POLICY

Receiving and Giving Gifts, Donations and Koha

Policy Responsibilities and Authorisation
Department Responsible for Policy
Strategy and Funding
Document Facilitator Name
Cara Dibble
Document Facilitator Title
Corporate Planning and Accountability Manager
Document Owner Name
Marc ter Beek
Document Owner Title
Executive Director - Strategy, Investment and
Transformation
Target Audience
Al  Waikato DHB Staff
Authorised By
Executive Leadership Team
Date Authorised

Committee Endorsed
Finance Risk and Audit Committee
Date Endorsed

Disclaimer: This document has been developed by Waikato District Health Board specifically for its
own use. Use of this document and any reliance on the information contained therein by any third party
is at their own risk and Waikato District Health Board assumes no responsibility whatsoever.

Policy Review History
Version
Updated by
Date Updated  Summary of Changes
5
Cara Dibble
Sept 2020
Full Review

Cara Dibble
Feb 2021
Incorporate feedback from consultation

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POLICY

Receiving and Giving Gifts, Donations and Koha

1  Introduction
1.1  Purpose
This policy sets the principles for receiving gifts within the Waikato District Health Board
(DHB) from external parties and defines what is, and what is not, a gift.
It also sets the principles for the limited circumstances where giving tokens of appreciation
paid for by the Waikato DHB is permissible, which includes some examples of giving koha
(while other instances are exempt, as outlined in 1.3.
This policy is intended to protect Waikato DHB staff by providing information to assist
them to comply with their legal and ethical obligations by reducing the risk of perceived
influence that may be associated with accepting, or giving of gifts.

1.2  Scope
The policy applies to all Waikato DHB staff.  Non-disclosure wil  be in breach of the Code
of Conduct policy and could result in performance management as directed by the
Waikato DHB Managing Behaviour and Performance policy (Ref. 5250).

1.3  Exclusions
The following are excluded from this policy:
•  Tokens such as promotional calendars, diaries, stationery or samples, of an apparent
value of less than $50.
•  Chocolates, flowers, food or other items, typically given to a group of staff by a patient
to express thanks for health or disability services received, that have an apparent value
of $150 or less.
•  A catered function provided to staff by the Waikato DHB - see Catering guideline (Ref
0038).
•  Koha laid in Pōwhiri or Whakatau ceremonies – see Powhiri and Whakatau guideline
(Ref 1847).
•  Sponsorship payments - see Sponsorship policy (Ref 0122).
•  During a procurement process, there is a complete prohibition on staff receiving gifts,
hospitality or sponsorship from any current or potential suppliers who are participating,
or are likely to participate in the procurement process – see Procurement and
Contracts policy (Ref 0170) in these circumstances.

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POLICY

Receiving and Giving Gifts, Donations and Koha

2  Definitions and acronyms
Appropriate Charity
A charity whose activities are consistent with Waikato DHB’s aims for
health and wellness. It would not include a charity relating to the gaming
industry, alcohol, tobacco or fast food.
Benefit
A benefit includes any decision made which is intended to provide an
advantage an external party. For example, Waikato DHB intending to
not ‘oppose’ a liquor licence or a resource consent.

A benefit also includes any gratuitous gesture of a tangible nature.
Direct Relation
Includes a:
•  child
•  grandchild
•  grandparent
•  parent (biological, step-parent or adoptive)
•  partner
•  partner’s parent
•  sibling (and step-siblings)
Donation
A donation is a payment (in money or by way of goods or services) made

voluntarily and without expectation of receiving goods or services in

return.
Gift
Generally means an item, service, or other benefit received by an

individual staff member without anything being formally given in

exchange. It is usual y given as a token of recognition of something
provided by the recipient.

A gift may be given by a public entity – such as to an employee for long
or outstanding service, or may be given by another organisation to
Waikato DHB (as an organisation) or a Waikato DHB staff member.

A gift usually takes the form of some tangible object, but might also be in
the form of free use, for example, free use of a corporate box at a
sporting event or privileged access to goods or services.

