accept, either directly or in kind. Any gift or hospitality you accept from someone should be something that you would be able to give them as a proper and appropriate business expense. "Proper and appropriate" is what matters. For instance, if an existing supplier invites you to share a box at a football match, you should record this, but it may be appropriate. However, if a prospective supplier hoping to get a contract from you does the same, that is not appropriate.

Additionally, local rules may also limit the value of gifts or hospitality you can accept.

Unacceptable Gifts - There are some types of gifts that are never acceptable. These include cash, securities, and personal cheques or payments to or for the benefit of individuals.

Use your judgement. If in doubt: always check it and record it.

To make sure you always make the right judgement, ask yourself:

  • Why is this being offered? Is it appropriate? Does it violate any laws, regulations or Serco policy?
  • What's the background? Does the person making this offer feel obliged to make it? Is something expected in return? Might the intended recipient feel under undue obligation?
  • Is it really an integral and logical part of the business relationship? What could be the outcome for Serco or the person receiving it if the offer is accepted or declined? Would it be easy to justify its acceptance to the public?
  • Is there any involvement with government officials (including employees at state owned or controlled companies and members of government sponsored institutions)?

For advice on whether it's appropriate: check out our SayNo Toolkit and App.

For more information download:

Business Conduct and Ethics Group Standard

Gifts and Hospitality Group Standard Operating Procedure

Gifts and Hospitality fact sheet

What you can expect from us:

  • We will never give or receive gifts or hospitality that may improperly influence a business decision or judgement.
  • We have clearly defined limits on what gifts we can give or receive. These vary across the business. What matters is that we never give or receive anything that is outside the norm, or that could be regarded as trying to exert improper influence.
  • We have a standard reporting process to register gifts and hospitality we give or receive anywhere in the world. You can find this at https://gandh.serco.com. As a minimum, all gifts or hospitality with a value over £100 must have management approval and must be registered. However, this limit may be less depending on local procedures.

We expect you to:

  • Take care when you give or accept business-related gifts or hospitality. You should know what is currently customary and acceptable. If it's of more than modest value, or you're not sure it's appropriate, always ask your manager.
  • Always ask yourself if any gift or hospitality could be thought of as an attempt to improperly influence a usiness decision. And always register anything you receive or give at https://gandh.serco.com.
  • Donate any gift you keep to a nominated charity or make it available to everyone in your unit. If you return a gift, do so immediately, along with a written explanation.
  • Take particular care if items of value are offered when we are negotiating or considering contracts, and the recipient could influence the outcome, either directly or indirectly.

I’ve been given branded baseball caps by a supplier for my entire team as a thank you for all the work we have given his company over the last year. Is it okay to accept them?

Sure, what’s the problem?

Wrong. Please try again.

We should make sure, before accepting

Right answer because:

The long term business relationships we depend on are based on trust and respect. Exchanging gifts and hospitality can build goodwill, but we should not give or accept them if they risk even appearing to create improper influence. This requires care and good judgement.

And in this case, we really do need to exercise good judgement. The problem here isn’t the value. It’s the fact that the caps are all branded.

If there were just one or two, that would be fine. But when our whole team wears them, this might suggest some kind of tie-in with the supplier.

Almost certainly that’s not appropriate, because it’s open to misinterpretation. But in any event, this gift should be discussed with management before it is refused or accepted.

What is important is that when you are not sure about whether it’s right to give or receive something, always check. As our Code says,

Use your judgement. If in doubt:

Always check it and record it.

No, we’d have to refuse this one. It’s those brands that are the problem

Wrong. Please try again.

We’re doing work with an important customer and bidding for more. I’ve just found out he is passionate about football. I can get some tickets for the final. Can I offer to take him?

Absolutely

Wrong. Please try again.

It depends what the value of the tickets is

Wrong. Please try again.

This could give the wrong impression. We must check

Right answer because:

Our Code tells us we must take care when giving or accepting business-related gifts or hospitality.

