that is additional to the business benefit. It also includes expenditure by a public entity
that could be considered unusual for the entity’s purpose and/or functions.
This policy gives employees and contractors a framework in which to operate. The
following are potential areas of sensitive expenditure covered by this policy:
Travel and accommodation
Air travel
Accommodation
Road travel
Food and drink while travelling
Expenses
Entertainment and hospitality
Food and drink
Employee benefits and use of assets
Koru Club membership
Loyalty reward scheme benefits
Professional memberships
Sale of surplus assets to employees
Private use of ACC’s assets
Private use of ACC’s suppliers
Employee support and welfare expenditure
Clothing/Corporate wardrobe
Long service recognition
Farewells and retirements
Life events
Employee recognition
Employee/Event sponsorship
Contributions and gifts to external parties
Donat ons
under the Official Information Act 1982
Koha/Meaalofa (and equivalents in other Pasifika cultures)
Gifts to external parties
Gifts and gratuities.
The policy also covers the following ways in which ACC pays and reimburse for sensitive
expenditure:
Released
Payment by purchasing card
Payment by invoice
Payment by reimbursement.
Sensitive Expenditure Policy
Page 2 of 14
Accident Compensation Corporation
March 2024
4 Policy standards
Sensitive expenditure receives more scrutiny than other costs. ACC expects those who
request and approve sensitive expenditure to understand ACC’s policy and guidance on
sensitive expenditure.
ACC expenditure should be:
consistent with the standards of probity and financial prudence that are expected
from a Crown Entity
able to withstand parliamentary and public scrutiny.
This policy adopts a principles-based approach to sensitive expenditure. The principles
are designed to give a balanced approach to individual circumstances.
The principles are that expenditure decisions must:
have a justifiable business purpose
preserve impartiality
be made with integrity
be moderate and conservative when viewed from the standpoint of the public
be transparent
be made with the proper authority and follow ACC’s delegation requirements.
4.1 Travel and accommodation
ACC’s travellers, travel arrangers and approvers are expected to:
Firstly, consider whether teleconference and video conference calls would produce
the same result in a timelier and cost-effective manner than travel
Make the trave ler’s safety paramount
Plan travel that requires the least time away from the office
Use the most cost-ef ective method of travel, taking into account the number
travelling
under the Official Information Act 1982
Take the most direct route to the destination
Arrange meetings to take into account the travel logistics of participants, rather than
arranging travel around meetings
Book as far in advance of travel as practical – at least two weeks in advance
Use ACC’s preferred suppliers.
Air travel
Personal, spouse and companion travel may be combined with business travel if it
Released is at no additional cost to ACC. When personal travel is combined with business
travel, this should be highlighted when approval for the travel is requested
Any work time used for private travel must be booked as annual leave before the
employee leaves
Sensitive Expenditure Policy
Page 3 of 14
Accident Compensation Corporation
March 2024
If an employee is required to change personal travel arrangements for business
purposes, ACC will meet any reasonable costs on a case-by-case basis. Relevant
Deputy Chief Executive approval is required
All air travel wil be economy unless the flight is more than 9 hours long, where
approval may be given by the Deputy Chief Executive for a higher class.
Accommodation
ACC’s preferred accommodation providers must be used and within cap where
possible. Where there are no preferred accommodation available, other providers
may be used
Employees may claim for a private accommodation allowance in lieu of staying at a
preferred provider. Prior approval from the employee’s line manager is required.
Road travel
The most cost-effective method of travel wil depend on the circumstances. This may
be rental car, fleet car, taxi or public transport. Private car can be used when no fleet
vehicle is available or the situation is not suitable, such as traveling to the airport. Prior
approval must be obtained from the employee’s line manager and should be noted on
the reimbursement request.
Food and drink while travelling
The cost of food and drinks must be within the Catering and Meals Guidelines
ACC does not pay for mini-bar or alcohol expenses.
Expenses while travelling
Cash advances, in exceptional circumstances, may be provided when travelling
overseas, with the approval of the Deputy Chief Executive Corporate and Finance
ACC will pay actual and reasonable expenses while travelling on business
ACC does not cover the costs of tipping by employees while travelling for business
purposes in New Zealand
ACC wil cover the costs of tipping by employees when travelling internationally for
business, although tips shouldn’t be extravagant and should only occur where
tipping is local practice.
4.2 Entertainment and hospitality expenditure
under the Official Information Act 1982
Entertainment and hospitality expenditure is acceptable when:
building relationships (this includes Manaakitanga where it is appropriate to express
reciprocity of kindness and respect as part of building Māori relationships)
representing ACC at an event or similar
when recognising a significant business achievement
celebrating events such as Christmas and retirement functions.