A gift includes raffles and prizes won when attending courses or events
as a representative of the DHB or where Waikato DHB has paid for the
recipient’s attendance.
Gift Register
Register to record gifts received by staff by emailing
[email address]
Hospitality
The reception and entertainment of guests, visitors, or delegates at
events and functions, normally at no cost to the guest.
Inexpensive
Any gift with a value lower than $50.
Infrequent
Gifts received from the same external party four or less times over a
consecutive 12 month period.
Koha
Koha is a gift, a token, or a contribution given on appropriate occasions.
Koha is an important cultural practice within te ao Māori; a mark of
respect and acknowledgement extended by/to tāngata whenua or the
hosts of marae, events or gatherings.
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POLICY

Receiving and Giving Gifts, Donations and Koha

Regular
Gifts received from the same external party three or more times over a
one month period.
Sponsorship
Sponsorship is financial or in-kind support that can generate measurable
results towards specific aims. Please refer to the Sponsorship Policy.
Staff
Al  employees, non-employee contractors, volunteers, independent
practitioners providing care, and visiting students.

3  Policy processes
3.1  Roles and Responsibilities
Al  Staff
•  Wil  read and understand their responsibilities with regard to the Receiving and Giving
Gifts, Donations and Koha policy.
•  Wil  ensure gifts received are registered on the gift register.

Managers
•  Managers are responsible for ensuring that all their staff comply with this policy.

Executive Director Finance, Procurement and Supply Chain
•  Wil  ensure the Gift Register is maintained and regularly reviewed.
•  Wil  ensure that all monetary gifts received by the Waikato Health Trust are banked and
accounted for appropriately.

3.2  Receiving Gifts
Waikato DHB staff should avoid creating a perception that they have been, or are able to
be, influenced by external parties and, as a general rule, should not accept gifts from
external parties.  Waikato DHB staff must be very careful about accepting gifts or
hospitality from external parties and always be aware of the public perception that can
result from doing so. The Code of Integrity and Conduct issued by the State Services
Commissioner under the State Sector Act 1988 requires Crown Entities and their
employees to be fair, impartial, responsible and trustworthy. Employees of Crown Entities
must decline gifts or benefits that place them under any obligation or perceived influence
and they should never misuse their position for personal gain.
Per the Procurement and Contracts Policy, during a procurement process, there is a
complete prohibition on the receipt by staff involved in the procurement process of gifts,
hospitality or sponsorship, from any current or potential suppliers who are participating in
the procurement process, or are likely to participate.
There are some situations where it is permissible to accept gifts (further guidance is
detailed in points 4.1 – 4.5 below).  The following principles will apply:
•  Consistently receiving gifts from a particular external party is not acceptable.
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POLICY

Receiving and Giving Gifts, Donations and Koha

•  Perceptions of influence must be avoided.
•  Staff must not solicit such items.
•  If any gift, benefit, or offer of hospitality is offered or accepted, and it has a value or
apparent value of $50 or more ($150 or more for a group gift) it must be listed on the
Gift Register by emailing [email address]
•  If any gift, benefit or offer of hospitality exceeding the actual or apparent value of $150
is accepted it must have one-up (direct manager) approval

3.2.1 Receiving Gifts intended to influence (directly or indirectly)
Waikato DHB staff shall not accept any gift for their personal benefit from any external
party where the staff member is able to directly influence the allocation of Waikato DHB’s
resources, or otherwise cause Waikato DHB to act in any way to benefit the external
party, unless:
•  the gift is inexpensive (less than $50);
•  the gift is infrequent (not given more than four times over a 12 month period); and
•  refusal to accept the gift would cause embarrassment or offence.

A direct influence includes, for instance, any involvement in the:
•  management of operational and/or capital expenditure;
•  purchase of goods or services; or
•  priority to be afforded to particular patients or services.

Note: A decision to select a particular product or service provider (pharmaceutical, device,
diagnostic procedure, or other) for individual patients wil  not constitute a direct influence
of Waikato DHB resources for the purposes of this policy. However, staff should take care
to avoid the “wrong” appearance and ensure that prescribing and other clinical decision
making is not able to be influenced by “sweeteners” (items and/or services provided) by
pharmaceutical companies or other vested interests.
As per the Procurement and Contracts Policy staff must keep a written record of any
approaches made and if the gift, hospitality, or sponsorship was inadvertently accepted,
the action taken to avoid any bias or perception of bias. Accepting gifts from commercial
organisations is generally discouraged to avoid bias or perception of bias during or after a
procurement process.

