Sensitive Expenditure
Policy
and/or the Privacy Act 2020
Information released under the Official Information Act 1982
Contents
Document control ..................................................................................................................... 1
Distribution ................................................................................................................................ 1
Information and records management ..................................................................................... 1
Policy statement ........................................................................................................................ 1
Policy application ....................................................................................................................... 1
Policy objectives ........................................................................................................................ 2
Definitions ................................................................................................................................. 2
Implementation and operation ................................................................................................. 3
Types of sensitive expenditure .......................................................................................... 3
Sensitive expenditure guidelines .............................................................................................. 3
Work-related travel expenditure ....................................................................................... 4
Travelling within Aotearoa New Zealand ........................................................................... 4
Meals .................................................................................................................................. 4
Accommodation ................................................................................................................. 4
Public transport/taxis/Ubers .............................................................................................. 5
Travelling overseas ............................................................................................................. 5
Combining work travel with personal travel ..................................................................... 5
Frequent flyer programmes ............................................................................................... 6
Credit cards ........................................................................................................................ 7
Hospitality and entertainment ........................................................................................... 7
Farewells and retirements ................................................................................................. 8
Functions and events ......................................................................................................... 8
Catering for meetings......................................................................................................... 9
Gifts .................................................................................................................................... 9
Giving gifts .......................................................................................................................... 9
and/or the Privacy Act 2020
Receiving gifts .................................................................................................................... 9
Personal use of HDC assets .............................................................................................. 10
HDC use of private assets ................................................................................................. 10
Information released under the Official Information Act 1982
Private use of HDC suppliers ............................................................................................ 10
Sale of HDC surplus assets to staff ................................................................................... 11
Donations and koha ......................................................................................................... 11
Key accountabilities and responsibilities ................................................................................ 11
Staff responsibilities ......................................................................................................... 11
Budget/financial delegations holders .............................................................................. 12
Claims and documentation .............................................................................................. 12
Monitoring and reporting ................................................................................................ 12
Supporting documents ............................................................................................................ 13
and/or the Privacy Act 2020
Information released under the Official Information Act 1982
Health and Disability Commissioner
Sensitive Expenditure Policy
Document control
File name and version
Sensitive Expenditure Policy Version 7
Date:
24 July 2024
Approved by:
Health and Disability Commissioner
Signature:
Filed in:
Intranet Content Folder
Finance Manager
Policy owner
Corporate Services Manager
Previous policy (version and date)
13.0 Sensitive Expenditure Version 6 26 July 2022
Next review due
July 2026 (biennially) or earlier if required
Distribution
1.
The information in this document is for personnel of the Office of the Health and Disability
Commissioner (HDC) only and any authorised agents. The document may contain
commercially sensitive information and cannot be copied or distributed in part or whole
without the express permission of the Health and Disability Commissioner.
Information and records management
2.
Under the Public Records Act 2005, HDC has a responsibility to create, maintain, and dispose
of Documents Policy).
Policy statement
3.
business-related expenditure. The policy covers the potential areas of sensitive spending to
ensure that it is fair and equitable and that HDC uses public money responsibly.
and/or the Privacy Act 2020
Policy application
4.
This policy applies to all HDC employees, Deputy Commissioners, the Commissioner, and other
workers, including temporary staff, contractors, and volunteers, irrespective of where they
Information released under the Official Information Act 1982
are working. Sensitive expenditure items specifically provided for by employment agreements
are not covered by this policy.
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Health and Disability Commissioner
Sensitive Expenditure Policy
Policy objectives
5.
Any spending must be consistent with the guidance for sensitive expenditure contained in the
Controller and Auditor-
Controlling sensitive expenditure: Guide for public
organisations . This covers the public expectations of public servants using taxpayer money
and scrutiny by both the public and Parliament.
6.
All sensitive expenditure decisions must follow these principles:
• A justifiable business purpose
• Impartiality means decisions based on objective criteria and not any sort of bias,
preference, or improper reason.
