Gifts, Hospitality, Discounts, Travel, Concessions and Other Potential Conflicts of Interest

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1 Policy Title CCMT Sponsor Department/Area Section / Sector Gifts, Hospitality, Discounts, Travel, Concessions and Other Potential Conflicts of Interest Deputy Chief Constable Professional Standards Headquarters 1.0 Rationale 1.1 The public must have faith in the honesty and integrity of the Police Service. All police officers and police staff should recognise that to retain public confidence, the receiving or giving of gifts and hospitality must be limited and properly controlled. 2.0 Intention 2.1 To provide all staff with guidance regarding how gifts and hospitality may be given or received and in what circumstances such gifts and hospitality should be declined. The policy also includes guidance on discounts, travel concessions and other potential conflicts of interest. 2.2 To inform staff and the public about how to access the Gifts and Gratuities register. 3.0 General Principles For the purpose of this advice, the guidance set out below deals with all police officers, staff, special constables and volunteers, in relation to their employment with or appointment to the Thames Valley Police and not as private individuals or as representatives of other organisations. 3.1 The Code of Ethics is a Code of Practice for the Principles and Standards of Professional Behaviour for the Policing Profession of England and Wales. The Code of Ethics sets out the principles and standards of behaviour that will promote, reinforce and support the highest standards from everyone who works in policing in England and Wales. The Code requires that all staff act with honesty and integrity at all times, for example neither solicit nor accept the offer of any gift, gratuity or hospitality that could compromise ones impartiality. 1

2 3.2 No personal gifts or hospitality may be accepted from any tenderer, contractor, supplier or anyone else who may be seeking any benefit, in relation to any specific contract or other matter. 3.3 The guidance set out below is not intended to affect existing arrangements in relation to Force Sponsorship Policy. The occasions when the force will accept gifts, loans and commercial sponsorship to promote or assist in promoting initiatives and activities relative to operational policing will continue to be determined in accordance with that existing policy. 3.4 The guidance in this policy seeks to ensure transparency and conformity in accordance with the Bribery Act 2010 and any other relevant legislation. Sections 1 and 2 of the Bribery Act 2010 make it a statutory offence for anyone to offer, give or promise a financial or other advantage when the intention of the giver is to induce the receiver to perform a relevant function or activity improperly. The act makes it a criminal offence for someone to offer, ask for or accept an inducement that may be a reward for acting improperly. The organisation will also be committing an offence if they fail to prevent bribery by someone associated to them. Thames Valley Police will take firm action where breaches of the 2010 Bribery Act or the Standards of Professional Behaviour are concerned. This could include disciplinary procedures leading to dismissal, termination of contract and criminal prosecution. 4.0 Guidance, Procedures & Tactics 4.1 GIFTS Members of Thames Valley Police may provide and accept modest gifts that reflect customary exchanges between professional organisations such as plaques or shields from visiting forces or public organisations. Members of staff may also receive inexpensive gifts of a promotional character. This may include such items as diaries, calendars, low value pens and conference packs In these cases no express permission is required nor is there a requirement to record details in the register Where any gift is offered which falls outside items included in then, if possible prior approval should be obtained from the relevant LPA / OCU Commander or Departmental Head. Appendix A provides a template form for this Where such a gift is offered without prior notice and it has not been possible to obtain the necessary approval, this may be granted retrospectively by the LPA / OCU Commander or Departmental Head. Such approval should be sought at the earliest opportunity. 2

3 4.1.5 If such an offer involves an LPA / OCU Commander or Departmental Head then he/she will seek approval from their appropriate Chief Officer and this will be recorded using the template at Appendix A Gifts which are declined by any member of staff on the grounds that it is believed that to accept such a gift would be in breach of this policy should also be recorded using template A. The template will be forwarded to the Professional Standards box who will collate the gifts and hospitality register on behalf of the Force Departmental Heads and Area Commanders must satisfy themselves that acceptance is in accordance with this Policy. The following questions should be considered. Why is the gift or offer of hospitality being made? What are the background circumstances to it? Does the donor feel obliged to make the offer? What is the donor likely to expect in return? How does the intended recipient feel about the propriety of the offer? Is the gift or hospitality an integral and logical part of the business relationship or process? Is the donor in the procurement process? What could be the outcome for the Force, the police service, or the intended recipient if the offer is accepted or declined? Would the recipient feel content, and easily able to justify its acceptance to the public? The following checklist can be used by all staff to make an informed decision when they are offered a gift or hospitality 4.2 HOSPITALITY G enuine is this offer made for reasons of genuine appreciation for something I have done, without any encouragement from me? I ndependent if I accept it, would a reasonable bystander be confident that I could be independent in doing my job? F ree could I always feel free of any obligation to do something in return for the donor? T ransparent would I be comfortable if the gift was transparent to my organisation, its clients and the public? Receiving and providing hospitality Hospitality can be offered or received as a matter of common courtesy such as light refreshment, e.g. tea / coffee / biscuits. (This does not include the offer a free meal at a private or commercial premises or outlet.) Hospitality may be given or received when members of staff attend or organise functions in their professional capacity. Members of staff may 3

