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Supplier Gifts & Hospitality Policy

Tim Barrett
Updated

Version: 1 | Date: November 2025

Policy Aims

This policy ensures transparency, compliance, and protection of the company’s interests in relation to any hospitality, gifts, or supplier-sponsored events. It is designed to prevent conflicts of interest, safeguard ongoing tender processes, and maintain integrity in supplier relationships. Please see the attached Supplier Gifts and Hospitality Policy,  which was last updated in November 2025.

What’s Covered

  • Roles and Responsibilities
  • Definitions
  • Pre-Approval
  • Logging and Compliance
  • Accepting Gifts
  • Incentive Trips
  • Standards of Behaviour
  • Breach of Policy

Roles and Responsibilities

  • Colleague: Declare any gifts or hospitality and uphold standards of behaviour.
  • Line Manager: Provide advice and support.
  • Ops Board: Assess gifts/hospitality and approve before acceptance.
  • Group Commercial Director: Review approval requests and oversee compliance tracker.
  • Procurement Team: Maintain Hospitality & Gifts Tracker.

Definitions

  • Gifts: Tangible objects such as branded merchandise, hampers, festive gifts.
  • Hospitality: Events including entertainment, travel, accommodation, meals, tickets.
  • Bribery: Attempt to influence decisions through gifts or money.

Policy Requirements

Pre-Approval

Any supplier-funded hospitality or event must be pre-approved by the relevant Ops Board Member. Requests must include:

  • Event details
  • Supplier involved
  • Estimated value
  • Attendees (including supplier attendees)

Copy the Group Commercial Director and PA for oversight and entry into the Hospitality & Compliance Tracker.

Logging and Compliance

All approved hospitality, events, and gifts must be recorded in the Hospitality & Gifts Tracker, capturing:

  • Colleague name
  • Date of event or gift
  • Supplier name
  • Approval details and date

Accepting Gifts

Gifts may be accepted if:

  • Not intended to influence decisions
  • Given openly and transparently
  • No cash or equivalents (e.g., vouchers)
  • Appropriate to occasion (e.g., Christmas gifts)
  • Logged in the Hospitality & Gifts Tracker

Value must not exceed £75 per occasion unless approved by Ops Board.

Incentive Trips

Supplier-funded trips must be:

  • Agreed and signed off by Procurement
  • Pre-approved by Ops Board
  • Logged in the Hospitality & Gifts Tracker

Standards of Behaviour

Hospitality is considered an extension of work. Key standards:

  • Responsible drinking: Stay within limits.
  • Driving: Ensure legal alcohol limit or arrange transport.
  • Drugs: No illegal substances.
  • Respectful behaviour: Professional and inclusive.
  • No bullying or harassment: Policy applies at all times.
  • Reputation: Avoid actions that damage company image.
  • Confidentiality: Do not disclose sensitive information.

Breach of Policy

Failure to comply may result in disciplinary action. Breaches include:

  • Accepting unapproved hospitality
  • Failing to log gifts
  • Attending supplier events without authorisation
  • Misconduct at events

External Support

Associated Policies

This policy should be read alongside:

  • Disciplinary Policy
  • Grievance Policy
  • Socialising at Stonegate Policy
  • Inclusion Policy
  • Wellbeing Policy
  • Relationships at Work Policy
  • Bullying and Harassment Policy
  • Whistleblowing Policy
  • Anti-Bribery and Corruption Policy
  • Alcohol and Drugs Policy
  • Expenses Policy

Legal Compliance

This policy complies with:

  • UK Bribery Act 2010
  • Employment Rights Act 1996
  • Equality Act 2010

 

 

For further support, please contact er.support@stonegategroup.co.uk (if Site based), or your HRBP (if PST based)

 

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