Gifts and hospitality policy

Policy owned by: Policy and Governance

Tier: 2 (Policy)

Version number: 2

Organisational Aim

This policy supports the organisational aim of “Customer - Saving lives and reducing harm” by preventing undue influence from gifts or hospitality and ensuring that all decisions are made with integrity, impartiality, and in the public interest. Having this policy is a key part of upholding trust in KFRS and those who work for the organisation. 

Introduction

To uphold integrity and public trust, KFRS has a clear set of principles related to gifts, hospitality, and sponsorship. This policy sets out those principles and the associated rules.

The ethical standards that inform and underpin this policy come from the Seven Principles of Public Life (the Nolan Principles) which, in turn, form the basis of our Code of Ethical Conduct. Colleagues must follow this policy in accordance with our Code of Ethical Conduct and relevant legislation, including the Bribery Act 2010.

To ensure there is no conflict, or perception of any conflict, between official duties and private interests, the acceptance of gifts, hospitality or sponsorship must not compromise, or give the impression of compromising impartiality, reputation or values of KFRS and its colleagues.

Definitions of gifts, non-gifts and external hospitality 

For the purposes of this policy these are defined as follows:

Gifts

Something given to or directed towards a particular person or group of people without payment. The giver intends that individual (or group of individuals) to be the recipient(s). The intent, audience, situation and context are key in determining what is a gift. Gifts can be physical objects, including money or items with a monetary value (such as vouchers and coupons), or access to events and experiences. For this policy, ‘hospitality’ is defined as a type of gift, as it is directed towards the intended recipient (see definition of hospitality below).

Non-gift items

These are things that are made freely available, offered to an undefined group ("anyone who passes by"), with no specific individual in mind. As with gifts, the intent, audience, situation and context are key in determining a non-gift item. Here the intent is broad, often promotional or for general goodwill. The most frequently occurring example of such non-gift items is at a conference where supplier stands offers free pens, notebooks, or doughnuts for attendees.

External hospitality

this refers to the provision of food, drink, entertainment, accommodation, travel, or any other service or benefit offered freely or at a reduced cost by an external party. Hospitality is classed as a form of gift and it includes events such as meals, access to receptions, sporting or cultural events, conferences, or site visits where the individual is not paying the full market value. In the private sector, hospitality may be offered while building professional relationships, but within a public sector context it must be carefully managed to avoid any perception of impropriety, bias or undue influence.

This is different from food and (non-alcoholic) drinks provided as part of a recognised package of attendance at an approved, work-related conference or event (e.g. an NFCC conference).

As with the Code of Ethical Conduct, in assessing these situations, colleagues are to apply the principles set out in this policy, along with their common sense and an appreciation of the situation and context.

The key question to ask yourself is “How would me accepting this look to my team, line manager, wider colleagues and the public we serve?”.

The Tier 3 Procedure and Guidance provides some example scenarios to aid colleagues’ understanding of this. 

