{{org_field_logo}}

{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Staff Gift and Hospitality Policy

1. Purpose

The purpose of this Staff Gift and Hospitality Policy is to provide clear, legally compliant and ethical guidance to all temporary workers and staff of {{org_field_name}} regarding the acceptance, offering or declaration of gifts and hospitality in the course of their work.

This policy is intended to ensure that interactions between temporary workers, clients, service users, their families, suppliers, contractors and other stakeholders are transparent, appropriate and free from bribery, improper influence, favouritism or the perception of improper influence.

{{org_field_name}} recognises that temporary workers may undertake assignments in healthcare, social care or other sensitive environments where service users, patients or their families may wish to show appreciation by offering gifts or hospitality. Such offers must be managed carefully in order to maintain appropriate professional boundaries, protect vulnerable people and preserve the integrity and independence of workers.

{{org_field_name}} operates as an employment agency and/or employment business supplying temporary workers to client organisations and does not itself carry on regulated care activities requiring registration with the Care Quality Commission. Temporary workers must nevertheless comply with the lawful policies and procedures of the client organisation at which they are placed and, where applicable, the requirements of their professional regulator.

This policy supports compliance with the Bribery Act 2010 and, where applicable to the individual worker, relevant professional standards including the NMC Code for registered nurses, midwives and nursing associates and applicable codes of professional conduct.

2. Scope

This policy applies to:

• All temporary workers of {{org_field_name}} under zero-hours or casual contracts, including registered nurses, healthcare assistants, and support workers
• All directors and office staff involved in the administration and delivery of services
• All interactions with clients, service users, relatives, contractors, suppliers, and external stakeholders

This policy applies during all work-related activities, whether on assignment, during travel, or when representing {{org_field_name}} at events, meetings, or conferences.

3. Related Policies

• Code of Conduct for Temporary Workers
• Safeguarding Adults and Children Policy
• Complaints and Whistleblowing Policy
• Staff Wellbeing and Mental Health Policy
• Disciplinary Policy
• Data Protection and Confidentiality Policy

4. Legal Framework

This policy is underpinned, where applicable, by:

• The Bribery Act 2010
• The Equality Act 2010
• The Human Rights Act 1998
• The Care Act 2014
• The NMC Code: Professional Standards of Practice and Behaviour for Nurses, Midwives and Nursing Associates, where applicable

Nothing in this policy permits a worker or member of staff to accept, request, offer, promise or give a gift, hospitality or other advantage where doing so would constitute bribery or other unlawful conduct.

Temporary workers must also comply with any lawful gifts, hospitality, anti-bribery, conflicts of interest and professional-boundary requirements imposed by the client organisation at which they are undertaking an assignment.

5. Policy Statement

{{org_field_name}} is committed to maintaining the highest standards of integrity, professionalism, and accountability. The acceptance or offering of gifts and hospitality must not influence, or be perceived to influence, professional judgement, decisions, or the delivery of care. Temporary workers must maintain appropriate professional boundaries at all times. This policy ensures that workers act transparently and avoid situations where their professional independence could be compromised.

6. Principles

All staff must:

• Decline any gifts or hospitality which may appear to affect their professional judgement or independence
• Declare and seek authorisation for any gift or hospitality, however small, following the procedures in this policy
• Ensure that all offers of gifts or hospitality are managed sensitively to protect the dignity of clients and the integrity of professional relationships
• Never solicit gifts, hospitality, or personal favours from clients, relatives, suppliers, or stakeholders
• Comply with all relevant legislation and professional codes

7. Definitions

Gift: Any item of value, including money, vouchers, food, drink, goods, or personal items offered by clients, their families, colleagues, or other stakeholders. Hospitality: Invitations to meals, drinks, entertainment, travel, or events offered to staff by clients, relatives, suppliers, or stakeholders.

Bribe: A gift or offer made to influence a person to act improperly or to reward improper behaviour.

Professional Boundary: The limits that define a safe and appropriate relationship between a worker and a client, ensuring professional integrity is maintained.

8. Acceptable and Unacceptable Gifts

8.1 Acceptable Gifts

A gift must never be accepted solely because its monetary value falls below a particular amount. There is no monetary threshold under the Bribery Act 2010 below which a gift or other advantage is automatically lawful.

Subject to the conditions below, temporary workers may accept an occasional low-value, non-cash token of genuine appreciation, such as chocolates, biscuits or flowers, with an estimated value of less than £20.

The £20 amount is an internal policy threshold only. It does not constitute a legal exemption or safe harbour under the Bribery Act 2010.

A low-value gift may only be accepted where all of the following conditions are satisfied:

• The gift is unsolicited and is offered as a genuine token of appreciation.
• It is not offered in return for favourable treatment, preferential treatment, the improper performance of a function or activity, or any other advantage.
• Acceptance would not influence, and could not reasonably be perceived as influencing, the worker’s professional judgement or conduct.
• Acceptance is permitted under the policies and procedures of the client organisation at which the worker is undertaking the assignment.
• Acceptance is compatible with any professional code or regulatory requirements applicable to the worker.
• The gift is not cash or a cash equivalent.
• There is no pattern of repeated or cumulative gifts from the same person which could create a conflict of interest or inappropriate relationship.
• The gift is declared in accordance with Section 9 of this policy.