3.2.2 Receiving Gifts from Patients/Service Users to Staff
As a general rule, staff should not accept personal gifts from patients.  This includes gifts
which may appear to be of low financial value (< $150). However small items such as
chocolates, beverages (e.g. tea/coffee), flowers or food, may be accepted if it would be
offensive to reject.
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Receiving and Giving Gifts, Donations and Koha

Staff must ensure that such gifts are not accepted on a regular basis from the same
patient or their family. ‘Regular basis’ being defined as more than three gifts received over
a one month period.
Staff should have regard to the following when considering acceptance of a gift:
•  Relevant ethical codes of practice from their professional body.
•  Particular care should be taken when gifts are offered by vulnerable patients including
the elderly, young patients and palliative care patients.

3.2.3 Staff giving gifts to patients/service users
At times staff may feel it is appropriate to provide a small offering to patients or service
users as a form of whakawhanaungatanga (e.g. biscuits, milk). Staff are entitled to
engage in this practice at their own discretion and at their own expense.

3.2.4 Receiving Monetary Gifts
Bequests in the wil s of deceased patients are considered ‘monetary gifts’ for the purpose
of this policy.
Staff should not (in any circumstances) accept monetary gifts.  Monetary gifts must be
refused and the patient asked if they would like to make a donation to the Waikato Health
Trust, or an appropriate charity.
In the situation where it is impossible to refuse the monetary gift (excluding koha), the
money together with an explanation of why it cannot be refused should be supplied to the
Office of the Chief Executive (by emailing the Chief Executive’s Personal Assistant) for
banking in the Waikato Health Trust’s bank account. These donations are managed by the
Trustees of the Waikato Health Trust.
In the situation where it is impossible to refuse a monetary gift which is in the form of
koha, please refer to the Waikato DHB Powhiri and Whakatau guideline (Ref 1847).

3.2.5 Receiving Gifts on behalf of Waikato DHB or Waikato Health Trust
A gift that is given for the benefit of the Waikato DHB and its patients collectively, or for
the benefit of the organisation at large, rather than for individual benefit, is permissible.
Where the giver of the gift has specified the purpose for which the gift is to be used, it
shall be used for that purpose, to the extent that the Waikato DHB or Waikato Health Trust
is legally able to do so.
The receipt of any gifts for a corrupt purpose may be an offence as set out in the Secret
Commissions Act 1910 and may be dealt with accordingly.
Donated equipment shall be managed in accordance with the requirements of the Waikato
DHB Procurement and Contracts policy and recorded on the Gift Register and the Asset
Register.

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3.2.6 Receiving Gifts during and after a Procurement process
When a procurement process is in progress (including early discussions about a possible
project), staff involved in the process (including governance, management, operational
staff and DHB Board members) must not accept any gifts, hospitality or sponsorship, from
any current, or potential suppliers, who are participating, or are likely to participate in the
procurement process.
After the conclusion of the procurement process, staff involved in the process must not
accept from the successful supplier any gifts, hospitality or sponsorship, that create the
perception of bias in the evaluation of the successful supplier and/or the recommendation
and decision to award the contract to that supplier.
Staff should also consult the Waikato DHB Procurement and Contracts Policy.

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Receiving and Giving Gifts, Donations and Koha

3.3  Giving gifts and donations (excluding koha)
3.3.1 Process for giving gifts to staff
If a staff member considers that a gift / token of appreciation is appropriate or necessary
the process that a staff member must follow is:
•  Staff member must discuss the proposal with their immediate manager who can
authorise expenditure up to $150. Authorisation of larger amounts must only be made
by a Level 3 Manager (generally Executive Director level).
•  All gifts / tokens of appreciation provided by Waikato DHB to staff are subject to Fringe
Benefit Tax (FBT).  To ensure taxation obligations are met, the Manager or Staff
member giving the gift must ensure the following details are to be emailed to
[email address].
o  name of recipient
o  amount / value of gift / token of appreciation
o  date gift / token of appreciation is given to staff member
o  details of gift / token of appreciation (e.g. supermarket voucher)
o  name and position of manager who approved the gift to the staff member (recipient)