• Integrity is about exercising power in a way that is true to the values, purposes, and duties
for which that power is entrusted to, or held by, someone. It is about consistently behaving
in keeping with agreed or accepted moral and ethical principles.
• Transparency means being open about the spending and will to explain any spending
decisions or have them reviewed.
• Expenditure must be moderate and conservative related to the
circumstances.
• Appropriateness means the perception of the individual transaction and the total amount
of sensitive expenditure is taken into account.
• Properly authorised by the relevant manager following the one-up principle.
• The employee should be neither advantaged nor disadvantaged by this policy.
Definitions
7.
Sensitive expenditure is discretionary expenditure by a public entity that could be seen to be
giving a private benefit to a staff member, their family, or friends that is additional to the
business benefit of the organisation. It also includes expenditure that could be considered
unusual for the organisation s purpose or functions.
8.
One-up principle in financial delegations means that delegation holders cannot approve
transactions involving themselves or from which they could be seen to benefit. Instead, these
must be approved by their one-up manager. In most cases, this will be the Commissioner and
ELT members. Expenditure incurred by the Commissioner will be approved by the Corporate
Services Manager. The Corporate Services Manager approves HDC credit card transactions
and/or the Privacy Act 2020
incurred by ELT members. The Commissioner will review these expenses on a quarterly basis.
Information released under the Official Information Act 1982
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Health and Disability Commissioner
Sensitive Expenditure Policy
Implementation and operation
Types of sensitive expenditure
9.
The following areas are potential areas of sensitive expenditure and are covered by this policy:
• Work-related travel expenses, including accommodation and meals
• Credit cards
• Hospitality and entertainment
• Farewells and retirements
• Functions and events
• Staff recognition
• Catering for meetings
• Gifts, including giving and receiving
• Personal use of HDC assets
• HDC use of private assets
• Sale of HDC surplus assets to staff
• Donations and koha
Sensitive expenditure guidelines
10.
These guidelines assist sensitive expenditure decisions. Where an amount is specified, it
should be seen as a maximum rather than a target. All dollar amounts include GST. Where
the maximum limit specified seems likely to be exceeded, approval must be sought from the
Corporate Services Manager, Deputy Commissioner or Commissioner in advance of the
expenditure being incurred. It is acknowledged that, from time to time, prior approval may
not be possible. In those cases employee over-expenditure will be considered in light of the
reasonableness of the overspend with reference to business requirements and broader
context.
11.
HDC funds are not to be used to purchase alcohol in any circumstance.
and/or the Privacy Act 2020
Information released under the Official Information Act 1982
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Health and Disability Commissioner
Sensitive Expenditure Policy
Work-related travel
Travelling within Aotearoa New Zealand
expenditure
• All travel costs must have a clear business
purpose and must be necessary to achieve
• An initial consideration of technology-enabled
solutions as opposed to travel in person is
required.
• Domestic travel should be undertaken in a
cost-effective, practical, and efficient manner.
• Air travel should be booked through either
Jetstar Agent Hub or
Government Travel Portal to ensure that
competitive prices are obtained. Both Jetstar
and Air New Zealand are AOG contracted
suppliers.
• The fare is up to $600 per return trip.1
Meals
• When work travel requires an extended
working day of 10 hours or more, the traveller
may claim reimbursement for meals and
refreshments.
• Travelling employees can claim up to $60 per
day for daily food expenditure.
• Meals may not be claimed if a meal is provided
as part of another package, ie, included in an
accommodation package.
• HDC requires original GST receipts for
employees to be reimbursed.
Accommodation
• Where possible, accommodation should be
pre-booked and cost effective, considering the
location of the accommodation relative to
where employees or other w
and/or the Privacy Act 2020 orkers are
working, the standard of accommodation, and
safety and security issues.
• Employees or other workers staying in
Auckland or Wellington should use HDC
Information released under the Official Information Act 1982
preferred hotels to ensure the best rate.
