Gifts hospitality and hostings policy at VisitScotland

1. Introduction

This policy provides guidance on how VisitScotland employees should act when offering or being offered gifts or hospitality. It aligns with our Anti-Bribery and Corruption Policy, which outlines the organisation’s commitment to ensuring it complies with the Bribery Act 2010.

The Bribery Act 2010 states that it is a criminal offence for anyone to give or receive any financial advantage which encourages improper performance or is intended to do so.

The Act introduced a requirement for public bodies, to demonstrate greater transparency when giving and receiving hospitality and gifts, for example, that they are proportionate, and reasonable.

The offence of bribery can be committed by an individual or by an organisation.

VisitScotland can be seen to commit an offence under the Act. Additionally, if it can be shown that a bribery offence has been committed with the involvement of a senior officer (or manager) then that person is also guilty of the bribery offence.

Therefore, VisitScotland and its employees need to take great care when offering or being offered gifts and hospitality.

2. Employee responsibilities

It is the personal responsibility of every employee to ensure they read and understand this policy and comply with it. Failure to comply with this policy may result in disciplinary action being taken.

All decisions around gifts and hospitality must be able to withstand internal and external scrutiny and must be defensible as being in the direct interest of VisitScotland and not in the interests of any individual or group of individuals.

Additionally, employees should consider how the general public or the media would perceive their acceptance of gifts and hospitality or an offer we make to someone else.

It is the responsibility of every employee to live and breathe the VisitScotland values that underpin all our work, and which align with this policy and the spirit of offering and being offered gifts and hospitality.

respectful - ambitious - knowledgeable - curious - accountable

If an employee has any questions about offering or being offered gifts or hospitality they should seek guidance from a director, chief officer or the Risk and Governance Manager.

3. Who is this policy for?

This policy is for all VisitScotland employees. It also covers any subsidiaries or others working on our behalf, such as partners, consultants, off-payroll workers and associates.

Additionally, it includes spouse, partner, family members and other friends (both business and personal). They are not allowed to offer or accept any hospitality or gifts on behalf of VisitScotland or through or from an employee or imply or infer that they can do so.

There is a separate guidance document for Board members.

4. Guiding principles

VisitScotland recognises that there are occasions when employees may be offered hospitality or gifts related to their work. It is important that all employees follow these guiding principles:

Employees must not offer or accept any gifts or hospitality that may give the impression that their personal integrity or judgement is compromised.
Employees cannot show favour or disfavour to any person or organisation.
All expenditure on hospitality and gifts should be modest and represent value for money. The cost should be appropriate and proportionate, relative to the purpose of the VisitScotland activity to which it relates.
Gifts and hospitality must not conflict with VisitScotland objectives or those of our partners, including Scottish Government.
Neither VisitScotland nor its employees can be involved in hospitality that relates to party political activity as part of their role at VisitScotland.
All expenditure on gifts or hospitality must be recorded against the project or business activity to which it relates.
All expenditure on gifts or hospitality must be approved in advance with the appropriate director or chief officer. Only approved employees can offer hospitality.
Cash (or equivalent) is not an acceptable gift and may be considered to be an act of bribery (a criminal offence). Any offer should be reported to a director or chief officer.
Accepting gifts or hospitality during a procurement process is not acceptable. Any offer should be reported to the Head of Procurement or the Director of Corporate Services.
Extra care should be taken when being offered or offering gifts or hospitality to international guests, due to cultural differences.
Accepting hospitality that includes a "plus one" (family member or friend) should be given special consideration for appropriateness. In all but exceptional cases, this should normally be rejected. Employees should seek director or chief officer approval.

The receipt of gifts and hospitality must be recorded. If in any doubt, make a declaration.

When faced with a difficult situation, where this guidance is not adequate, empoyees must seek advice from a VisitScotland director, chief officer or the Risk and Governance Manager.

5. What is meant by offering hospitality and gifts

Offering appropriate hospitality is an important part of working with external stakeholders.

