Gifts and hospitality policy

The Gifts and Hospitality policy is a core part of our overall Code of Business Conduct for all colleagues. Together with our other key corporate policies it guides us in how to preserve our reputation and live our values.

This policy covers how you should act when it comes to the provision and / or receipt of hospitality and/or the receipt or provision of gifts while working for NHS Digital.

Remember, if you don’t comply with this policy, you could face disciplinary action from NHS Digital or your employer. If you are not directly employed by NHS Digital, your placement, secondment, or other arrangement could be ended.

The Code covers everyone who works for us, or with us. That include full or part-time, temporary, or interim roles working at any level of the organisation. It also covers anyone working on behalf of NHS Digital as a contractor, supplier, or consultant.

All the above are referred to as “colleagues” throughout this policy.

If you are offered or provide any gift or hospitality – whether accepted or not – you must declare and record it using the declaration of gifts and hospitality eForm.

You need to declare any gifts and hospitality during your business for NHS Digital, except those of minimal value.

You should only accept or provide hospitality when you can show it is in NHS Digital’s interest. That might be helping with a key business aim or to build relationships for a clear business goal, but it should not lead to potential concerns for your reputation or that of NHS Digital.

The guiding principle is that staff must not accept gifts, hospitality or other benefits of any kind which might be seen to compromise their personal or professional integrity, and that they make all necessary declarations in accordance with this policy. If you are unsure, please refer to the Code of Business Conduct Policy and or Register of Interests Policy.

If you remain unsure about whether you should offer or accept a gift, hospitality, or other benefits you must seek advice from your line manager, executive director, or the Head of Corporate Governance.

If you attend hospitality that is more lavish than you were made aware of beforehand – and if refusing it would be rude or embarrass anyone – you should accept it. But you must declare it immediately on your return to work.

You can accept any hospitality that is modest and reasonable in the circumstances without recording it.

The following examples of hospitality are unacceptable in any circumstances:

• a holiday abroad
• use of a company or private house, flat or hotel suite
• invitations to entertainment or sporting events
• attendance at awards ceremonies which are not approved and seen as fit for the business by an executive director

Acceptance of any gift offered must be justified. In general, gifts should be refused to avoid the appearance of improper influence. You can accept items that are trivial, inexpensive, or reasonable and proportionate, such as:

• low value ‘promotional’ gifts (such calendars, diaries, or items up to the value of £10)
• conventional personal gifts – such as flowers, fruit, or sweets
• low value gifts to be shared by your team such as sweets or cakes

You should return any unreasonably generous gift quickly, with a letter politely explaining our policy and that NHS Digital cannot accept it.

If the gift cannot be returned, such as perishables, your line manager may decide whether it can be shared among colleagues, given to charity, or kept by you. You should write to the person who sent it to let them know what you did with it.

You may attend commercially sponsored conferences or courses at the sponsor’s expense, except where it could be seen to potentially compromise our purchasing decisions.

To attend these events, you need the agreement of your Executive Director (or for EMT members, the Chief Financial Officer or Chief Executive Officer) before you accept. You should also record the event using the declaration of gifts and hospitality eForm. 

Hospitality you provide on behalf of the organisation to representatives of other organisations should always be modest and appropriate. Once it is agreed, you should record it using the declaration of gifts and hospitality eForm.

Meetings / training

For meetings or training courses solely for colleagues, you should keep hospitality to light refreshments only. You should always get permission from a senior colleague in the business area providing the hospitality, by setting out your business case and the expected benefits from the event in writing.

Our official events

For official events hosted by NHS Digital such as conference and seminars, provision of food and refreshment should be requested through corporate services via the Buffet Request form who will ensure costs are recorded to demonstrate best value for money.

Off-site events

Any official off-site hospitality you provide should not look to match or exceed hospitality you have received. These should be exceptional cases and, where possible, the event should be agreed in advance from the relevant executive director.

You can provide working lunches at our official meeting venues when they unavoidably take place for a minimum four hours and through the hours of midday to 2pm. Lunches as part of NHS Digital training courses for external participants are acceptable.

Special occasions

Special occasions include one-off events where you may provide refreshments. These might be held to open a building, launch a new service, or recognise excellence by a group of colleagues. They should be strictly justified by management and meet a cost limit.

If you host social events such as retirements, birthdays, or office parties they should be funded by you and your colleagues.

Refreshments at office meetings with external delegates

At any formal meetings which run for at least three hours you can provide light refreshments such as:

• tea and coffee from any free of charge stocks available in NHS Digital offices
• stock you requested through office services
• from an on-site caterer where it is the only option

NHS Digital keeps a central register of all gifts and hospitality records, managed by our Governance and Compliance team.

All colleagues should use the declaration of gifts and hospitality eForm to record any gifts and hospitality as described in this policy. You may also want to keep your own record.

If you can’t be sure of the exact value of the hospitality you record, it’s still important to record a realistic estimate.

We do an annual audit of the hospitality register to:

• review the number and sources of the entries
• analyse the value of hospitality and the gifts that were offered but declined
• analyse the hospitality and gifts that were accepted
• look at the value and nature of the hospitality we provided
• see which outside organisations offered hospitality and gifts
• see which outside organisations received hospitality