One important criterion is value but this is not the only criterion. If it’s of more than modest value, or the tickets are hard to get hold of, or you’re not sure it’s appropriate, always ask your line manager.  We have clear policies on this - always check these. And always register anything you give or receive on our Gift Register.

However, our Code also tells us:

“Always ask yourself if any gift or hospitality could be thought of as an attempt to improperly influence a business decision“.

This requires care and good judgement, particularly when looking at the context in which the gift is being made.

In this case, since we are in the middle of bidding for more work from this customer, could we be accused of trying to create improper influence? Would it be easy to justify this if it were made public?

These are difficult judgements to make. That’s why our Code says:

Use your judgement. If in doubt:

Always check it and record it.

I’ve provided an important government client with legitimate token gifts. He now expects a gift at every meeting and even drops hints about what he’d like! None are over my sign off limit. Should I keep bringing him gifts?

It’s an established pattern now. If we stop, we risk insulting him

Wrong. Please try again.

No, we have to stop this

Right answer because:

Our Code asks us to take care when we give or accept business-related gifts or hospitality.

There’s very good reason for this – after a certain point the difference between a gift or hospitality, and a bribe, is too narrow to call.

So our Code tells us to always ask ourselves if any gift or hospitality could be thought of as an attempt to improperly influence a business decision.

In this case, it’s not the value that is inappropriate but the frequency and volume of the gifts this client expects. It’s excessive, and it could be interpreted as a bribe.

The risk of this impression is increased because an important government client is involved.  In many countries government employees are not well paid but often have significant power. This situation increases the potential for bribery.

That’s why our Code asks us to stop and think when there is any involvement with Government Officials, including employees at State owned or controlled companies and members of Government sponsored institutions.

This doesn’t mean we should never give gifts to public employees. It does mean that we must always take the greatest care.

In this case, the gifts should stop, and senior managers need to discuss how to do this in a way least likely to insult the client.

Use your judgement. If in doubt:

Always check it and record it.

The gifts are within legitimate limits so it’s okay

Wrong. Please try again.

I’ve been working closely with a supplier on an important project which has gone well. As a thank you the supplier has given me an expensive watch. What should I do?

Get management approval and register the gift

Right answer because:

After a certain point the difference between a gift or hospitality, and a bribe, is too narrow to call.

So our Code tells us to always ask ourselves if any gift or hospitality could be thought of as an attempt to improperly influence a business decision.

We have clearly defined limits on what gifts we can give or receive. These vary across the business. What matters is that we never give or receive anything that is outside the norm, or that could be regarded as trying to exert improper influence.

We also have a standard reporting process to register gifts and hospitality we give or receive anywhere in the world. As a minimum, all gifts or hospitality with a value over £250 must have management approval and must be registered. However this limit may be less depending on local procedures.

In this case, it’s hard to see in what way the supplier may be trying to improperly influence a business decision if there are no pending contracts that he is applying for. However, the value of the gift is cause for concern.

Before accepting or refusing the gift you should explain that it is outside the norm, and that you will need to have management approval. If this is granted, you will need to register the watch. And ordinarily you should donate it to a nominated charity.

If you need to refuse the gift, then you should do immediately, along with a written explanation.

Refuse to accept it – it’s not appropriate

Wrong. Please try again.

Thank the supplier and wear it with pride

Wrong. Please try again.

I’ve been given branded baseball caps by a supplier for my entire team as a thank you for all the work we have given his company over the last year. Is it okay to accept them?

Sure, what’s the problem?

Wrong. Please try again.

We should make sure, before accepting

Right answer because:

The long term business relationships we depend on are based on trust and respect. Exchanging gifts and hospitality can build goodwill, but we should not give or accept them if they risk even appearing to create improper influence. This requires care and good judgement.

And in this case, we really do need to exercise good judgement. The problem here isn’t the value. It’s the fact that the caps are all branded.

If there were just one or two, that would be fine. But when our whole team wears them, this might suggest some kind of tie-in with the supplier.

Almost certainly that’s not appropriate, because it’s open to misinterpretation. But in any event, this gift should be discussed with management before it is refused or accepted.