The following are examples of what it might look like:

Accompanied familiarisation visits (fam trips).
Non-accompanied fam trips.
Hosting of experiential visits by travel writers, influencers and journalists, where there is no formal written contract in place.
Promotional dinners and receptions during trade or other events.
Industry dinners, trade or association events, meetings and award ceremonies, where there is food, drink and entertainment.
Conferences where there is food, drink and entertainment.
Sponsorship of events, with contracts in place that provide hospitality.
Stakeholder dinners, meetings or engagement events.
Complimentary gift or goodie bags to delegates at events, fam trips or dinners.
Complimentary marketing clothing at events.
Low value giveaway gifts for promotions.
Guest speaker acknowledgement gift.

Please note that experiential visits by travel writers, influencers, and journalists, where we have a written contract in place, is not hospitality. They are a supplier.

6. Approvals for offering gifts and hospitality

All gift and hospitality spend must be pre-approved.

Amount	Approver
Up to £1,000	Pre-authorised by Head of Department
Between £1,000 and £2,000	Pre-authoried by a Director of Chief Officer
Over £2,000	Pre-authorised by a Director of Chief Officer with additional sign-off required from Executive Leadership Group or Chief Executive

Directors and chief officers cannot approve their own gifts and hospitality.

Chief Executive expenditure can be approved by Director of Corporate Services (DCS) or other director in DCS absence.

7. Claiming hospitality expenditure (through T&S)

Only approved employees can offer hospitality. If in doubt, the employee should check with the director or chief officer that they are approved. Authorisation should be given per the values in section 6 of this policy.

Expenditure on low value, one-off hospitality can be claimed through travel and subsistence expenses. The cost must be incurred in the course of business associated with approved events, conferences or fam trips.

When claiming hospitality expenses, the name of every guest, their organisation, and an itemised bill, must be provided.

What can be claimed?

Expenditure should be reasonable and proportionate. Ordinarily, this should not exceed the values set out in the travel and subsistence policy.
Lavish hospitality is not appropriate and may create the wrong impression, if offered.
Alcohol can only be claimed when offering hospitality to a non-VisitScotland person and should be reasonable. For example, up to two drinks per person.

Please note that:

hospitality can only be offered when it has been authorised in advance
an event with only VisitScotland employees is not hospitality
careful consideration should be given when offering hospitality in situations where VisitScotland employees make up more participants than the external contacts to whom hospitality is provided
spouse, partner, other relative or friend should not be invited to VisitScotland organised and hosted hospitality events.

8. What is meant by accepting hospitality?

All hospitality over £50 should be declared. Anything below £50 does not. Accepting appropriate hospitality is an important part of working with external stakeholders. The following are examples of what it might look like:

Hosted familiarisation visits (fam trips).
Promotional dinners and receptions during trade or other events.
Eating out with visiting dignitaries, travel writers, influencers or journalists.
Industry dinners, trade or association events, meetings and award ceremonies.
Stakeholder dinners, meetings or engagement events.
Tickets to events where VisitScotland would be expected to be present and meet with other guests and the event organisers.
Attending a conference or event.

Please note that:

Where employees, or VisitScotland have paid for an employee to attend a conference or event (that has NOT been organised by VisitScotland), IT IS NOT classed as hospitality, and does not need to be declared.
If it is a VisitScotland sponsored, organised or hosted event (or table at an event), IT IS NOT classed as hospitality for any employee, and does not need to be declared.
Where we are offering hospitality at a VisitScotland sponsored, organised or hosted event (or table at an event), it should comply with the other elements of this policy as outlined in section 5 of this policy.
Where a free ticket has been provided by a third party, IT IS classed as hospitality and should be declared.

Guidance on hospitality (from external contacts)

Employees should exercise careful judgement when handling offers of hospitality.
Hospitality is a "work" activity where employees are expected to undertake their VisitScotland role as part of the hospitality.
Simple, low-cost conventional hospitality (working lunch or evening meal) is acceptable.
Regular invitations from the same source may test the principles of acceptable hospitality and employees should seek additional guidance from their director or chief officer.
For invitations which include a personal plus one (for example, spouses and friends), employees must seek authorisation from a director or chief officer in these instances.
When attending an event or conference as a speaker, it would be appropriate to accept a ticket, modest travel, food and accommodation in return for their role at the event. A small gift would also be acceptable (to the value of £50).
Careful judgement is required to ensure there is not over-representation of VisitScotland employees at a single event. Asking a director or chief officer for advice is recommended in these situations.