1 Pre-approval is required from the Corporate Services Manager if the amount exceeds the limit.
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Health and Disability Commissioner
Sensitive Expenditure Policy
o Auckland
& Citylife Auckland
& Heritage Auckland
o Wellington
& Citylife Wellington
& Bolton Hotel Wellington
& Novotel Wellington
• For other locations within New Zealand, the
rate is up to $250 per night.2
Public transport/taxis/Ubers
• Using public transport should be considered as
a default position.
• Taxis or Ubers may be used when travelling
where this is the most cost-effective option.
The request for taxi vouchers should come
Travelling overseas
• All overseas travel must be pre-approved by
the Commissioner or the Acting Commissioner.
• Overseas travel for the Commissioner is to be
approved by two other ELT members.
• Economy class must be booked for all overseas
travel.
• For overseas travel, the Ministry of Foreign
Affairs and Trade per diem rate is to be used as
a guide to the maximum daily cost of
accommodation, meals, and other costs. The
rates can be found here:
https://www.mfat.govt.nz/en/aid-and-
development/working-with-the-aid-
programme/getting-paid/per-diem-rates/
and/or the Privacy Act 2020
Combining work travel with personal travel
• Business travel must be for a justifiable
business purpose.
Information released under the Official Information Act 1982
2 Pre-approval is required from the Corporate Services Manager if the amount exceeds the limit.
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Health and Disability Commissioner
Sensitive Expenditure Policy
• Any leave taken during work-related travel
normal leave processes.
• If an employee wishes to change or upgrade
their travel class or accommodation for a
private reason, HDC must not incur any
additional costs as a result. Staff are expected
to repay HDC if extra costs are incurred.
• If an employee wishes another person such as
a spouse or partner to accompany them on
work-related travel, HDC must not incur any
additional costs as a result.
• HDC funds are not to be used for tipping, mini-
bar, or entertainment expenses, including
networking and in-room entertainment.
Frequent flyer programmes
• HDC does not fund any airline club
memberships, such as Koru Club.
• Where practically possible, airpoints
accumulated by an employee or other worker
whilst travelling on HDC business must be used
only for future HDC travel or used for the
benefit of HDC. Employees are encouraged to
use airpoints for subsequent HDC travel or
membership subscription.
Refer to the Vehicle and After-hours transport
Policies (under review) for other travel-related
matters.
and/or the Privacy Act 2020
Information released under the Official Information Act 1982
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Health and Disability Commissioner
Sensitive Expenditure Policy
Credit cards
• The cardholder is solely responsible for all
charges made to the card.
• HDC credit cards are for approved HDC
business-related purposes only.
• Cash advances are prohibited.
• All credit card purchases must be supported by
a GST receipt when the credit card is
authorised for payment.
• Cardholders must not use the credit card for
personal expenditure.
Refer to the Credit Card Policy for more details.
Hospitality and entertainment
• When hosting guests or having meetings off
site with people who are official
representatives of their organisations, there
may be times when it is appropriate for HDC to
pay for food or non-alcoholic drinks.
• This type of expenditure must be pre-
approved by the Commissioner or Corporate
Services Manager.
• Costs should be moderate and conservative.
and/or the Privacy Act 2020
Information released under the Official Information Act 1982
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Health and Disability Commissioner
Sensitive Expenditure Policy
Farewells and retirements
• Expenditure on farewells and retirements
includes spending on gifts and functions when
staff leave or retire from HDC.
• ELT members may approve expenditure on a
function or a gift to recognise
valued contribution.
• Expenditure should be in line with the
following limits based on the leaving staff
Tenure
Maximum allowed
Less than 2 years
$50
2 5 years
$80
5 10 years
$100
10 20 years
$150
• For employees who are leaving after a tenure
of more than 20 years, the Commissioner, at
sole discretion, may
approve additional funding. Any contribution
must be less than $200.
Functions and events
• HDC will fund employees to attend the HDC
Christmas party and the Matariki/end-of-
financial year celebration at a cost of up to $35
per head per occasion. Any additional funds
will need to be agreed by the Commissioner.