Hospitality can cover a range of expenditure from tea, coffee and biscuits served at
Released
meetings to catered events.
The provision of
Food and Drink is acceptable for:
Farewell functions
Sensitive Expenditure Policy
Page 4 of 14
Accident Compensation Corporation
March 2024
Employee celebrations
Meetings or workshops
Business networking
Manaakitanga events.
ACC will contribute towards employee Christmas parties at an amount set by the Deputy
Chief Executive each year. This contribution may not be used for the purchase of alcohol
When entertaining external guests, the meal limits should act as a guide and should be
actual and reasonable.
ACC does not pay for the purchase of any alcohol for any functions or gatherings. Any
exceptions to this position require prior approval by the Chief Executive.
The
Food and Drink pages give you all the information you need on how to incur and
account for this expenditure.
Entertainment and hospitality expenditure must be paid by the most senior ACC person
in attendance (when multiple ACC people are present)..
4.3 Employee benefits and use of assets
Loyalty reward scheme benefits
Loyalty reward schemes tend to be given to the named individual who orders or purchases
the goods or services, regardless of who has paid for them. Examples include Airpoints
and Flybuys. Employees are able to use loyalty rewards for their personal benefit.
Koru Club membership
ACC may provide Air New Zealand Koru Club membership for employees who fly a
significant amount.
Professional memberships/subscriptions
Professional memberships of associations and subscriptions (paper or electronic) may be
paid on behalf of an employee by ACC when it is required for professional registration
purposes, is relevant to the performance of the employee or as part of their contract. If
not within contract, ACC wil pay for one membership, provided it is clearly relevant to the
performance of the employee’s current duties and responsibilities.
Sale of assets to employees
under the Official Information Act 1982
Fixed assets can be sold to employees if approved by the appropriate people. Refer to
Fixed Asset Policy.
Private use of ACC’s assets
Any physical item owned, leased or borrowed by ACC is considered an asset. These
include motor vehicles, photocopiers, phones, digital devices, internet access and
stationery. As a general rule, employees should not use ACC’s assets for personal
reasons unless approval is obtained from the relevant cost centre manager.
Released
Sometimes it is impossible to avoid using a business asset for personal use. You may be
asked to provide evidence that no additional or excessive cost to ACC was incurred
resulting from the personal use. Refer to
Telephony Policy.
Sensitive Expenditure Policy
Page 5 of 14
Accident Compensation Corporation
March 2024
Private use of ACC’s suppliers
Employees can use ACC suppliers for their own personal use if they make it clear to the
supplier that the arrangements are personal, and the employee wil pay them directly.
Employees should be moderate in their use of employee discounts, should note that these
cannot be used on behalf of any third party (including family and friends) and must pay in
full at the time of purchase.
Some suppliers provide discounts to our employees, but ACC does not take this into
account when choosing suppliers. ACC selects all suppliers by following
ACC’s
Procurement Policy and
Government Rules of Sourcing.
4.4 Employee support and welfare expenditure
Clothing/Corporate wardrobe
Only reception employees are entitled to a
corporate wardrobe subsidy. From time to
time, employees who are supporting ACC initiatives may be provided a uniform to wear
at an event. This becomes the property of the employee.
Long service recognition
ACC recognises employees who have reached specific milestones based upon their
continuous service. Refer to
Long Service Recognition Guidelines.
Welcoming/Whakatau/Powhiri
A welcoming/whakatau/powhiri morning/afternoon tea function may be held for when a
new Deputy Chief Executive or Head of joins ACC or moves to a dif erent position at the
same or higher level. A Head of or Deputy Chief Executive may approve a welcoming
function for other employees depending on their role.
Farewel s and retirements
A farewell morning/afternoon tea function may be held for permanent employees who
have at least 12 months service and resign, retire or are made redundant. ACC will
generally not contribute towards a gift or flowers for a departing employee unless they are
retiring. The relevant Deputy Chief Executive may approve a farewell gift for employees
that resign or are made redundant in exceptional circumstances. The relevant Deputy
Chief Executive may approve a gift up to $200.
A farewell function may not be held for an employee whose employment has been
terminated for poor performance, inappropriate behaviour or serious misconduct. A
farewell function is not held for an employee who has moved teams.
under the Official Information Act 1982
Refer to Meals,
Food and Drink and
Farewells and retirements.
Life events
ACC may offer an expression of support or sympathy and cover the cost of flowers or a
gift basket, up to $80 including GST (the $80 excludes delivery costs, which should not
exceed $20) in the following cases:
An employee’s serious il ness or accident
A bereavement of an employee or employee’s immediate family such as parent or
Released child
A birth of an employee’s baby.