Service policy

1. Gifts
  1. It is the policy of KFRS that colleagues will not accept any gifts or hospitality from third parties.
  2. The only exceptions to this are items such as stationery, novelty items, fire service or organisational memorabilia, non-alcoholic drinks, food items including cakes, biscuits, and confectionery up to the value of £10 (including VAT). If more than one item is given, then the total value of all items cannot exceed £10 per recipient.
  3. Any gift exceeding this value must be declined. If you think that declining the gift at the time would cause a problem (e.g. a diplomatic or fire service exchange), then you may accept it, but the gift must be submitted to the Clerk to the Authority as soon as practicable. If it is not practical to do so (e.g. a perishable food item) then it must be disposed of as soon as possible (but not used or consumed) and reported by email to the Clerk of the Authority.
  4. We do recognise that operational crews may be given food gifts such as tea, sandwiches cake etc whilst they attend an incident from concerned and grateful members of the public. These are permitted as they are not meant as payments or inducements.
2. External hospitality and entertainment
  1. Attendance at any corporate hospitality events (e.g. sports matches or events, activity centres, museums, theatres, opera, ballet, concerts, garden parties or other forms of entertainment) is not permitted.
  2. Even if it falls within acceptable items under point 1.1 above, hospitality must never be accepted if it could influence or give the impression of influencing, any decisions KFRS might make. Examples of this would be situations related to fire safety inspections and enforcement or selection of suppliers.
  3. This is different from when colleagues attend an externally organised seminar, training or similar type of event for which food and (non-alcoholic) drinks are provided as part of the attendance package for that event, which is acceptable. Examples of this could be with an NFCC conference, paid for seminar or training course.
  4. Please refer to the Tier 3 Procedure and Guidance for information about hospitality provided by KFRS.
3. Non-gift items
  1. It is recognised that colleagues will attend events, such as conferences, where items are made freely available with no specific individual in mind. As with gifts, the only types of non-gift items that are allowed to be obtained are stationery, novelty items, non-alcoholic drinks, food items including cakes, biscuits, and confectionery.
  2. Non-gifts are only allowed up to the value of £10 (including VAT), based on a reasonable estimation on value. If more than one non-gift item is obtained, then the total value of all items cannot exceed £10 per person.
  3. Colleagues must behave with self-control and remember the £10 threshold is a limit and not a target. For example, taking only one doughnut valued at £2 rather than five doughnuts, even though the total value of five would still be within the £10 limit.
4. Electronic devices
  1. Electronic devices with the ability to capture, store and transmit data (e.g. mobile phones, USB drives, smart watches, smart glasses, laptops, tablets and any other such similar devices), must not be accepted. This is because of the potential cybersecurity risks and the possibility of embedded surveillance tools or malware.
  2. This is regardless of value and so includes devices under the £10 threshold.
  3. If you think that declining the gift at the time would cause a problem (e.g. a diplomatic or fire service exchange, or a risk of causing offence), then the gift must not be switched on or used and must be submitted to the Clerk to the Authority as soon as practicable.
     
5. Money
  1. Money, or monetary gifts (including vouchers, tokens or gift cards), of any value, denomination or currency must not be accepted at any time.
  2. This includes even when you think declining the gift at the time would cause a problem (e.g. a diplomatic or fire service exchange, or a risk of causing offence). You will be fully supported in this by CMB.
  3. When declining an offer of money, suggest the person make a donation the Fire Fighters Charity instead (firefighterscharity.org.uk).
6.  Donations, grants and sponsorship
  1. In accordance with the Donations and Grants (Community Groups, Associations and Charities) Policy, donations and grants will not be paid to organisations where a KFRS colleague who is covered by the Code of Ethics for Senior Managers, or a Member of the Fire Authority, is involved in a financial decision making or a trustee role.
  2. For more information about this, refer to the Donations and Grants (Community Groups, Associations and Charities) Policy and its underlying Tier 3 guidance.
  3. When colleagues seek sponsorship for a charity event they are participating in (e.g. marathon or bike ride) this must not compromise, or give the impression of compromising, the impartiality, reputation or values of KFRS and its colleagues. Examples of this would be with a colleague receiving sponsorship from a current or prospective supplier or seeking sponsorship for an event or charitable cause that is not consistent with the values of KFRS. For more information about this, refer to the Donations and Grants (Community Groups, Associations and Charities) Policy and its underlying Tier 3 guidance.
7. Reporting gifts, hospitality and sponsorship
  1. All gifts, hospitality and sponsorship offers, whether accepted or declined, that are received in relation to a colleague’s role in KFRS must be reported by email to the Clerk to the Authority ([email protected]) who will record them in the hospitality register. Please see the Tier 3 Guidance and Procedure for more information about this.
  2. Both reporting and recording must be done as soon as reasonably practicable.
  3. All enquiries or requests for decisions relating to gifts, hospitality, and sponsorship must be sent to the Clerk to the Authority who will refer them to CMB.
  4. Non-gift items, which are only permitted where the value is under £10, including VAT, do not need to be declared.
  5. Food and non-alcoholic drinks given to firefighters at the scene of an operational incident as part of publicly provided welfare can be accepted and are exempted from this policy.

Relevant legislation and Codes of Practice

Underlying Tier 3 Procedure and Guidance

Procedure and Guidance for the Gifts and Hospitality Policy

Guidance for Donations and Grants (Community Groups, Associations and Charities) Policy

Data inputs and controls

KFRS Hospitality Register

Security marking

Not protectively marked.