3.3.2 Process for giving gifts or donations externally
External gifts or donations must be for purposes that are consistent with the business of
the entity making the donation; and the size of the donation must be appropriate in the
circumstances.
The principles of preserving impartiality and integrity, and moderate and conservative
expenditure, are particularly relevant. Making a donation should not result in any
counterpart obligation on individuals or entities, other than to apply the donation to the
purposes of the recipient.
External gifts or donations must be:
•  lawful in all respects, including complying with Parliamentary appropriations;
•  disclosed in aggregate (where required);
•  made to a recognised organisation by normal commercial means – not to an
individual and not in cash; and
•  non-political.

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3.4  Giving koha
3.4.1 Framework
Waikato DHB is obliged to safeguard and use its resources in a prudent and responsible
manner. Furthermore, Waikato DHB’s staff must guard against actual or perceived
conflicts of interest in regard to the use of those resources. Due to the personal nature of
gifts and the risk of perceived or actual personal benefit to the staff member giving or
receiving the gift, the Controller and Auditor General defines a gift as a “sensitive”
expenditure type.
The Commissioner/Board expects that all staff involved in making or approving
expenditure on koha, or receiving koha on behalf of the DHB:
•  do so only for DHB purposes;
•  to exercise prudence and professionalism;
•  not to derive personal gain (financial or otherwise);
•  to act impartially;
•  to ensure the expenditure is moderate and conservative in the context of the given
situation (note that specific expenditure amounts are further explained below);
•  to have read and adhered to this and other relevant DHB policies.
There is a line between token gifts of appreciation and those that may compromise the
recipient. This line is not easily defined but, as a general rule, staff must not give or accept
koha if it could be perceived by a reasonable person as an inducement or reward that
might impact on Waikato DHB’s reputation.

3.4.2 Koha gifted to external parties
Koha is a gift, a token, or a contribution given on appropriate occasions made in the
context of Maori custom, without any obligation for that recipient to provide something in
return.
Examples of koha include money gifted to:
•  a bereaved family and / or marae commit ee at a tangihanga.
•  a bereaved family where the deceased person is a Board/Board Committee, staff
member, or an immediate relative of a staff member (i.e. father, mother, brother, sister,
son, daughter, husband, wife) or an external person who has provided support to
Waikato DHB.
•  the bereaved family and / or marae commit ee at a hura kohatu
•  a marae or organisation in recognition/acknowledgement for the holding of an event or
hui relevant to the work of Waikato DHB (where no direct charge has been levied on
Waikato DHB for use of the premises).
•  an organisation where Waikato DHB staff attend an event of that organisation (e.g. the
opening of Whare/Building) where there is a professional relationship that exists and it
is appropriate to provide a donation.
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•  An organisation holding an event organised by / sponsored by Waikato DHB staff; have
staff involvement; or staff attend as a visitor / advocate / liaison and there is a sound
business reason to support it.

Examples of when payments not considered to be koha are payments:
•  to individuals to attend meetings
•   for Kaumatua assistance
•   to conduct traditional welcomes
•   to ceremonial entertainers
•   to individuals carrying out rituals and blessings
•   to individuals presenting to gatherings
•   to marae for catering and use of premises
Payments for services given, such as the examples above, are not koha, but rather
payments for services. These are paid under the provisions of the Procurement and
Contracts Policy.
When considering a koha the following should be taken into account:
•  Employees attending a function on behalf of Waikato DHB are not expected to give
personal koha.
•  Employees attending a function in a personal capacity i.e. not on behalf of Waikato
DHB, can only give koha from their own personal monies.
•  The amount of koha when given in a monetary or purchased format will not usually
exceed $50.00 and wil  require pre-approval from the Service Manager. However this
wil  depend on the number of approved persons attending the function as follows:
Number of attendees representing Waikato DHB
Value of koha
1-5 person(s)
$50.00 (max)
6-10 persons
$100.00(max)
More than 10 person
$150.00 (max)
Significant Relationship with Waikato DHB
$250.00 (max)

