Gifts and hospitality come in many different guises and this Policy is not able to provide an exhaustive list however, below sets out some rules that must always be followed and also acts as a guide to help you make the right decision where the proposed gift/hospitality is not mentioned expressly below. Even where you follow these rules, you must still complete the Group's Gift Register as described below, as this is required for all gifts and offers of gifts.
Whenever you make or receive an offer of hospitality or a gift, even where you decline the offer, you must make sure it is logged on the Group's Gift Register. To do this, you need to complete a Corporate Gift and Hospitality Register form (the "ABC Gifts Form"), which must be signed by your line manager and promptly lodged with the Company Secretary. Your line manager's permission must be received before any hospitality event or gift is accepted.
Bona fide hospitality and promotional, or other business expenditure which seek to improve the image of a commercial organisation, better to present products and services or establish cordial relations is recognised as an established and important part of doing business and it is not the intention of the Act to criminalise such behaviour.
When accepting or giving a gift or hospitality, you should consider the intention that accompanies it. If this is, or could be, construed as influencing 'improper performance' or 'improper behaviour', then it is likely to amount to a bribe. It has become commonplace for suppliers to offer free places, accommodation and/or travel to colleagues at conferences, where the intention is that they will meet with a number of potential suppliers of products or services. Whilst these events may not cause a problem in themselves, line managers should carefully consider the implication and impression of allowing a supplier (current or potential) to fund a colleague's attendance at such an event.
- Never accept or offer monetary gifts.
- Never give the impression that the award of business is conditional upon gifts or hospitality. Nor should Halfords' colleagues ever ask or encourage a third party to provide a gift or hospitality to them.
- Gifts received from suppliers must never be accepted on a personal basis and must instead be placed in a raffle for charity, other than:
- low value items such as pens, calendars, mugs and diaries that carry a company logo, which can be retained by colleagues; or
- low value gifts where receipt is a local/cultural tradition and it would be impolite to decline (e.g. China), which can be retained by colleagues provided they are pre-approved by line managers.
- All gifts must be delivered to a work location. Gifts must never be received at home/alternative addresses.
- Samples received from suppliers will not become the personal property of any individual, unless purchased through a properly organised sample sale. Samples may be removed for evaluation as part of a colleague's role (and returned at the end of the evaluation), but only where line manager's approval is obtained through the existing samples logging system.
- Never offer or give a gift to a public official, including foreign public officials.
- Never make a cash payment to a public official other than in an official capacity.
- For certain roles it is appropriate to have dinner with a supplier (eg when on a foreign trip or at an exhibition).
- Meals and entertainment (including sporting/music events) are acceptable provided:
- they are incidental to a business-related event(s);
- reasonable in value;
- given in good faith;
- permitted under local laws and customs;
- offered infrequently; and
- line manager consent is obtained prior to the activity and a form submitted to the Company Secretary.
Gifts or hospitality should always be avoided whilst any tendering process is underway or any contract or engagement is being negotiated.
Where hospitality is being offered, we should seek to pay and/or reciprocate at least half of the time and when more than one colleague is involved and Halfords is paying, the most senior employee must pay. Any such payment may be recoverable as expenses but only if it is incurred in accordance with our Expenses Policy which must be observed at all times when paying for hospitality.