Sensitive Expenditure Policy
Page 6 of 14
Accident Compensation Corporation
March 2024
A pre-approval is required from the relevant cost centre manager before the expense is
incurred and should be arranged by the employee’s line manager.
Gifts for other events (including engagements, weddings, birthdays, Easter and
Christmas) wil not be paid for by ACC.
Employee recognition
In addition to the annual performance review cycle processes, one-off recognition and
non-cash rewards may be given, usually up to $50. Vouchers may be given to the
employee’s employees at the discretion of the manager, and can be obtained through the
gift station procedures outlined at
Benefits and Recognition.
Employee functions and team building
Team morning/afternoon teas and team building may be used as a form of non-monetary
recognition or achievements. Team building activities should be up to $30 including GST
per head on an annual basis and within approved budgets. The $30 per head can include
the cost of the activity and/or food, however it cannot include alcohol. Any expense over
this amount must be pre-approved by the relevant Deputy Chief Executive.
Employee/Event sponsorship
Sponsorship is support of an event, activity, person or organisation financially or through
the provision of products or services. Refer to the
Sponsorship Policy for guidance.
4.5 Donations and gifts to external parties
Donations
A donation is a payment of money or provision of goods or services by ACC. A donation
is voluntary, and the external organisation has no expectation of receiving goods or
services from ACC. Al donations must be pre-approved by the Deputy Chief Executive of
Corporate and Finance or the Chief Executive Officer. A donation is made to a recognised
organisation and not to an individual nor in cash.
Koha
Koha is an unconditional gift given and not a payment for goods or services received.
Koha may be given by a representative of ACC when ACC is represented at a Māori tangi.
Koha process:
may be given in cash
Al requests for koha must be sent to Tūhono Tāngata in the first instance for review.
Requests for koha payments over the value of $500 wil then be forwarded (by
under the Official Information Act 1982
Tūhono Tāngata) to DCE Māori for approval.
Tūhono Tāngata wil inform the requesting manager / group within 24 hours of receipt
of the request whether the request has been accepted or declined.
Cost centre managers must authorise payment.
Refer to ACC’s Koha Policy for guidance around the giving and receiving of koha.
Meaalofa (and equivalents in other Pasifika cultures)
Meaalofa (and equivalents) is also an unconditional gift given and not a payment for goods
Released
or services received, it may for example be given by a representative of ACC upon special
cultural events or when ACC is represented at a Pacific funeral. All payments of meaalofa
(and equivalents) made on behalf of ACC must be notified to
[email address].
Sensitive Expenditure Policy
Page 7 of 14
Accident Compensation Corporation
March 2024
Gifts to external parties
Gifts may be given to show appreciation to individuals, groups or organisations who have
provided a service at no charge, such as training, consultations or customer testing.
Alcohol may not be provided as a gift. Prizes may be given to injury prevention initiatives.
Prizes should be in the form of a good or service. These must be in line with the
recommended amounts defined in the Gifts and Gratuities Procedure.
Gifts and gratuities
ACC’s people are occasionally offered a gift or gratuity from a supplier, provider or client.
ACC must not receive or solicit gifts or gratuities from a third party for the performance of
our role. As members of the public sector, our people must ensure any offer of a gift or
gratuity is managed in a way that maintains the integrity and transparency of ACC and
our people. This policy applies to gifts and gratuities offered to individuals, groups or ACC
as a whole, from any third party, including clients, treatment providers, preferred suppliers
and other individuals or organisations.
No gift or gratuity is to be accepted from prospective suppliers that are actively tendering
for the provision of goods and services.
Money must never be accepted as a gift or gratuity.
Gifts and gratuities include, but are not limited to, the following due to the principle of
private benefit:
gift vouchers, goods, services, meals or other hospitality
tickets to events (e.g., sporting, musical or theatrical)
prizes won as a result of incurring some expense on behalf of ACC
free or discounted travel or accommodation, which includes discounted travel and
accommodation for seminars
any other reward or benefit.
Prizes received whilst representing ACC should be politely declined.
If an employee is offered a gift, and the value of the gift is greater than $50, then they will
need approval from their line manager to accept the gift.
All gifts accepted must be recorded monthly in a register managed by each Business
Group’s team administrator, and forwarded to
Procurement. Deputy Chief Executives will
review the gift register twice a year prior to Select Commit ee submissions.
under the Official Information Act 1982
It is not necessary to record minor items in the register, eg branded pens or coffee offered
in the normal course of business. Gifts or gratuities with an individual value of less than
$50 per person do need to be recorded.
Refer to
Gifts and Gratuities Procedure.
