gifts hospitality and entertainment procedure for release.pdf

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Koha
An unconditional gift, a gesture of goodwill and good faith and in

contemporary practice is often given in the form of money.
Protected
A disclosure of information is a protected disclosure if the discloser –
disclosure
• believes on reasonable grounds that there is, or has been, serious
wrongdoing in or by the discloser’s organisation, and
• discloses information about that in accordance with this Act, and
• does not disclose it in bad faith.
3  Declaring an offer of a gift, hospitality or entertainment
3.1
You must declare all accepted offers of gifts, hospitality or entertainment from third parties with
a value of $50 or more in MBIE’s online register, Camms, (there are two exceptions to this
requirement – see 3.1(d) below). Declarations should be made in a timely manner. Where offers
of gifts, hospitality or entertainment from third parties with a value of $50 or more are declined,
staff are also strongly encouraged to declare these in Camms.
a.
For offers of gifts, hospitality or entertainment with a value of less than $50 (accepted or
declined), you are not required to declare these, however, you may choose to do so
depending on the circumstances. This may include things like the perception of others,
potential scrutiny of your actions or more stringent rules in your business group or branch.
b.
Declarations entered in Camms must be clear and appropriate. They should include
sufficient detail about the response as agreed with your manager (accepted, declined,
disposed of or returned) and any other relevant details eg disposal plans.
c.
Declarations must specify the monetary value of the offer of a gift, hospitality or
entertainment (usually the retail value) or an estimate if the actual retail value is unable to
be determined.
d.
All accepted koha (including koha with a monetary value of less than $50) and all accepted
offers of gifts, hospitality or entertainment from an embassy, consulate, foreign
government or business (including those with a monetary value of less than $50) must be
recorded in Camms. Further guidance on this is outlined below in paragraphs 7 and 8.
4  Assessing an offer of a gift, hospitality or entertainment
4.1
People leaders/managers must review all declarations of gifts, hospitality and entertainment in a
timely manner. They should discuss with their staff member whether the gift, hospitality or
entertainment could create a perception of favour, influence or personal benefit in the eyes of
others, and record in MBIE’s online register, Camms, how the offer of a gift, hospitality or
entertainment will be resolved (accepted, declined, disposed of or returned).
4.2
People leaders/managers must resolve and close a declaration in Camms within ten working days
of being notified that a staff member has declared a gift, hospitality or entertainment in MBIE’s
online register, Camms.
4.3
When assessing declarations of gifts, hospitality and entertainment, people leaders/managers will
consider factors such as:
a.
the nature or significance of the work you do and the position you hold
b.
the nature or extent of your current or intended involvement in MBIE’s business activities
(within your business group and across the wider organisation)
c.
the potential to cause a perception of favour, influence or personal benefit in the eyes of
external stakeholders or members of the public.
Title:
Gifts, Hospitality and Entertainment Procedure
Next Review:
April 2027
Date of Issue:
November 2020
DCE Sponsor:
Deputy Secretary, Corporate Services, Finance and Enablement
Last Review:
April
Policy Owner:
Head of Integrity
Approved By:
Secretary for Business, Innovation & Employment and
Classification:
UNCLASSIFIED
Chief Executive
Page 4 of 6