4 receive or provide hospitality in circumstances such as those associated with seminars and presentations as well as formal visits to or from other Forces. In these cases no express permission is required nor is there a requirement to record these details in the register Members of staff should properly consider all of the circumstances before accepting any hospitality offered. If any offer does not relate to a policing activity it should normally be declined. If it is offered from an existing supplier or one with a commercial interest, consideration should be given to the impact the attendance would have in relation to this commercial relationship With the exception of paragraphs , where an offer of hospitality is made permission must be sought from LPA / OCU Commander or Head of Department using Appendix A. Such permission can be given retrospectively where it has not been practical to obtain prior permission and considerations at will apply. Appendix A will be forwarded to the Professional Standards box who will collate the gifts and hospitality register on behalf of the Force. Commercial Considerations The force has a large number of commercial relationships with suppliers that are at various stages of the procurement lifecycle. It is essential that negotiations or tender processes are not compromised by the acceptance of hospitality or gifts. Advice should be sought from the Contracts Department regarding commercial relationships and stages of procurement. 4.3 DISCOUNTS Individual Discounts and Benefits No police officer or member of police staff will seek to obtain, negotiate or accept any individual or team discounts or benefits by virtue of their membership (temporary or otherwise) of Thames Valley Police. All staff are reminded that it is a disciplinary offence to improperly use or attempt to use their position within Thames Valley Police for private advantage. Warrant or identity cards must only be used for purposes directly related to the discharge of official duties or in circumstances otherwise approved - for example approved travel arrangements. It can never be acceptable to use a warrant or identity card to gain free access to a nightclub, sporting event or other commercial premises. Police Federation membership cards should be used in conjunction with Federation negotiated discount schemes General discounts There will be occasions where bona fide organisations offer discounts and other benefits to police officers and police staff generally. Nothing in 4

5 this policy is intended to restrict this practice as long as the benefits and discounts available are open and documented and available to all members of the service in general and not confined to an individual or select groups of individuals. These discounts must be registered on the Staff Portal Benefits Site or with the relevant staff association. The key question must always be - Does the offer in question prejudice the impartiality or integrity of individual officers, or the Service as a whole or could it be perceived to do so by members of the public A key principle will be whether the discount would be available to other large organisations To ensure complete openness, all discounts and benefits available to police officers and police staff will be registered in the manner set out below Force and National Discounts and Benefits The Staff Associations will maintain a list of nationally and locally negotiated discounts and benefits available to their members. The Reward and Benefits Team will maintain a list of nationally and locally negotiated benefits available to all staff. 4.4 Discounted / Free Travel schemes Such schemes should not be negotiated unilaterally by individuals. Any individual who is approached with a proposal should refer the details to the Reward and Benefits Team, who will advise on the appropriate way ahead All schemes will be registered with the Rewards and Benefits Team, and will be reviewed on an annual basis. Approved schemes will be kept on the Staff Portal. 4.5 Other conflicts of interest A conflict of interest may also occur with regard commercial relationships with staff and/or Officers around business interests. It is essential that such interests are declared before any involvement in a tender/quotation or supply process is undertaken. Business interests will also be declared when notifying acceptance or decline of gift or hospitality using Appendix A template. 4.6 MONITORING OF POLICY It is the responsibility of individual staff members to ensure that they notify their Department Head or LPA / OCU Commander of the necessary details, usually by template at Appendix A Alleged breaches of this policy can be reported to any line manager or direct to the Professional Standards Department. Reports can be made anonymously using the I line facility or confidential e mail facility. (See PSD intranet site). Reports can also be made to the Police and Crime Commissioner. It will be the responsibility of the Deputy Chief 5

