CODE OF CONDUCT STATEMENT AND RULES ON CORPORATE ENTERTAINMENT, GIFTS AND HOSPITALITY Scope

Transcription

1 CODE OF CONDUCT STATEMENT AND RULES ON CORPORATE ENTERTAINMENT, GIFTS AND HOSPITALITY Scope This is a SPIE UK Group policy and applies to all employees working for SPIE UK Group companies and employing entities. Introduction SPIE s Guiding Principles (as provided to all employees and available on the HR intranet) endorse our commitment to fighting corruption in all its forms and to avoid underhand or unethical practices. We aim to be reliable, trustworthy and fair in everything we do. It is therefore vital that we all operate in an open and transparent way when it comes to corporate entertainment, gifts and hospitality and avoid circumstances which could create potential conflicts of interest or breaches in law. Ethical business conduct is fundamental to the way in which SPIE UK operates and underpins how we do business. The Bribery Act 2010 sets down measures for Companies to follow to ensure they conduct business in an ethical manner. This statement is part of Company s responsive measures to this legislation. Responsibilities All employees have a responsibility to familiarise themselves with this code of conduct and ensure that they follow and comply with its requirements. Managers also have a responsibility to ensure that both they as individuals and their teams comply with and follow the code of conduct. Requirements and Process Employees should consult with their line manager to establish whether it is acceptable to receive a gift or an offer of entertainment or hospitality in advance. In the event this is not possible, then the employee must advise and give details to their line manager that they have accepted a gift, entertainment or hospitality. If at any stage an employee feels uncomfortable or under pressure to accept an invitation they should decline the gift and report their concerns to their manager. The Company has secured the services of a specialist organisation known as Safecall who will provide the platform and system by which our Corporate Hospitality, Gifts and Entertainment register is maintained. Instructions on how to complete this register are attached at Appendix 1. Page 1 of 6

2 All employees who receive gifts, entertainment or hospitality are required to declare and register what they have received. In addition employees should also register significant invitations or offerings, even if they have been declined. Failure to declare gifts, entertainment or hospitality could lead to disciplinary action. Any employee who, after discussion with their line manager, remains in doubt on whether it is appropriate to accept any offer of gift or offer of entertainment should contact Chris Rowe, the Group Compliance Officer who can provide advice. Tip to note: If the acceptance of any offer could prejudice fair and objective decision making in the future it should be politely declined. Guidelines and rules relating to gifts, entertainment and hospitality offered. It is difficult to lay down hard and fast rules without an appreciation of the circumstances and relationships. Ultimately therefore it is for each of us to assess and determine what is reasonable and what should be declined to avoid any future pressure for favours being exerted with input from senior managers if in doubt. Gifts Like many other reputable organisations our policy is that any offer of a gift should be politely declined. There may however be occasions e.g. at Christmas where gifts are simply delivered. As a guide, it is acceptable to accept such gifts up to a nominal value of 50. Examples of such gifts would be chocolate, bottles of wine and fruit. The provision on receiving such gifts would be that they are declared to Safecall and either shared out amongst colleagues or are raffled for charity. Entertainment Working business breakfast, lunches or early evening refreshments providing these are to a reasonable level (e.g. up to 50 per person) and are not too frequent with the same representative are generally acceptable. Lunches or evening meals costing over 50 per head must be declared to Safecall. Any offers which involve employees being out of the office during normal working time must be cleared with the employee s line manager in the first instance Page 2 of 6

3 Tip to note: It is not only the cost or lavishness of hospitality or entertainment but also frequency of when they are offered. Regular acceptance of these could lead to a compromising position, so be conscious of not accepting frequent invitations from the same person or Company. If in doubt, declare and register regardless of cost Hospitality The following section not only provides a guideline on hospitality but also a framework for consideration for all of the above. Generally acceptable: The following are considered to be generally acceptable but must be registered with Safecall Charity, trade or professional association dinners where host is inviting a number of external people. Domestic sporting event where the employee is one of a number of people being hosted. Corporate golf days, theatres or concerts. Invitations are normally received well in advance so that any employee should have the opportunity to raise it and clear it as ok with their Line Manager / Director. For careful consideration: Regular lunches or evening refreshments with the same person and/or company and/ or that exceed 50 per person. Out of normal hours social events involving partner attending e.g.; Ascot, Theatre, particularly if the invitation is not extended to other business people. For rejection: Extremely lavish or highly expensive lunches, dinners or corporate entertainment. Any gift or hospitality event which is considered as being a return for a favour or could be construed as an inducement for current or future preferential treatment. Any cash gift offered to the individual. Any event taking place overseas. Attendance at any event involving accommodation or significant travel cost which is funded by the host, particularly if one s partner is part of the event. Page 3 of 6

4 If an employee is not comfortable with something he or she has been offered as a gift entertainment or hospitality then, after consultation with their line manager, consideration should be given to contacting the next level of management within the organisation offering gift, entertainment or hospitality to express our concern. Offering Gifts, Entertainment or Hospitality on behalf of the Company Similar guideline principles should be applied if it is intended to offer hospitality or entertainment to business partners, clients, etc. during the course of conducting our normal business activities. Gifts In line with many other organisations it is the Company policy not to provide gifts to any third parties. Entertainment All client or third party entertainment with a cost of 50 or more per person should be cleared in advance with your line manager and then processed via expenses in accordance with the Company s expenses policy. Cost in excess of 50 per head must be registered via Safecall. Tip to note: All employees need to ensure that the frequency of entertaining the same person does not put them or the other person in a position where third parties question the intent of such entertaining. Hospitality Our delegated authorities set down approval requirements for hosting major hospitality events and should be adhered to before any invitations or offerings are made. Gifts, Hospitality and Entertainment Register As referred to above the Corporate Hospitality, Gifts and Entertainment register will be maintained via Safecall which will be to log gifts and hospitality received by employees from suppliers, subcontractors and other third parties. Details of how to declare is set out at Appendix 1. It will also be used to register any entertainment or hospitality being offered by our employees. It is a mandatory requirement that the register is completed by all employees. Page 4 of 6

5 The hospitality register will be managed by the Group Compliance Officer and will be made available for review to the Board of Directors/ the Ethics Committee on request. The register exists to protect the integrity of the employees of SPIE UK Group Companies by recording any gifts, hospitality or corporate entertainment with an independent third party. With such transparency, the Company is better placed to resist any claims of perceived influence over business decisions or potential conflict of interest. It is therefore in everybody s interest to utilise this system to avoid any future allegations of bribery or malpractice alleging undue influence in decisions or through the creation of a conflict of interest The SPIE UK Group Chief Executive Officer has lead responsibility for policy implementation within the Group and this policy is signed by the CEO to demonstrate the Board s commitment. James Thoden van Velzen Chief Executive Officer June 2011 Page 5 of 6

6 Appendix 1 SPIE UK GIFTS, HOSPITALITY AND ENTERTAINMENT REGISTER SPIE UK has commissioned Safecall Ltd. To provide gifts, entertainment and hospitality register so that all our employees are able to register the fact that they have either been offered a gift, entertainment or hospitality or that they have offered the same. This can be done in 4 straightforward steps: Go to Enter the username: SPIEUK Enter the password: 5P1Eregister This will take you into the register and you should select one of the options, enter the details as registered and submit. It is Company policy to register all gifts, entertainment and hospitality events as already outlined in the code of conduct statement. Page 6 of 6