Visit Scotland | Alba

1. Introduction

This policy provides advice for VisitScotland around the provision and receipt of gifts or hospitality.

It fits under the auspices of the Anti-Bribery & 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. It also introduced a requirement for companies and public bodies, to demonstrate greater transparency when providing/receiving proportionate hospitality and reasonable gifts, to/from external business contacts, stakeholders and suppliers.

The offence of bribery can be committed by an individual or by a ‘body corporate’. It follows that VisitScotland, as a ‘body corporate’, can itself commit offences under the Act. Additionally, if it can be shown that a bribery offence has been committed with the consent, or connivance, of a senior officer of the body corporate (or a person purporting to be a senior officer) then that person is also guilty of the bribery offence.

Consequently, the provision of anything which might be deemed an incentive needs to be considered with great care, and as a result VisitScotland has introduced a detailed combined policy to cover the provision and receipt of gifts and hospitality which aligns to the VisitScotland Anti-Bribery & Corruption Policy.

2. Who is this policy for?

This policy is intended to provide advice to all members of VisitScotland Group "Board" and "Staff" which are employees of VisitScotland and all subsidiaries and external people acting on behalf of VisitScotland (ie suppliers, partners, consultants, contracted staff, associates, etc).

It is intended to cover anyone working for, or with VisitScotland, and who, in the course of their day-to-day work or as a result of their employment, may make or receive offers of gifts and hospitality.

Staff are reminded that any spouse, partner or other associate (business or personal), is not allowed to offer/imply to offer, or provide/receive, gifts or hospitality to/from third parties, on behalf of VisitScotland.

All decisions made by individuals on the provision/receipt of gifts and hospitality must be able to withstand both internal and external scrutiny and must be defensible as to being in the direct interest of VisitScotland and proportionate to that interest.

Freedom of Information (FOI) requests may place VisitScotland under additional scrutiny in this matter. All must be aware of the perception/interpretation that can be placed upon abnormal levels of hospitality provided/received, for whatever reason.

3. General guiding principles

Staff must give/receive gifts or hospitality only in line with this policy. It is every individual’s responsibility to be aware of and understand this policy.

Staff must not give/receive gifts, which might be perceived as compromising personal judgement or integrity, or which may influence, or be perceived to have influenced a business decision. When acting in an official capacity, board and staff should not give the impression that they have been/may have been attempting to influence, through gift or hospitality to show favour or disfavour to any person/organisation.

Corporate gifts and hospitality must not be provided/received for party political activity, or events that conflict with VisitScotland objectives, those of our partners, or the Scottish Government

Corporate hospitality that is provided should be modest and represent value for money in committing public funds. They should be proportionate in value and appropriate in the nature of the hospitality, and with regard to the budget of the project or initiative within VisitScotland.

The provision of any gift or hospitality must have clear objectives, with the approved expenditure being recorded against the project, so that the impact can be measured accordingly.

The provision of hospitality and gifts should be agreed in advance with the appropriate Head of Department, whose responsibility it is to ensure that all hospitality/gifts are compliant with this policy.

Under no circumstances should anyone provide/offer to accept a cash payment on behalf of VisitScotland or even imply/be perceived to imply that they can do so.

Staff must not offer/be perceived to offer to make a facilitation payment, that is a payment to a third party to expedite a business transaction or activity. Such payments are illegal.

Staff must not permit third party suppliers to offer/receive/imply to offer anything on behalf of VisitScotland, unless specifically contracted to do so.

No gifts or hospitality of ANY kind should be accepted/ given to any person/organisation involved in the procurement process of a contract with VisitScotland. It is imperative that no criticism can be levelled against staff or VisitScotland regarding bias to a company/supplier/individual, and that all procurement decisions and negotiations are based solely on achieving best value for money for VisitScotland (and the taxpayer).

Staffmust not offer/promise/be perceived to offer a gift/hospitality to a foreign public official (other than token low value gifts), in the course of negotiating, obtaining or retaining business on behalf of VisitScotland. A foreign public official includes elected or appointed legislative, administrative or judicial persons of any kind. It also includes any person who performs public functions in a branch of the national, local or municipal government, or for any public agency or public enterprise.

Staff must record all accepted gifts except those of a trivial nature (see section below).

Staff must record all accepted hospitality above the value of £50.

Staff must refer to their Head of Department, when faced with a situation for which there is no adequate guidance available. In the absence of their Head of Department, advice should be sought from the Director of Corporate Services or the Head of HR. 