Hospitality connected with an official meeting, training event, conference or similar legitimate business activity may only be accepted where it is reasonable and proportionate, has a genuine business purpose, does not create an obligation or expectation of favourable treatment and is permitted by {{org_field_name}} and the relevant client organisation.

8.2 Unacceptable Gifts and Hospitality

Temporary workers and staff must not request, agree to receive or accept:

• Cash.
• Cash equivalents, including gift cards or vouchers.
• Gifts of significant personal or financial value, including jewellery, electronics or other valuable personal items.
• Loans or other personal financial arrangements from service users, patients, their relatives or persons connected with them.
• Gifts or hospitality offered on condition that the recipient provides favourable or preferential treatment.
• Any gift, hospitality, payment, reward or other advantage intended to induce or reward improper performance.
• Gifts or hospitality which could reasonably be perceived as compromising professional judgement, independence or impartiality.
• Repeated or cumulative gifts from the same service user, patient, relative, supplier or other stakeholder where the pattern creates, or could reasonably be perceived as creating, an inappropriate relationship or obligation.
• Gifts or hospitality prohibited by the client organisation’s applicable policies.
• Gifts or hospitality prohibited by an applicable professional code or regulatory requirement.

Where there is any doubt about whether a gift or hospitality may lawfully and appropriately be accepted, the worker must not accept it until advice has been obtained from {{org_field_name}}.

9. Declaration of Gifts and Hospitality

All gifts and hospitality (including those accepted or declined) must be declared to {{org_field_name}} by completing the Gifts and Hospitality Declaration Form. The declaration must include:

• The date the gift or hospitality was offered
• The nature and estimated value of the gift or hospitality
• The name of the person or organisation offering the gift
• The decision to accept or decline

The director will maintain a Gifts and Hospitality Register which will be regularly reviewed.

10. Managing Offers of Gifts

Temporary workers must:

• Politely and respectfully decline any gift or hospitality that is prohibited by this policy, by the client organisation’s applicable rules, by an applicable professional code or by law.
• Decline any gift or hospitality that could undermine professional boundaries, independence or impartiality or could reasonably give rise to a perception of favouritism or improper influence.
• Seek advice from {{org_field_name}} where they are uncertain whether an offer may be accepted.
• Record offers of gifts or hospitality in accordance with Section 9, including offers which are declined.

Where declining an otherwise genuine and low-value token of appreciation may cause significant distress or offence, a worker may only accept the item temporarily where:

• there is no reason to believe that the gift constitutes, or is intended to constitute, a bribe or improper inducement;
• acceptance is not expressly prohibited by the client organisation or an applicable professional requirement;
• the worker informs {{org_field_name}} and the appropriate representative of the client organisation as soon as reasonably practicable; and
• the item is dealt with in accordance with instructions provided by {{org_field_name}} and/or the client organisation, which may include sharing the item with the wider team, returning it or donating it appropriately.

The possibility that refusing a gift may cause embarrassment, offence or disappointment does not permit a worker to accept a gift, hospitality or other advantage which is unlawful, constitutes or may constitute bribery, or is expressly prohibited by the client organisation or an applicable professional requirement.

11. Bribery and Conflicts of Interest

{{org_field_name}} prohibits bribery and corrupt conduct in connection with any part of its business.

No director, employee, temporary worker or other person acting on behalf of {{org_field_name}} may:

• offer, promise or give a financial or other advantage to another person intending to induce or reward the improper performance of a relevant function or activity;
• request, agree to receive or accept a financial or other advantage in circumstances prohibited by the Bribery Act 2010;
• offer, promise or give a financial or other advantage to a foreign public official with the intention prohibited by the Bribery Act 2010;
• use a third party to offer, promise, give, request, receive or facilitate a bribe; or
• conceal, disguise or inaccurately record a gift, hospitality, payment or other advantage.

Temporary workers and staff must not request gifts, hospitality, rewards, personal favours or financial benefits from service users, patients, relatives, clients, suppliers or other stakeholders.

Temporary workers and staff must avoid personal, financial or other relationships with clients, service users, patients or their relatives where the relationship creates, or could reasonably be perceived as creating, a conflict between personal interests and professional responsibilities.

Any actual or potential conflict of interest must be disclosed promptly to {{org_field_name}} and, where relevant, to the client organisation.

{{org_field_name}} will take proportionate measures designed to prevent bribery by persons performing services for or on its behalf. These measures will include, as appropriate:

• management commitment to preventing bribery;
• proportionate assessment of bribery risks;
• appropriate due diligence;
• communication of anti-bribery requirements and relevant training;
• appropriate recording and monitoring of gifts and hospitality; and
• periodic review of the effectiveness of anti-bribery arrangements.