If the monetary amount or purchased koha requested is greater than the above,
authorisation is required by the Chief Executive.  Non-monetary or non-purchased koha
given will reflect the circumstance, and often wil  not have a specific or obvious
monetary value.
•  All koha must be approved by the Service Manager prior to the event, with any
consequent purchase, reimbursement or expense claim following this. The requestor
must demonstrate a clear and appropriate business link between Waikato DHB and the
receiving person or organisation.
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•  Any koha given should be reflective of the occasion and the prestige of Waikato DHB in
its relations with iwi.
•  Koha must relate to an activity that fits the objectives of Waikato DHB.
•  Giving koha is a practice of bestowing an unconditional gift where the recipient has
neither stipulated that it be given, nor has any expectation of receiving it.
•  In this policy “koha” means an unconditional gift which complies with the IRD definition:
“An unconditional gift is defined as a donation made to a non-profit body, where the
giver does not receive any goods or services in return for the donation. This carries
with it no obligations to account for tax”.
•  No payment is to be made as “koha” (i.e. tax free) when the actual circumstances
surrounding the payment carry an obligation to pay tax.
•  If a number of Waikato DHB staff and / or groups are attending a function, there should
be no more than one koha on behalf of the organisation.  Co-ordination of the
organisation contribution prior to the hui must be managed by a designated person.
•  The koha wil  be given to the recipient in a manner appropriate to the nature of the
gathering. Guidance and clarification can be sought from Waikato DHB Maori Health
team (Te Puna Oranga).
•  The koha requester and the koha receiver cannot be the same person, or a direct
relation to each other.

3.5  Gift Register
The Executive Director Finance, Procurement and Supply Chain is responsible for
maintaining the Waikato DHB’s gift register and ensuring it is reviewed on an annual basis
by Finance Risk and Audit Committee. The annual review is to include:
•  the top 10 monetary value gifts received and the institution it came from
•  recipients receiving gifts more than once
Managers can request a copy of the Gift Register to monitor transactions by staff by
emailing - [email address]
The implications of not disclosing a gift may include:
•  lack of a clear audit trail to gifts for any investigations into the gifts or relevant parties
•  recipient’s integrity may be compromised in any current or future dealings with a
supplier or gift giver
•  reputational damage to Waikato DHB
•  interference with a formal procurement process
•  employee performance or behaviour concerns due to breach of policy

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4  Audit
4.1  Indicators
•  When any gift, benefit, or offer of hospitality is offered or accepted, it is listed on the
Gift Register.
•  All koha meets the requirements of sec 2.4.
•  Al  gifts and donations are authorised by a correct level of delegation
•  An annual review is completed by, or under the delegation of, the Executive Director
Finance

5  Legislative requirements
5.1  Legislation
To include but not limited to:
•  Contract and Commercial Law Act 2017
•  Fair Trading Act 1986
•  Secret Commissions Act 1910

5.2  External standards
•  Controller and Auditor General’s Good Practice Guidelines for “Controlling Sensitive
Expenditure”
•  Medical Council of New Zealand Professional Boundaries in the Doctor-Patient
Relationship
•  Medical Technology Association of New Zealand - “Code of Practice” Clause 5.8 Gifts
to Healthcare Professionals
•  The Royal Australasian College of Physicians - “Guidelines for ethical relationships
between physicians and industry”
•  Medical Council of New Zealand Cole’s Medical Practice in New Zealand 2017
•  Nursing Council of New Zealand Guidelines to Professional Boundaries 2012
•  Nursing Council of New Zealand Code of Conduct 2012

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6  Associated documents
6.1  Associated Waikato DHB Documents
•  Waikato DHB Catering guideline (0038)
•  Waikato DHB Code of Conduct policy (5674)
•  Waikato DHB Delegations of Authority policy (2175)
•  Waikato DHB Engaging Kaumatua Services and Payment guideline (3911)
•  Waikato DHB Fraud policy (3274)
•  Waikato DHB Managing Behaviour and Performance policy (5250)
•  Waikato DHB Powhiri and Whakatau guideline (1847)
•  Waikato DHB Procurement and Contracts policy (0170)
•  Waikato DHB Sponsorship policy (0122)

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Document Outline

20-04-21 - OIA Response N Vaughan - Appendix 1.pdf