•
utilised, when
possible, to avoid unnecessary venue hire and
travel costs.
• Other team events, including Christmas
lunches at team level, must be self-funded.
• Team lunches, if during work time, should be
no longer than two hours.
and/or the Privacy Act 2020
• T
sole discretion, fund morning/afternoon teas
for other occasions (for example, the welcome
of new team members, or recognition of
work). Costs should be no more than $8 per
Information released under the Official Information Act 1982
head.
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Health and Disability Commissioner
Sensitive Expenditure Policy
Catering for meetings
• There may be times when it is more cost- and
time-effective to provide catering for meetings
or planning days where the meeting is for
more than half a day.
• Catering for meetings and HDC planning days
must have prior approval from the relevant
one-up ELT member.
• Costs should be no more than $20 per head
for lunch and $8 per head for morning or
afternoon tea.
Gifts
Giving gifts
• In normal circumstances, it is not general
practice to give gifts internally within HDC.
• In the event of a bereavement of an
serious illness of a staff member, the relevant
ELT member may approve flowers and a card
up to the value of $120.
Receiving gifts
• It is important that receiving a gift does not
-
making, as this could be perceived as acting
without impartiality or integrity.
• Cash gifts are unacceptable in any
circumstances.
• Staff who accept gifts are required to report
them promptly to the Finance Manager, who
maintains the HDC Gift Register.
• Staff may personally receive infrequent,
inexpensive gifts that are openly distributed by
suppliers and clients, eg, pens, badges, and
calendars. All other gifts are to be accepted as
HDC property and are to be used for the
and/or the Privacy Act 2020
-up manager.
Refer to the Conflicts of Interest Policy for more
details.
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Health and Disability Commissioner
Sensitive Expenditure Policy
Personal use of HDC assets
• HDC assets, including photocopiers, stationery,
mobile devices, computer equipment, laptops,
and internet usage should not be used for
private use unless permitted as per the
relevant policy, eg, Private Use of HDC Assets
Policy.
• Personal use of a work mobile is allowable.
However, if personal use results in a cost to
HDC, the employee and their manager will be
notified to discuss usage and reimbursement.
All non-work-related costs, eg, roaming
charges, should be paid back to HDC by the
person responsible for the usage.
• The use of HDC assets for any employee
private business is not permitted.
Refer to the Private Use of HDC Assets Policy and
Computer Use & IT Security Policies for more details.
HDC use of private assets
• Reimbursement for HDC business use of
personal assets such as vehicles and private
cell phones may be approved for reasons such
as cost, convenience, or availability.
• For costs to be reimbursed, the personal asset
use must be for a justifiable business purpose
and the reimbursement must not impact on
the perception of impartiality and integrity.
• For costs to be reimbursed for private asset
use for HDC purposes there must be prior
approval from the relevant ELT member.
Private use of HDC suppliers
• Employees are generally prohibited from
purchasing goods and services from HDC
suppliers at preferential rates unless explicit
staff discounts have been negotiated.
• Employees must not use HDC as a source of
credit or use purchasing privileges on behalf of
and/or the Privacy Act 2020
a third party, such as a family member or
friends.
Refer to the Private Use of HDC Suppliers Policy for
more details.
Information released under the Official Information Act 1982
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Health and Disability Commissioner
Sensitive Expenditure Policy
Sale of HDC surplus assets to
• No surplus assets with a market value of more
staff
than $1,000 per item can be sold to
employees.
• HDC should not sell surplus assets at a
discounted rate to employees if HDC can make
a better financial return through a different
method of disposal.
Refer to the Sale of Surplus Assets to Staff Policy for
more details.
Donations and koha
• It is not general practice for HDC to make
donations.
• Koha is a gift, token of appreciation, or
contribution given on appropriate occasions,
including tangihanga; attendance at an
event/meeting; for use on or for a marae; and
kaum tua support for p whiri, mihi whakatau
meetings, or other events.
• All koha must reflect the occasion; be
approved in advance by the Commissioner; be
clearly documented with the date, amount,
description, and purpose; and be no more
than $500 for an individual or an organisation.