Fam trip situations

Where discounted accommodation rates or travel costs have been negotiated as part of a fam trip (i.e. Connect) or conference, then this IS NOT hospitality, as they have been paid for. This does not need to be declared.

However, where accommodation (or other elements) has been provided free of charge, IT IS hospitality and should be declared.

Procurement and tender situations

When a procurement or tender exercise is being planned or is underway, accepting offers of gifts or hospitality of any kind, is not acceptable.

With the exception of contract management meetings with an existing supplier, where a modest working lunch is provided as part of the meeting.

Attending conferences, workshops, webinars (or similar) hosted by a supplier and/or attended by suppliers, who may be involved in a planned or current procurement process may be permitted, but advice should be sought from the Head of Procurement or the Director of Corporate Services.

Receipt of hospitality should be recorded. If in any doubt, make a declaration.

9. What is meant by accepting gifts?

General principles

Employees must make a declaration for a gift that is over £50. If in any doubt, make a declaration.

Cash

All offers of cash or equivalent MUST be rejected and reported to the employee's director or chief officer, as it may be construed as an act of bribery, which is a criminal offence.

Cash equivalents include:

lottery tickets
gift vouchers
free holiday arrangements or vouchers
free airline tickets or vouchers
free accommodation arrangements or vouchers
free meal arrangements or vouchers
free car hire arrangements or vouchers
trade or discount cards

Please note that this does not apply in the case of vouchers that may be available or freely given to the public.

What else is not acceptable?

Tickets to events, where VisitScotland is not the sponsor or where there is no connection to the conduct of our business and the job role of the person being invited, should be refused. If in any doubt, seek clarification and approval from a chief officer or director.

Discounted travel or accommodation

Use of free or discounted travel or accommodation as part of a VisitScotland partnership contract are only permitted for the use of employees as a direct part of their responsibilities at work, they are not for leisure use and not for the use of spouses, partners, other relatives or friends.

The use of these should be closely monitored by the head of department, director or chief officer.

Small gifts

Small gifts of a trivial or inexpensive nature can be accepted.
If the value is under £50, they do not need to be declared.
Typically, this might include promotional items such as branded calendars, diaries, notepads, pens, a water bottle or eco cup.
This might include small items given as part of a prize or award.

Larger gifts (over £50)

Where an employee is offered a more substantial gift, such as a hamper or expensive wine or whisky worth over £50, a declaration should be made.

However, such gifts should not simply be accepted and kept without seeking advice from a director or chief officer.

Larger prizes or awards that are valued over £50 should be declared. Employees can NEVER accept a cash prize.

Procurement

Gifts offered during a procurement or tender process should be politely refused by all employees and reported to the Head of Procurement.

Ad hoc hospitality offered to procurement department employees, with no clear purpose for the delivery of a contract, should be politely refused.

10. What should be declared?

If an employee has any questions, they should speak to their director, chief officer, or the Risk and Governance Manager for guidance.

They must declare all accepted gifts, except those of a trivial nature. This means gifts over £50 in value.
They must declare all hospitality over the value of £50.
They must make an estimation of the value of the gift or hospitality when making the declaration.
If in any doubt, make a declaration.

Certain employees are required to submit a monthly return, even if they have received no gifts or hospitality. These are:

all directors
all chief officers
all procurement employees

11. How to make a declaration?

It is the employee’s personal responsibility to make a declaration. Employees should make their declaration within one month of receipt or when requested by management.

VisitScotland has an obligation to report on the gifts and hospitality that employees receive. The report and declaration is subject to Freedom of Information requests.

If employees have any questions, speak to a director, chief officer or the Risk and Governance Manager for guidance.

12. Review of this policy

This policy will be reviewed on a three-yearly basis or as necessary due to operational or legislative changes. This policy will be reviewed and approved by the Executive Leadership Group, Audit and Risk Committee and Board.