4. The provision of corporate hospitality & gifts

Representatives engage with key contacts at many different types of events each year. Corporate hospitality is considered to be a necessary and valuable tool to raise awareness of the organisation’s activities. Such authorised expenditure supports our strategy, and is both proportionate and reasonable, and is seen as having a positive influence on the economic benefit of tourism to Scotland.

Acceptable business activity

The arrangement of marketing and promotional events for Scotland (embraced under the generic banners such as Scotland – The Perfect Stage or Scotland is Now or Only in Scotland) are key activities in respect of such engagement/hospitality. They are principally negotiated by staff and there are often event support packages focused on the provision of "hospitality". This may include entertaining, meals, and complimentary tickets to events.

Major activities which surround the hosting of Travel Trade operators and members of UK and international media, as part of the promotion of Scotland may include:

  • Hosted familiarisation/study visits.
  • Non-hosted familiarisation/study visits.
  • Contributions towards the cost of "experiential" visits by travel writers, bloggers, vloggers and journalists.
  • Promotional receptions and dinners during trade fairs, business missions and other promotional events.
  • Provision of free airline tickets/ accommodation to visiting dignitaries, travel writers, bloggers, vloggers, journalists, etc.

Other promotional activities may include:

  • Industry dinners, award ceremonies, prize presentations where VisitScotland provides food/drinks.
  • Conferences where VisitScotland provides food/drinks – ie National Events Conference.
  • Stakeholder dinners/meetings/engagement events.
  • Industry groups/associations events and meetings, where VisitScotland provides food/drinks.
  • Complimentary gifts/ ‘goodie bags’ to delegates at familiarisation trips/receptions, dinners and events.
  • The provision of complimentary ‘VS marketing’ clothing at events.
  • Full or part sponsorship of industry events ie Scotland Food & Drink Awards, HITA Awards, etc.
  • Low value ‘giveaway’ gifts at consumer promotions and Travel Trade Fairs eg branded bags, pens or golf tees.
  • Acknowledgements to consultants or guest speakers, or other contributory volunteers, in the form of a token gift of modest value, with documented prior approval from the Head of Department or Senior Management.

Control of spend on gifts and hospitality

  • Up to £10,000 - Pre-authorised by Directors, Leadership Group or Heads of Department
  • Over £10,000 - Pre-authorised by the Chief Executive Officer.

A new digital process will be established to allow this activity to be efficiently undertaken. Until such time as this is established, pre-approval should still be obtained, and email is suggested.

If the provision is part of a larger event/activity, then this pre-approval process must still take place to allow the organisation to understand its potential risk and outlay in this area.

Note: In all instances the appropriate procurement and grant provision rules should be followed.

5. Hospitality claimed through the travel & subsistence process

Expenditure is expected to be of a relatively low value with costs being incurred in the ordinary course of business associated with approved entertaining, conferences, Board meetings and familiarisation trip costs etc.

Staff are reminded that by claiming such expenses they are certifying that the expenditure has been incurred on VisitScotland business, and in so doing, that it was compliant with this Policy.

Such hospitality should not be offered solely as a return gesture or be seen to be of a recurrent nature.

Expenditure on external one-to-one hospitality should be clearly identified as such and charged to the appropriate expense codes.

When hospitality is claimed, the name of each guest and their respective organisation must be stated for tax purposes.

 

What Can Be Claimed What Cannot Be Claimed

Hospitality is only to be used by Board and pre-authorised staff* when it is considered in the interests of VisitScotland to maintain a good working relationship with individuals and/or other organisations.

Alcohol can only be claimed when undertaking hospitality.

It should be reasonable and proportionate.

* Directors can authorise staff via e-mail and notify the Head of Finance.

Hospitality by any VisitScotland staff that has not been pre-authorised.

Hospitality when only VisitScotland staff are present, or when VisitScotland Staff are in the majority (ie in excess of 50%)

Hospitality for spouse, partner, friend, relative or associate.

It will not be possible for staff to claim for alcohol when not undertaking hospitality.

6. The receipt of hospitality

For the purposes of clarity:

  • In all cases of accepted hospitality, the details should only be recorded if over £50. 
  • Attending an event/conference where VisitScotland has paid for staff's participation ticket, is NOT classified as hospitality.
  • Attending a VisitScotland organised event is NOT classified as hospitality. 
  • Attending a free event organised by someone other than VisitScotland, any food or drink IS classified as hospitality and it should be recorded appropriately if it is deemed to exceed the £50 reporting limit (even if staff are working). 