What is important is that when you are not sure about whether it’s right to give or receive something, always check. As our Code says,

Use your judgement. If in doubt:

Always check it and record it.

No, we’d have to refuse this one. It’s those brands that are the problem

Wrong. Please try again.

Dilemma 2

We’re doing work with an important customer and bidding for more. I’ve just found out he is passionate about football. I can get some tickets for the final. Can I offer to take him?

Absolutely

Wrong. Please try again.

It depends what the value of the tickets is

Wrong. Please try again.

This could give the wrong impression. We must check

Right answer because:

Our Code tells us we must take care when giving or accepting business-related gifts or hospitality.

One important criterion is value but this is not the only criterion. If it’s of more than modest value, or the tickets are hard to get hold of, or you’re not sure it’s appropriate, always ask your line manager.  We have clear policies on this - always check these. And always register anything you give or receive on our Gift Register.

However, our Code also tells us:

“Always ask yourself if any gift or hospitality could be thought of as an attempt to improperly influence a business decision“.

This requires care and good judgement, particularly when looking at the context in which the gift is being made.

In this case, since we are in the middle of bidding for more work from this customer, could we be accused of trying to create improper influence? Would it be easy to justify this if it were made public?

These are difficult judgements to make. That’s why our Code says:

Use your judgement. If in doubt:

Always check it and record it.

Dilemma 3

I’ve provided an important government client with legitimate token gifts. He now expects a gift at every meeting and even drops hints about what he’d like! None are over my sign off limit. Should I keep bringing him gifts?

It’s an established pattern now. If we stop, we risk insulting him

Wrong. Please try again.

No, we have to stop this

Right answer because:

Our Code asks us to take care when we give or accept business-related gifts or hospitality.

There’s very good reason for this – after a certain point the difference between a gift or hospitality, and a bribe, is too narrow to call.

So our Code tells us to always ask ourselves if any gift or hospitality could be thought of as an attempt to improperly influence a business decision.

In this case, it’s not the value that is inappropriate but the frequency and volume of the gifts this client expects. It’s excessive, and it could be interpreted as a bribe.

The risk of this impression is increased because an important government client is involved.  In many countries government employees are not well paid but often have significant power. This situation increases the potential for bribery.

That’s why our Code asks us to stop and think when there is any involvement with Government Officials, including employees at State owned or controlled companies and members of Government sponsored institutions.

This doesn’t mean we should never give gifts to public employees. It does mean that we must always take the greatest care.

In this case, the gifts should stop, and senior managers need to discuss how to do this in a way least likely to insult the client.

Use your judgement. If in doubt:

Always check it and record it.

The gifts are within legitimate limits so it’s okay

Wrong. Please try again.

Dilemma 4

I’ve been working closely with a supplier on an important project which has gone well. As a thank you the supplier has given me an expensive watch. What should I do?

Get management approval and register the gift

Right answer because:

After a certain point the difference between a gift or hospitality, and a bribe, is too narrow to call.

So our Code tells us to always ask ourselves if any gift or hospitality could be thought of as an attempt to improperly influence a business decision.

We have clearly defined limits on what gifts we can give or receive. These vary across the business. What matters is that we never give or receive anything that is outside the norm, or that could be regarded as trying to exert improper influence.

We also have a standard reporting process to register gifts and hospitality we give or receive anywhere in the world. As a minimum, all gifts or hospitality with a value over £250 must have management approval and must be registered. However this limit may be less depending on local procedures.

In this case, it’s hard to see in what way the supplier may be trying to improperly influence a business decision if there are no pending contracts that he is applying for. However, the value of the gift is cause for concern.

Before accepting or refusing the gift you should explain that it is outside the norm, and that you will need to have management approval. If this is granted, you will need to register the watch. And ordinarily you should donate it to a nominated charity.

If you need to refuse the gift, then you should do immediately, along with a written explanation.

Refuse to accept it – it’s not appropriate

Wrong. Please try again.

Thank the supplier and wear it with pride

Wrong. Please try again.