6 Constable to decide on a proportionate response to the circumstances outlined. If the alleged breach concerns an officer of the rank of Deputy Chief Constable or Assistant Chief Constable, the report should be made to the Chief Constable. If the alleged breach concerns an officer of the rank of Chief Constable, the report should be made to the Police and Crime Commissioner The register relating to gifts and hospitality will be reviewed on a six monthly basis by the Head of PSD. The review will include communication with the department responsible for procurement. Observations regarding gifts and hospitality will be presented at the Force Security Meeting. The register will also be reviewed annually by the Office of the Police and Crime Commissioner. 5.0 Challenges/ Representations Head of Professional Standards Department Police Headquarters Oxford Road Kidlington OX5 2NX 6.0 Communication The Policy Management Unit will publish the policy on the Policy and Procedures intranet site and the Force website. The document is not restricted and can be disclosed to any interested parties. Changes or revisions to this policy will be publicised on the force intranet. 6.1 Links to Police National Legal Database/Other This policy will be published on the Policy Management Unit and the PSD Intranet sites. There will be a link from the Policy and Procedures Intranet site to the PSD Intranet site. 6.2 Implementation Strategy (Policy Impact Assessment) Unison and the Police Federation have been consulted about this policy. PAG members have agreed the content of the policy. All LPA / OCU Commanders and Department Heads will be ed about their responsibilities and a reminder will be published for all staff annually, just after the annual review. The Head of PSD has regular meetings with LPA / OCU Commanders and Departmental Heads, and will request that they ensure they remind their staff of the need to comply with this policy. 7.0 Compliance and Certification 7.1 Human Rights Audit (i) Legal Basis 6

7 This policy document is not based on any legal requirements. It is founded on what is considered to be good working practice. Human Rights Articles Engaged This policy has been drafted and audited in accordance with the Human Rights Act 1998 and the principles underpinning them. (ii) Human Rights Articles Engaged It is considered to have no potential for engaging any of the Articles of the Convention. (iii) Prohibition of Discrimination This does not have the potential to discriminate. 7.2 Equality Impact Assessment An Equality Impact Assessment has been carried out and is published with this Policy. 7.3 Management of Police Information (MOPI) This policy does not impact on the key business areas. 7.4 Data Protection The registers do not contain any sensitive personal data, and will only contain the information given by the individual staff member, together with the manager s decision. The data is held for the purpose of complying with this policy, and no other reason. Information will be held for seven years, to bring it into line with the PSD destruction policy. 7.5 Freedom of Information Act This policy and the gifts and hospitality register will be available internally to all staff and externally to the general public via the Thames Valley Police website. Data Protection Act principles will apply to the publication of the register and names of individuals will be redacted with the exception of officers and staff subject to the ACPO Police Publications scheme. 7.6 Protective Markings This policy does not require Protective Marking. 7.7 Health & Safety at Work There are no health and safety issues connected with this policy. 8.0 Monitoring and Review 8.1 Links to Best Value/PPAF/Priorities/Performance Indicators 7

8 There are no existing performance indicators which relate to this policy. This policy does not relate to the Policing Performance Assessment Framework. 8.2 Review Process This policy will be reviewed annually, in April, by the head of the Professional Standards Department. The review will take account of the following criteria:- * changes in legislation * court rulings domestic, European and Human Rights * examples of good practice from other forces or other organisations * changes in Home Office circulars * developments within ACPO policy unit * representations made by individuals and relevant organisations * relevant Equality data For use by the Policy Management Unit Only Policy Authorisation Policy signed off by: (Deputy Chief Constable) (Signature) (Date) Date created/modified Version Summary of changes made V3 05/12/12 V4 Update policy to reflect change to Office of Police and Crime Commissioner 23/01/15 V5 Updated to take into account new Code of Ethics 8

9 Appendix A GIFTS/HOSPITALITY REGISTER Section 1 Staff / officer details - to whom the offer was made. Name Rank Staff number Area / Dept Job title Declared business interest yes / no ( If yes provide brief details ) Section 2 Details of person or company offering gift or hospitality Name Address Contact Details Section 3 Details of gift / hospitality accepted or declined Description of gift / hospitality Date offered / received Accepted yes / no Reason gift / hospitality accepted or declined LPA / OCU Commander/Departmental Head or ACPO authorising acceptance or noting decline of gift/ hospitality Date Please forward completed form to Professional Standards in box 9

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