Staff members and, where relevant, associated persons must obtain advance authorisation for proposed hospitality and promotional expenditure (other than for normal client entertaining such as a business lunch or dinner). Requests should be submitted well in advance to the Compliance Officer.
An example of promotional expenditure or exceptional corporate entertainment which would need prior authorisation would be taking a customer or customers to a high-profile sporting event, such as an international football match or tennis match at Wimbledon, and providing hospitality (meal, drinks etc.) during the event. The Company will only authorise reasonable, appropriate and proportionate entertainment and promotional expenditure.
Requests for approval for exceptional promotional expenditure should be submitted to the Compliance Officer and should set out:
- the objective of the proposed client entertainment or expenditure;
- the identity of those who will be attending;
- the organisation that they represent; and
- details of the proposed activity and some explanation as to why this entertainment/expenditure has been selected as opposed to other options.
The Company will approve promotional expenditure proposals only if they demonstrate a clear business objective and are appropriate for the nature of the business relationship. The Company will not approve business entertainment where it considers that a conflict of interest may arise or where it could be perceived that undue influence or a particular business benefit was being sought (for example, prior to a tendering exercise).
Any gifts, rewards or entertainment other than normal ‘business lunch/dinner/drinks’ received or offered from clients, public officials, suppliers or other business contacts should be reported immediately to the Compliance Officer. In certain circumstances, it may not be appropriate to retain such gifts or be provided with the entertainment and staff and associated persons may be asked to return the gifts to the sender or refuse the entertainment. This could be, for example, in any circumstances where there could be a real or perceived conflict of interest. As a general rule, small tokens of appreciation, such as flowers or a bottle of wine, may be retained by staff members.
If you wish to provide gifts to suppliers, clients or other business contacts, you should complete the form ‘Business Gift Provision Form’ and submit it to to the Compliance Officer for authorisation. If you purchase gifts for business contacts without obtaining written authorisation, your claim for reimbursement of money spent on such gifts will not be reimbursed. Additionally, depending on circumstances, the purchase and offer of gifts to business contacts without prior authorisation could be the subject of a disciplinary investigation and possible disciplinary action up to and including dismissal, or termination of Service Agreement.
Staff and, where applicable, associated persons must supply records and receipts, in accordance with the Company’s expenses policy.