Entertainment and gifts

Overview

Why do we need this policy?

The Bank’s position as a public body means that it has to apply, and be seen to be applying, high standards of ethical behaviour.

Under the Bribery Act 2010 it is an offence for a Bank employee to offer, promise or give a bribe to another person, or to request, agree to receive or accept a bribe from another person, and individuals may be subject to prosecution.

Who does this policy apply to?

This policy applies to all of us working at the Bank. This includes consultants, contractors, and agency staff.

The Governors, Executive Directors, other members of the MPC, FPC, PRC and Advisers to the Governor are also covered by the rules. The Secretary acts as their point of reporting and reference.

What you must know or do?

The following rules requirements apply to all staff. If the acceptance of entertainment or gifts by an individual member of staff was challenged it would be necessary to show that acceptance was appropriate, consistent with the Bank’s rules, and did not give grounds for concern that personal judgement or integrity had been compromised.

Executive Directors and Directors may, where necessary, adapt the rules to suit particular circumstances of the work of their area. But these rules are the minimum. Stricter rules will usually be required when staff have a direct commercial involvement with an organisation or individual through their work; for example, purchasing, tenders and contracts, financial market operations. Business areas will also need to consider their approach to the receipt of entertainment and gifts when individuals are heavily engaged in activities or projects over particular periods which might result in unusual levels of business contact. Where no local variations are in place, these rules apply.

Prior approval from the Secretary must be sought before the implementation of business area rules.

1: Entertainment

1.1. Offers of entertainment^{footnote [1]} may be accepted or made where they are necessary to develop and maintain outside contacts relevant to work responsibilities. They should be restricted to working lunches or similar events as far as possible.

1.2. You should decline any offer of entertainment that might be seen as excessive, as putting the recipient under an obligation, as offered to influence a procurement decision, as in doubtful taste or as liable to bring the Bank’s name into disrepute. ‘Excessive’ includes offers of entertainment that are time consuming, over-frequent (part of a pattern of invitations to one area from a particular organisation that, taken together, appears inappropriate); or disproportionately lavish. Invitations to expensive events should be declined.

1.3. Please decline invitations from firms regulated by the Bank or the FCA, or from professional advisers without the prior agreement of an Executive Director or Governor (which may be a general permission rather than case by case).^{footnote [2]}

1.4. Business contacts may also be personal friends. For the purposes of these rules, any hospitality offered and accepted in an official Bank capacity (eg whether through your day to day Bank role, or your role on a Bank employee network) and not a personal capacity should be seen as institutional and reported accordingly (eg where a firm is paying for the hospitality). Invitations from personal friends that are not offered in an official capacity and do not involve corporate hospitality (ie not paid for by a firm) do not need to be reported.

1.5. If you are invited to an event accompanying your spouse or partner, you should treat the invitation as though it was to yourself at the Bank and apply these rules accordingly. For example, you should consider if the invitation is from a Bank or FCA regulated firm; from professional advisers; or from an organisation that you have contact with as part of your role.

1.6. If in doubt about whether it is appropriate to accept an invitation, please discuss with your manager/Head of Division (HoD) or seek advice from the Secretary’s Department before accepting the entertainment offered.

2: Gifts

2.1. You should discourage the presentation of gifts as far as possible. However, where refusal would cause offence or embarrassment, and when the value is modest (see below), a gift may be accepted. Sometimes gifts are virtual or take the form of ‘prizes’ offered by a corporate entity when you are on Bank business. The same rules apply.

2.2. You must not accept cash or retail vouchers (except for commemorative coins/specimen notes), or electronic devices (for security reasons).

2.3. Heads of Division may permit recipients to keep items up to a value of £30. Approval from the Secretary (or the Conflicts Team) must be obtained if you wish to retain a gift over £30 and under £100 in value. Gifts with a value over £100 cannot usually be retained and should be passed to the Community Team for the benefit of charitable organisations. You do not need to report the acceptance of trivial or ephemeral items, such as calendars and diaries. No gifts worth more than £30 (such as hampers or ‘goodie’ bags) should be broken up into smaller portions to comply with the £30 rule.

2.4. Heads of Division, line managers and recipients should ensure they are not authorising/accepting gifts that together have an accumulating effect for an individual.

2.5. Gifts where the value is less than £30 and a HoD has given permission for it to be kept should be given to charity directly by the staff member if not retained. Any gifts not retained where the value is over £30 should be passed to the Community Team for disposal to, or to the benefit of, charitable organisations (unless the point below is applied).

2.6. Heads of Division may set up local arrangements for raffling or otherwise disposing of gifts of a value of less than £100 for the benefit of charitable organisations. Gifts whose value is likely to be in excess of £100 should be passed to the Community Team for the benefit of charitable organisations.

2.7. You must not solicit gifts from a Bank supplier for yourself or for any other purpose.

3: Speaking engagements

3.1. As a general rule, invitations to speak at a commercially sponsored conference should be accepted only when the relevant Heads of Division has agreed that the occasion provides a good opportunity for the Bank to communicate information to a relevant audience. Please refer to the Issuing Press Releases and Speeches – Appendix 2 (Decision tree for speaking engagements).

3.2. If the organiser offers to meet travel and/or accommodation costs, then provided the condition in the point above is met, this can be accepted.

3.3. Where fees and expenses are offered for speaking engagements and other appearances, they should be accepted and surrendered to the Bank; this includes where the option of a fee or gift is offered. Any gifts received in respect of speaking engagements/articles/media appearances should be dealt with in accordance with the requirements on gifts set out above.

3.4. The application of this policy will be in accordance with the relevant data protection legislation. For information on how the Bank processes your data, please see our staff data privacy notice.

Key policy requirements

What support is available to help you comply with this policy?

The following documents will aid your understanding of, and compliance with, this policy:

• Our Code.

What is the impact of non-compliance?

If you realise you have breached – or suspect that you might have breached – a requirement in this policy please tell AskCompliance as quickly as possible, so that the issue can be reported and redressed under the Bank’s Breach management policy. The Bank gives credit for you taking prompt responsibility for your mistakes. You should be aware that failing to discharge your responsibilities could lead to disciplinary or other action.

January 2024