21 April 2026
LGOIMA 26-064
Simon Glenn
[FYI request #34195 email]
Tēnā koe Simon
Probity and social drinking with contractors
Thank you for your request of 22 March 2026, in which you sought information about how many
Wellington Water staff have been invited to social drinks with contractors, and whether any such
interactions have been disclosed in a register.
On 2 April 2026, you were contacted to seek clarification and refinement of your request. Your
clarified request was received on 6 April 2026. The relevant correspondence is included in full at
Appendix One.
In accordance with the Local Government Official Information and Meetings Act 1987 (LGOIMA –
the Act), Wellington Water’s response is set out below.
Scope of the request
Your request has been considered in two parts:
•
Part A: Whether social drinks with contractors have been disclosed in any Wellington
Water register
•
Part B: How many staff have been invited to social drinks with contractors (requiring an
email and IT system search)
Part A: Disclosure in registers
We are pleased to provide the following information relating to your request:
The Wellington Water Gifts Register requires that:
• All offers of gifts or entertainment valued at $50 or more must be recorded
• Gifts under $50 are not required to be recorded, unless there is a concern (in which case
staff are directed to consult their manager)
• All Christmas gifts, regardless of value, must be recorded and are managed centrally
• Gifts over $100 should not be accepted, except in exceptional circumstances, and must be
recorded regardless of whether they are accepted
A search of the Gifts Register confirms that there are no entries that record or disclose social
drinks with contractors.
Additionally, Section 5.4 of the Wellington Water Limited Code of Conduct provides that staff must
not accept gifts or benefits that could compromise, or be perceived to compromise, their integrity.
Part B: Number of staff invited to social drinks with contractors
For the second part of your request, following your clarification and suggested search terms
(Project Manager, Contract Manager, and Procurement Manager), IT searches were undertaken for
the relevant timeframes. The search parameters and results are provided at Appendix Two. Names
have been withheld under section 7(2)(a) of the Act to protect the privacy of individuals.
These searches returned a total of 33,329 results. Reviewing, assessing, and extracting relevant
information from this volume of material would require substantial collation and manual analysis.
As a result, this part of your request is refused under section 17(f) of the LGOIMA, as it would
require substantial collation and research. Processing this volume of material would involve a
disproportionate and unreasonable diversion of Wellington Water’s staff resources.
The public interest in release has been considered and has been assessed. As noted above,
Wellington Water Limited has rules in its Code of Conduct which prevent staff from accepting gifts
or benefits that could compromise, or be perceived to compromise, their integrity.
Further as noted, any gift or benefit received over $50 is required to be registered. All staff are
required to adhere to Wellington Water Limited’s Code of Conduct. Breach of the Code may give
rise to disciplinary action.
You have the right to seek an investigation and review of this response by the Ombudsman.
Information about how to make a complaint is available at www.ombudsman.parliament.nz or by
calling 0800 802 602.
If you would like to discuss this response, please contact us at
[Wellington Water Limited request email]
Nāku noa, nā
Erin Ganley
Chief Risk and Compliance Officer