Staff must exercise careful judgement when handling offers of hospitality.  Whilst it can be embarrassing to refuse hospitality, there is a need to distinguish between simple, low cost conventional hospitality, (a working lunch or evening meal) compared with more expensive and elaborate hospitality, which, if accepted, should be reported if the deemed value exceeds £50.

Frequent, regular or annual invitations to events or functions, particularly from the same source and where extensive hospitality is involved, may severely test the principles.  Therefore, due consideration should be given to whether acceptance would open staff or VisitScotland to criticism and should always be reported if the deemed value exceeds £50

However, if attending such an event as a speaker, any tickets/invitations/accommodation, (other than a working lunch, and light refreshments, or an evening meal) provided free by organisers/sponsors, should be recorded as hospitality received if the deemed value exceeds £50. 

As a general rule, invitations of hospitality, by a commercial firm as a public relations exercise, which are extended to VisitScotland as a whole, can be accepted by a nominated officer and appropriately recorded in line with this Policy.  These are less likely to attract criticism than personalised invitations to individual employees. This raises the profile of the invitation as being for the benefit of the organisation rather than the individual. However, in these instances, it is essential that the number of invitations accepted by VisitScotland staff is not so great as to cause adverse comment.

Heads of Department need to manage situations carefully, and if in doubt as to the proportionality of attendance at these events, then consideration should be given to ensuring that such invitations should be opened up to the organisation as a whole, rather than being specifically associated with an individual(s) and/or department, or for the offer to be politely declined.

It is particularly important to ensure that VisitScotland is not over-represented at a third-party event or function, by way of invitation.  Care should be taken to manage our representation and the person invited should make every effort to determine from the host as to how many other VisitScotland individuals may have received similar invitations and advise their Head of Department accordingly.

In all instances where an invitation may be considered excessive, or goes beyond conventional hospitality, staff should seek the approval of the Head of Department, Corporate Services Director or Head of HR.

Procurement & supplies

Where a contract is being negotiated, hospitality of any kind, including attendance at events hosted by suppliers or contractors, must not be accepted by any person who is part of the procurement process.

The following provide guidance on Procurement matters

NOT ACCEPTABLE

  • ANY invitation, other than as a guest speaker received DURING the procurement process.
  • ANY provision of overnight accommodation, travelling costs or subsistence by a supplier/contractor (or a potential supplier/contractor) of goods/services to VisitScotland DURING the procurement process.
  • ANY invitation of whatever nature extended to a spouse/partner or associate of a member of the organisation.

ACCEPTABLE AND RECORDABLE

  • Free working lunches
  • Low cost evening meals/drinks after work
  • Free tickets provided for attendance at events run by voluntary and business organisations.
  • Free invitations for attendance at annual dinners organised/sponsored by professional or trade bodies, business firms or voluntary organisations.
  • Free tickets for attendance at events (maintaining a stand etc), where VisitScotland is one of the sponsors.
  • Free invitations to an establishment wine or food tasting, etc.
  • Any invitations to frequent or more expensive social functions where the deemed value exceeds £50.

Attendance at such is considered an integral element in building and maintaining such relationships and any hospitality received is likely to be reasonable and proportionate, and therefore acceptable, though reportable, and appropriate for the person attending.

7. Acceptance of gifts

Cash or cash equivalents

All offers of cash or cash equivalents made by suppliers, contractors, service users or their relatives to a member of Staff, should be declined and reported to their Head of Department or the Director of Corporate Services as it may be construed to be an act of bribery.

This includes:

  • Cash or Cheques
  • Lottery tickets
  • Gift vouchers
  • Free holiday arrangement/vouchers
  • Free airline tickets/vouchers
  • Free accommodation arrangement/vouchers
  • Free luncheon or dinner arrangement/vouchers
  • Free car hire arrangement/vouchers

The above does not apply in the case of vouchers, etc, which may be freely available/given to the public.

Small non-cash gifts

Gifts of a small, seasonal or inexpensive nature can be accepted and reported if the deemed value is over £50. If there is any doubt as to whether the acceptance of such an item is appropriate, the matter should be referred to either their Head of Department, the Director of Corporate Services or Head of HR, no matter the value.

Examples which are acceptable and will fall under the deemed value of £50 threshold and are therefore not recordable

  • Calendars/Diaries
  • Flowers
  • Chocolates
  • Mousemats
  • Bottle of wine, or equivalent
  • Water bottle/eco cup 

Exceptional cases

There is never an exception in the case of cash gifts, these should always be refused and reported in line with this policy.

All other gifts should be reported in line with this policy.