Any worker or member of staff who is offered a bribe, is asked to make a bribe, suspects that bribery has occurred or believes that bribery may occur must report the matter promptly to the director or through the agency’s applicable whistleblowing or reporting procedure.

No worker will be subjected to detrimental treatment by {{org_field_name}} for refusing to participate in bribery or for raising a genuine concern about suspected bribery in good faith.

A suspected breach will be investigated in accordance with the agency’s applicable procedures. Where there is evidence of criminal conduct, the matter may be reported to the police or another appropriate enforcement authority. Any internal disciplinary or contractual action is separate from any criminal investigation or proceedings.

12. Professional Boundaries

Temporary workers must:

• Ensure that the relationship with service users and their families remains strictly professional
• Avoid accepting personal gifts or hospitality from clients where this could lead to expectations of special treatment or exploitation of a vulnerable person
• Always refer to the client’s own policies if they have specific restrictions regarding gifts and hospitality
• Seek support from the director if challenged about refusing a gift

13. Training

{{org_field_name}} will:

• Provide training on professional boundaries, conflicts of interest, and this policy as part of mandatory induction
• Include guidance on gifts and hospitality within safeguarding and professional standards training
• Reinforce this policy through supervision, appraisal, and regular updates
• Provide case studies and reflective learning opportunities where appropriate

Temporary workers must:

• Complete all required training before undertaking assignments
• Seek clarification where unsure about appropriate actions regarding gifts and hospitality
• Reflect on professional boundaries as part of ongoing development

14. Recording and Monitoring

The director will:

• Maintain a Gifts and Hospitality Register to record all declared gifts and hospitality
• Monitor the register for patterns, trends, or concerns
• Review the register regularly and take appropriate action if repeated or high-value offers are noted
• Report concerns to relevant regulators or safeguarding bodies where appropriate

15. Breach of Policy

A breach of this policy may result in:

• Disciplinary action under the Disciplinary Policy
• Suspension or removal from assignment pending investigation
• Reporting to relevant regulatory or safeguarding authorities
• Termination of employment or contractual relationship if serious misconduct is established

Temporary workers are expected to cooperate fully with any investigation relating to gifts or hospitality.

16. Director’s Responsibilities

As {{org_field_name}} operates as an employment agency and/or employment business supplying temporary workers to client organisations and does not itself carry on a regulated activity requiring registration with the Care Quality Commission, responsibility for the implementation of this policy rests with the director or another appropriately authorised senior person designated by {{org_field_name}}.

The director will:

• Take overall responsibility for the implementation, monitoring and review of this policy.
• Promote compliance with the Bribery Act 2010 and the agency’s anti-bribery requirements.
• Ensure that appropriate information and training concerning gifts, hospitality, conflicts of interest and professional boundaries are provided to relevant workers and staff.
• Review declarations of gifts and hospitality and ensure that appropriate action is taken where concerns are identified.
• Ensure that the Gifts and Hospitality Register is appropriately maintained.
• Respond promptly to concerns raised by temporary workers, clients or other stakeholders.
• Work with client organisations where an incident concerns a temporary worker undertaking an assignment at the client’s premises or service.
• Ensure that temporary workers are informed that they must comply with relevant client-specific restrictions concerning gifts and hospitality.
• Promote a culture of integrity, transparency and appropriate professional boundaries throughout the agency.
• Ensure that suspected bribery or other criminal conduct is escalated to the appropriate authority where required.

If {{org_field_name}} subsequently changes its business model and begins directly carrying on a regulated activity, it must reassess its CQC registration obligations and review this policy accordingly.

17. Working with Client Organisations

{{org_field_name}} will:

• Inform temporary workers of client-specific policies on gifts and hospitality during induction and placement briefings
• Work with clients to manage concerns about gifts or hospitality involving temporary workers
• Support client organisations during audits, investigations, or inspections related to professional conduct
• Promote shared learning to improve practice and uphold professional boundaries

18. Continuous Improvement

The director will:

• Review this policy annually or sooner if required due to changes in legislation, guidance, or agency learning
• Analyse incidents, complaints, and feedback to identify trends or risks related to gifts and hospitality
• Update training materials and guidance where needed
• Promote reflective learning and discussion of professional boundaries during supervision and appraisal

19. Policy Review

This policy will be reviewed at least annually by the director of {{org_field_name}} and earlier where necessary following:

• a relevant change in legislation;
• a material change to applicable professional or regulatory standards;
• a significant bribery, gifts, hospitality or conflicts-of-interest incident;
• findings arising from an investigation, audit or complaint;
• a material change to the activities or business model of {{org_field_name}}; or
• identified learning indicating that the policy is no longer effective or appropriate.

If {{org_field_name}} changes its activities so that it begins to carry on a regulated activity within the meaning of the Health and Social Care Act 2008 regulatory framework, the agency must separately assess whether Care Quality Commission registration is required.

All material changes to this policy will be communicated to relevant temporary workers and staff.

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Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.