Policy contents
1Purpose and Scope
Corporate hospitality means hospitality of any kind provided by Albrighton Group Services Ltd, or by its employees or representatives, to persons outside the company in connection with lawful and legitimate business activity.
This policy also applies where an employee is offered hospitality by a client, supplier, contractor, prospective business partner or other person or organisation connected with the company's activities.
The purpose of this policy is to ensure that hospitality is reasonable, proportionate, transparent and never offered or accepted in a way that could improperly influence, or appear to influence, a business decision.
2Providing Corporate Hospitality
Corporate hospitality may be provided only where there is a genuine business purpose and the type, value, timing and frequency are reasonable in the circumstances.
Hospitality must not:
- be intended to secure an improper business, contractual or personal advantage;
- be offered in exchange for favourable treatment;
- create an obligation or expectation of a return favour;
- be lavish, excessive, secretive or inappropriate;
- be offered during a live tender, procurement evaluation, contract award or sensitive negotiation where it could affect impartiality;
- involve cash or a cash equivalent; or
- breach the recipient organisation's own rules.
3Approval Thresholds
All proposed corporate hospitality must be agreed in advance by the employee's line manager before any commitment is made.
Corporate hospitality expenditure likely to exceed £100 inclusive of VAT per event or per recipient must also receive prior written approval from a Director.
Approval must take account of:
- the legitimate business purpose;
- the number and identity of attendees;
- the total and per-person cost;
- the timing in relation to tenders, contract awards or negotiations;
- the frequency of hospitality involving the same parties;
- the role and influence of the recipient; and
- whether public officials or public-sector representatives are involved.
4Expense Claims and Record Keeping
Claims for corporate hospitality expenses must include:
- the business reason for the expenditure;
- the date, location and nature of the hospitality;
- the names of the persons entertained;
- the organisations they represent;
- a clear breakdown of the expenditure;
- supporting receipts or invoices; and
- evidence of the required prior approval.
All corporate hospitality expenditure will be monitored by Albrighton Group Services Ltd and recorded accurately within the company's financial and compliance records.
5Receiving Corporate Hospitality
The company does not prohibit employees from attending genuine and proportionate business events. However, employees must consider whether accepting hospitality could compromise, or reasonably be perceived to compromise, their judgement, independence or integrity.
Hospitality may be accepted only where:
- there is a legitimate business purpose;
- the hospitality is reasonable and proportionate;
- attendance is openly declared;
- the employee has obtained the required prior approval;
- the hospitality does not conflict with a procurement or commercial decision; and
- acceptance would not damage the reputation of the employee or the company.
6Lavish, Extraordinary or Excessive Hospitality
Employees must not attend lavish, extraordinary or excessive hospitality events offered by customers, clients, suppliers, contractors or other persons with whom the company has, or may have, a business relationship.
Examples may include:
- luxury travel or accommodation unrelated to a genuine business requirement;
- high-value entertainment with little or no business content;
- repeated invitations from the same supplier or client;
- hospitality offered to influence a tender, contract award, pricing decision or commercial negotiation; or
- hospitality involving family members or personal guests without a clear business justification.
Where hospitality is considered inappropriate, the employee should decline the invitation courteously and explain that company policy restricts participation.
7Employee Reporting Duties
Employees must report any corporate hospitality invitation they wish to accept to their line manager as soon as possible after receiving it.
The disclosure must include:
- the nature and estimated value of the hospitality;
- the identity of the person and organisation offering it;
- the proposed date and location;
- the employee's business relationship with the offeror; and
- any current or anticipated procurement, tender, contract or negotiation involving the parties.
8Decision-Making and Conflicts of Interest
Employees must not allow hospitality to affect their objectivity, professional judgement or duty to act in the company's best interests.
Where uncertainty exists, the employee must seek guidance from their line manager, a Director or the person responsible for compliance before accepting, offering or committing to hospitality.
Hospitality involving public officials, politicians or representatives of public bodies requires particular caution and prior Director approval.
9Breaches and Disciplinary Action
Failure to declare an invitation, obtain required approval, maintain accurate records or comply with this policy may result in disciplinary action.
Serious or deliberate breaches may be treated as gross misconduct and could result in dismissal, termination of a contractual relationship, recovery of expenditure or referral to the appropriate authority.
10Monitoring and Review
The company will monitor corporate hospitality expenditure, invitations, approvals and patterns of activity to identify unusual, excessive or higher-risk transactions.
This policy will be reviewed periodically and updated where required to reflect legal, regulatory, contractual or operational developments.
11Official Legal and Government Guidance
Relevant official sources: The Bribery Act 2010 establishes offences relating to offering, promising, giving, requesting or accepting improper advantages. The Ministry of Justice's Bribery Act 2010 guidance confirms that reasonable and proportionate hospitality is not prohibited, but hospitality intended to influence improper conduct may create bribery risk.
The UK Government's anti-bribery policy guidance for businesses explains that an anti-bribery policy should be proportionate to the risks faced by the organisation.