4.6 Payment methods
Payment methods are not a type of sensitive expenditure; however, care must be taken
Released
to ensure sufficient documentation is retained to support the incurring and accounting of
the expenditure.
Purchasing card payment
Sensitive Expenditure Policy
Page 8 of 14
Accident Compensation Corporation
March 2024
Purchasing cards are issued by ACC’s approved bank:
to purchase low dollar value good and services with suppliers where ACC has no
preferred supplier arrangement
to employees who are permanent employees or on a fixed term contract of at least
six months.
Rules
The card holder is the only person authorised to use their card
A purchasing card holder must never disclose their card’s PIN number to others
Cash advances are not al owed
No personal expenditure may be charged to the purchasing card
Purchasing cards are to be returned and cancelled when the cardholder is no longer
employed by ACC. Employees taking parental leave or who are participating in a
secondment external to ACC are required to surrender their card prior to taking leave or
commencing their secondment. Purchasing cards that have not been used for a period of
six months wil be reviewed and may be cancelled.
Refer to
Purchasing Card Procedures.
Invoice payments
Where payments are made through ACC’s Financial System, in addition to meeting
normal invoice procedures, the following details must be recorded:
the full name of the recipient(s) being paid
the reason the expenses were incurred
the type of goods or services
Reimbursing employee payments
Employees wil be reimbursed for actual and reasonable business expenses that they
have paid from their personal funds on ACC’s behalf.
Al expenses over $50.00 must be accompanied by tax invoices. If tax invoices are
unavailable for expenses of $50.00 or less, they must be accompanied by appropriate
documentation and approved by the employee’s line manager. Expenses wil be paid
fortnightly into the employee’s bank account via the HR payroll system. Reimbursements
must be claimed within three months.
under the Official Information Act 1982
If an employee has a financial interest or there is a
conflict of interest with the supplier,
the employee must declare this to the employee’s line manager before reimbursement
can be made.
Refer to
Cash reimbursement procedures.
Reimbursing Koha payments
Released
As koha is a cash payment, the procedure for reimbursement of the funds wil be similar
to the procedures for cash reimbursement. When there is a requirement for koha, the
following procedures should be followed:
Sensitive Expenditure Policy
Page 9 of 14
Accident Compensation Corporation
March 2024
Preferred Method: Funds will be paid directly from accounts payable to the relevant staff
member’s bank account prior to the Koha being given to the recipient.
Alternative Method: Where funds are unable to be paid from accounts payable, the
relevant staff member wil withdraw the funds from their own bank accounts. The staff
member must retain a copy of the transaction record (ATM) and the funds will be
reimbursed through cash expenses.
In exceptional circumstances there may not be time to seek pre-approval and/or arrange
the payment for koha. In these types of exceptional circumstances, koha is permitted to
be given without prior approval. If koha is made without pre-approval, approval must be
sought as soon as practical and include the full reasons for not seeking pre-approval.
4.7 Executive and Board Sensitive Expenditure
ACC executives (defined as the Deputy Chief Executives and the Chief Executive Officer)
and Board Members hold privileged positions as stewards of the organisation. They make
a commitment to serve in the best interests of New Zealand and New Zealanders - to act
in the spirit of service at all times.
The positions ACC’s executives and Board members hold come with very high
expectations for standards of integrity and conduct and they must always put the interests
of the Public Service and ACC before their own personal interests to maintain the trust
and confidence of New Zealanders.
As such, higher expectations in relation to accounting for sensitive expenditure are
required, including:
Expenses should be modest as they have an obligation to use public resources
prudently
Expenses that are nominal (defined as less than $10) should be covered by relevant
executive or Board member
Executive and Board members must exercise the highest judgement when deciding
to accept any gifts and benefits, including hospitality from third parties. It is not
acceptable for executives to use their position for personal gain or be perceived to
be doing so. Any offers made to executives that are not directly related to fulfil ing
the obligations of their role should be declined. This could include tickets to sports
matches or concert.
when executives or Board members are presented with ceremonial gifts, these are
under the Official Information Act 1982
expected to remain the property of the organisation rather than the executive or
Board member. This reflects the relationship that gave rise to the gift.
Al gifts and benefits received by the Chief Executive, with a value greater than $50,
that are accepted or declined, should be disclosed through the annual expense
disclosure process and registered on the Office of the Chief Executive Gift Register.
5 Accountabilities
Released
Board responsibility for finances is set out in the Board Governance Manual. This
acknowledges that the Board plays a lead role in setting a clear strategic direction for the
organisation; oversees the organisational governance framework and standards; ensures
Sensitive Expenditure Policy
Page 10 of 14
Accident Compensation Corporation
March 2024