Conferences, professional & trade association events

If anyone is attending or speaking at a conference or event, as a representative of VisitScotland, then ALL offers of cash or cash equivalent, made by the organisers/sponsors should be declined and reported in line with this policy.

Small non-cash gifts can be accepted such as those as listed above.

Attendance as an invited guest (on behalf of VisitScotland) at a conference or event sponsored by an organisation may be accepted and reported, if it exceeds the deemed value of £50:

  • Free attendance.
  • Any luncheon/dinner provided.
  • Any overnight accommodation etc, provided.
  • Free course material.

However, ALL invitations, etc, received DURING any negotiations for a procurement contract with said organisations should be declined and reported to a staff member's Head of Department and the Director of Corporate Services.

Note: where VisitScotland has paid for a staff member to attend a conference or event, then this is not considered to be hospitality.

Trade or discount cards

It is expected that everyone will use the Corporate Travel Agent to make travel arrangements and that no-one will make arrangements to make personal benefit at the expense of the public purse.

NOT ACCEPTABLE

Trade or discount cards, (other than those negotiated by VisitScotland) by which an employee might benefit from the purchase of goods or services at a reduced price, are classified as cash and should be politely declined.

ACCEPTABLE AND NOT RECORDABLE

Private use of accumulated value/rewards points derived from the authorised business use of such VS cards/schemes to book flights/hotels/car hire or enjoy any other benefits/facilities provided by any associated, or linked organisations.

Use of the cards/schemes in the ordinary course of business to enable staff, carrying out the duties of

their job, to avail themselves of the facilities, such as entrance to special departure lounges or achieve priority booking status/check-in, etc.

Use of such accumulated rewards/points derived from VisitScotland business use in the reduction of expenditure on legitimate VisitScotland business to maintain cost efficiencies.

Discounted/free travel or hotel accommodation arrangements

NOT ACCEPTABLE

Personal use (ie anything other than on VisitScotland business) of discounted or free airline tickets, or any form of discounted or free travel/accommodation arrangements, derived from bookings made on behalf of VisitScotland. This excludes vouchers that may be freely available to the public, via newspapers or the postal service.

ACCEPTABLE but NOT Recordable

Use of free ticket or discounted rate arrangements for airline flights, or accommodation costs negotiated as part of a VisitScotland partnership deal. Such flights/accommodation arrangements are for the SOLE use of VisitScotland staff (NOT spouse/partners etc) and are regarded as mitigating overhead costs in the normal course of the business of VisitScotland. 

These arrangements should be under the primary control of a member of the Head of Department within the negotiating department.

8. Awards or prizes

Staff should consult their Head of Department or Director of Corporate Services, if they are offered an award or prize in connection with their official duties. They should either;

  • Accept it on behalf of VisitScotland
  • Accept it on behalf of VisitScotland, and donate it for an official charitable purpose, notifying the presenter that it will be so donated.

This ONLY applies to awards/prizes received personally in the context of work carried out in connection with VisitScotland, rather than an award given direct TO THE ORGANISATION, and does not include any awards/prizes etc, for personally undertaken achievements with no connection to VisitScotland.

Please note: In all cases accepted awards or prizes should be recorded. Cash or equivalent should never be accepted.

9. Registering gifts and hospitality

In order to counter any possible accusations or suspicions of breach of the rules of conduct, a record

  • will be kept by VisitScotland of ALL offers of gifts, hospitality, awards and prizes (other than
  • small non-cash gifts of nominal value), that have been accepted within the organisation.

They must complete the required form and submit the form to the Finance Department on a monthly basis. A nil value return is not required.

It is the intention of Management that a new digital system be introduced which will make the process more efficient for all. The existing system remains in operation until such time as the new system is launched.

It is a staff member's individual and sole responsibility to complete the necessary submission for anything they have received.

The Register will be reviewed by the Director of Corporate Services, and the Audit & Risk Committee on an annual basis.

If it is discovered that any gifts or hospitality have been accepted, but have not been disclosed at the appropriate time, it may be considered to be a disciplinary offence.

10. Review of policy

This Policy will be reviewed on a three-yearly basis or as necessary due to operational, legislative or risk assessment changes.

11. Associated policies / guidelines

  • Travel and Subsistence Guidelines
  • Anti-bribery and Corruption Policy
  • Whistleblowing Policy
  • Disciplinary Policy
  • Alcohol & Drugs Misuse Policy
  • Fraud Policy

Related links

Our procurement policy

Read about how we promote fair, responsible competition whilst getting the best value for money.