4.4
All gifts, hospitality and entertainment accepted by individuals or teams become the property of

MBIE, not the individual or team that accepted them. Gifts must not be sold or exchanged.
5  Managing a declared offer of a gift, hospitality or entertainment
5.1
Generally, staff should not accept gifts, hospitality or entertainment offered by third parties.
When managing offers of gifts, hospitality and entertainment, people leaders/managers have the
following options:
a.
Declining or returning the gift, hospitality or entertainment to the person or organisation:
returning a gift is a useful option in situations where staff feel uncomfortable or are unable
to decline the gift politely and graciously when it was offered, or when the gift arrives at
the office unexpectedly.
b.
Keeping the gift as MBIE property: this is useful for cultural gifts from overseas delegations
where declining the gift would be seen as culturally insensitive (subject to section 8 below).
c.
Keeping the gift for your team or your office as the gift recipient: this option is useful for
gifts, hospitality and entertainment where the estimated retail value is small (eg gifts that
are infrequent, inexpensive and openly distributed by suppliers or clients such as pens,
badges or calendars).
d.
Disposing of the gift in a secure manner: unapproved gifts that do not meet the
requirements of the Gifts, Hospitality and Entertainment Policy should be disposed of
securely and in a way that does not identify the person or organisation giving the gift.
e.
Other: this option is for rare circumstances where the gift, hospitality or entertainment
does not fit the options listed above.
5.2
For further guidance on how to manage offers of gifts, hospitality and entertainment, contact
your manager or the Integrity team.
6  Declining gifts
6.1
You are empowered to politely and graciously decline offers of gifts, hospitality and
entertainment in situations where you can do so without causing embarrassment or offence.
6.2
If you can anticipate that a gift, hospitality or entertainment may be offered, you should advise
the organiser ahead of time that, although the offer is appreciated and very thoughtful on their
part, it is against MBIE policy to accept the offer. You can suggest to the organiser that a simple
email of appreciation recognising your contribution would be most welcome.
7  Koha
7.1
There may be times when a koha is given to MBIE staff. All accepted koha (including koha with a
monetary value of less than $50) must be recorded in Camms.
7.2
Guidance provided by the Office of the Auditor General clearly states that cash gifts are
unacceptable in any circumstances. However, if deemed inappropriate to decline a cash koha, it
must be declared in Camms and staff should contact the Chief Financial Officer or Deputy Chief
Financial Officer for advice on next steps.
7.3
MBIE employees are not entitled to receive koha payments for their involvement in ceremonies
or events as part of fulfilling their duties.
7.4
For further guidance on the Koha Policy or Mandatory Koha Procedures, contact
[email address]
Title:
Gifts, Hospitality and Entertainment Procedure
Next Review:
April 2027
Date of Issue:
November 2020
DCE Sponsor:
Deputy Secretary, Corporate Services, Finance and Enablement
Last Review:
April
Policy Owner:
Head of Integrity
Approved By:
Secretary for Business, Innovation & Employment and
Classification:
UNCLASSIFIED
Chief Executive
Page 5 of 6

8  Gifts, hospitality or entertainment from an embassy, consulate,
  foreign government or business
8.1
These should be approached in a way that is consistent with the principles outlined in the Policy
Statements section of the Gifts, Hospitality and Entertainment Policy. When responding to offers
from an embassy, consulate, foreign government or business, staff and people leaders should
consider the options outlined in paragraph 5 above, and ensure that our response to these does
not affect our decision making, or create a perception that our people are acting without
impartiality or integrity.
8.2
Gifts from embassies, consulates, foreign governments or businesses can create security concerns
and introduce vulnerabilities to MBIE work areas or systems.
8.3
All accepted offers of gifts, hospitality or entertainment from an embassy, consulate, foreign
government or business (including those with a monetary value of less than $50) must be
recorded in Camms.
8.4
Accepted gifts should not be stored, used or displayed in restricted MBIE areas (any sites not
accessible to the general public). Staff must seek advice from Protective Security before displaying
a gift in a non-restricted area.
8.5
Staff must not accept electronic devices (including USBs) of any value.
8.6
Where staff are offered gifts by an embassy, consulate, foreign government or business
repeatedly or these are of significant monetary value, further guidance should be sought from
Protective Security.
9  Monitoring and reporting
9.1
People leaders/managers will review the response recorded in Camms to check that the offer of a
gift, hospitality or entertainment was disposed of as agreed. This could occur during a regular
conversation as part of MBIE’s performance and development cycle.
10 Speaking up – raising concerns or reporting wrongdoing
10.1
Anyone can report real or perceived wrongdoing, or raise concerns about an offer of a gift,
hospitality or entertainment or how this has been resolved in MBIE’s online event reporting tool,
Camms. You can raise concerns by submitting a Speaking Up event via Camms, contacting MBIE’s
workplace Integrity Line (0800 33 77 33 within NZ or +64 (9) 927 5905 overseas), or emailing the
Integrity team to raise your concern or make a complaint.
10.2
Reports of conduct or behaviour that amount to ‘serious wrongdoing’ as defined by the Protected
Disclosures (Protection of Whistleblowers) Act 2022 can also be made to MBIE’s Chief Legal
Officer or the General Manager, People and Culture. Refer to MBIE’s Protected Disclosures Policy
and Procedure for more information on how to make a disclosure.
10.3
The Integrity team will assess each concern raised and work with people to achieve a resolution.
If an investigation into wrongdoing is warranted, the people involved will have the opportunity to
respond and will be regularly updated throughout the process.
Title:
Gifts, Hospitality and Entertainment Procedure
Next Review:
April 2027
Date of Issue:
November 2020
DCE Sponsor:
Deputy Secretary, Corporate Services, Finance and Enablement
Last Review:
April
Policy Owner:
Head of Integrity
Approved By:
Secretary for Business, Innovation & Employment and
Classification:
UNCLASSIFIED
Chief Executive
Page 6 of 6