Key accountabilities and responsibilities
Staff responsibilities
12.
Staff must ensure that:
• When deciding to spend money on any of the areas above they:
o follow the key principles above when deciding whether expenditure is appropriate
o consult any other relevant policies and the sensitive expenditure guidelines below to
inform their decision-making
o obtain approval for sensitive expenditure before it occurs
and/or the Privacy Act 2020
o have expenditure approved by their one-up manager or Corporate Services Manager for
expenditure incurred by ELT managers
o ensure that any external function or entertainment expenses are incurred by the most
senior employee present, to preserve the one-up principle
Information released under the Official Information Act 1982
• All sensitive expenditure is coded correctly, and appropriate supporting documentation,
such as invoices, is retained and submitted to support approval
• All sensitive expenditure claims are made promptly, including complying with the regular
cycle for credit card approval
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Health and Disability Commissioner
Sensitive Expenditure Policy
Budget/financial delegations holders
13.
Managers must ensure that:
• All approved expenditure follows the one-up principle
• Before they approve any expenditure, they are satisfied that it is a justified business
purpose and the principles and requirements in this policy and any other relevant policy
are met
• There is appropriate budget and they have delegated authority to approve it
• The correct expenditure coding is used
• All supporting documents are enclosed
• Explanations are documented for any expenditure that could appear unusual
Claims and documentation
14.
Claims relating to sensitive expenditure need to:
• Clearly state the business purpose of the expenditure
in instances where the purpose is
not clear, further clarification may be requested
• Be accompanied by adequate original supporting documentation, such as tax invoices or
other validating documentation. Note that credit card statements or EFTPOS slips do not
constitute adequate documentation for reimbursement
• Document the date, amount, description, and purpose of minor expenditure when receipts
are unavailable, eg, purchases from vending machines
• Be coded correctly on the Expense Reimbursement Claim Form
• Be submitted promptly after the expenditure is incurred.
Monitoring and reporting
15.
Responsibilities for monitoring and reporting include the following:
• Budget holders use monthly financial divisional reporting to monitor activity in their areas
of responsibility.
• Budget holders approve Travel Requisition Forms (TRFs) for their team members, and
relevant transactions to verify charges in their areas of responsibility.
•
TRFs are pre-approved by the Corporate Services Manager, and t
and/or the Privacy Act 2020 he associated costs
are reviewed by the Commissioner on a quarterly basis.
• The
Commissioner.
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• The Finance team, when loading transactions, will follow up with individuals and their
managers any transactions that do not appear to match policy.
• The Finance Manager will check expense claims forms for policy adherence when approving
batch processing.
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Health and Disability Commissioner
Sensitive Expenditure Policy
• The Corporate Services Manager and another authorised approver will sample expense
claim forms for policy adherence when approving batch payments.
• The Finance Manager and Corporate Services Manager will review the sensitive
expenditure periodically to identify whether HDC has effective oversight and controls to
demonstrate honesty and financial prudence.
• A review of sensitive expenditure also forms
.
16.
A summary of sensitive expenditure incurred by the Commissioner is required to be published
on the HDC website.
17.
Failure to comply with this policy may result in disciplinary action.
18.
Examples of non-compliance include, but are not limited to:
• Failure to obtain appropriate one-up approval
• Unauthorised use or misuse of an HDC credit card
• Failure to declare a gift received.
Supporting documents
19.
Supporting documents include:
•
Controller and Auditor-
Controlling sensitive expenditure: Guide for public
organisations
•
Delegated Financial Authority Schedule
•
Travel & Vehicles Policies
•
Credit Card Policy
•
Conflict of Interest Policy
•
Private Use of HDC Assets Policy
•
Private Use of HDC Suppliers Policy
•
Sale of Surplus Assets to Staff Policy
•
Standards of Conduct Policy
•
State Service Code of Conduct
and/or the Privacy Act 2020
Information released under the Official Information Act 1982
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