Gifts, Benefits and Hospitality

Management of the provision of gifts, benefits and hospitality

This chapter sets out the requirements for providing gifts, benefits and hospitality.

HOST test

The HOST test can be used as a guide to decide the appropriateness of offering hospitality.

Hospitality

To whom is the gift or hospitality being provided?

Will recipients be external business associates, or individuals of the school community?

Objectives

For what purpose will hospitality be provided?

Is the hospitality being provided to further the conduct of official business? Will it promote and support government policy objectives and priorities? Will it contribute to staff wellbeing and workplace satisfaction?

Spend

Will public funds be spent?

What type of hospitality will be provided? Will it be modest or expensive, and will alcohol be provided as a courtesy or an indulgence? Will the costs incurred be proportionate to the benefits obtained?

Trust

Will public trust be enhanced or diminished?

Could you publicly explain the rationale for providing the gift or hospitality? Will the event be conducted in a manner which upholds the reputation of the public sector? Have records in relation to the gift or hospitality been kept in accordance with reporting and recording procedures?

Requirements for providing gifts, benefits and hospitality

Gifts, benefits and hospitality may be provided when welcoming guests to facilitate the development of business relationships, further school outcomes and to celebrate achievements.

When deciding whether to provide gifts, benefits or hospitality or the type of gift, benefit or hospitality to provide, school staff must ensure:

• any gift, benefit or hospitality is provided for a business reason that furthers the conduct of official business or other legitimate organisational goals, or promotes and supports government, department or the school’s objectives and priorities
• that any costs are proportionate to the benefits obtained for the school, and would be considered reasonable in terms of community expectations (the ‘HOST’ test above is a good reminder of what to think about in making this assessment)
• it does not raise an actual, potential or perceived conflict of interest.

School staff must keep detailed records when providing gifts or hospitality that captures:

• legitimate business benefit or purpose of providing the gift or hospitality
• details of the gift or hospitality including invoices and order forms
• details of approving officer and records of approval.

Records must be available to audit and are ideally kept per transaction in CASES21.

Containing costs

School staff must contain costs involved with providing gifts, benefits and hospitality wherever possible, and comply with the financial probity and efficient use of resources guidance outlined in the Code of conduct for Victorian public sector employees (for members of the teaching service) and the Code of conduct for directors of public entities (for school councillors).

The following questions may be useful to assist school staff to decide on the type of gift, benefit or hospitality to provide:

• Will the cost of providing the gift, benefit or hospitality be proportionate to the potential benefits?
• Is an external venue necessary or does the school have facilities to host the event?
• Is the proposed catering or hospitality proportionate to the number of attendees?
• Does the size of the event and number of attendees align with intended outcomes?
• Is the gift symbolic, rather than financial, in value?
• Will providing the gift, benefit or hospitality be viewed by the public as excessive?

Hospitality guidelines

Approval for hospitality

The purchase of hospitality with departmental funds must be approved by the responsible financial delegate.

Schools are required to complete the School hospitality expense approval form (DOCX) (staff login required) and submit it to the principal or school council president for approval.

An approval form must be approved prior to confirmation of an event unless extenuating circumstances prevent this. Such circumstances must be noted on or attached to the form. Any prior verbal approval must also be noted.

An approval form is required prior to processing an invoice for any amount of hospitality. Blanket approvals for a period of time are not acceptable.

Non-allowable hospitality

Hospitality is not to be provided in the following situations:

• for school staff that is of an unofficial or private nature, including birthdays or farewells (other than retirements)
• for end of year celebrations beyond the definition of ‘light refreshments’ below.

Business meetings

Working meals involve participation of persons outside the school.

School council meetings are business meetings and therefore light catering is permitted.

Where a business meeting is expected to be of extended duration it may be appropriate to offer tea, coffee, milk and biscuits which would be a small cost.

The provision of working meals must be limited to ‘light refreshments’ and normally occur:

• at an ordinary school-based meeting location
• on non-regular occurrences, except where particular meetings are planned to continue without break for the convenience of school-based timetables.

Working meals may be provided when:

• there are organisational efficiencies in continuing the meeting through the normal meal break
• there is no reasonable alternative date and time to conduct the meeting except through a normal meal period.

Any hospitality provided for business meetings must be considered ‘light refreshments’ and be commensurate with a modest meal attendees would usually consume. A multiple-course meal at a restaurant would not meet the definition of modest and would not be approved.

Effort needs to be made to avoid meetings between 12 noon and 2 pm, unless necessary.

School staff are not permitted to claim a reimbursement or allowance for meals or beverages where the meal or entertainment has been provided as part of hospitality.

Behaviour

School staff must ensure that when hospitality is provided, participants:

• demonstrate professionalism in their conduct
• behave in a manner that upholds their duty of care to other participants.

Catered lunches

For a range of reasons, catered activities may be occasionally provided for school staff. These are likely to be limited to a lunch as part of a larger staff-related event, for example a training course, workshop, planning day seminar or conference that is held offsite.

Catered lunches are encouraged to be modest and meet the description of ‘light refreshments’ above. The staff member approving the expense must also ensure that the general community would consider it to be a reasonable public expenditure.

Provision of alcohol

The supply of alcohol at any event can lead to increased risks, including the risk of anti-social behaviour and risks to the reputation of both individuals and the school alike. Given the risks, alcohol would not normally be served at school functions or official meetings, particularly those which are attended solely by school staff. This requirement however may be waived at the discretion of the principal.

Financial delegates must only supply alcohol at an official event in accordance with the Occupational Health and Safety Act 2004, Liquor Control Reform Act 1998, Code of Conduct and Alcohol at School Events policy.

School staff must not be impaired by alcohol while working or while otherwise at a school or departmental location.

If the school hosts an event where alcohol will be served, express authorisation is required from the:

• principal if the event is held off school premises
• school council if the event is held on school premises.

Providing gifts and hospitality to non-school staff

Authorised delegates may provide gifts and hospitality to non-school staff such as external guests, presenters and delegates for legitimate business purposes. Any gift provided must be token, that is, under $50. Gifts must not bring the school into disrepute and gifts involving alcohol would not ordinarily be appropriate.

Providing gifts to volunteers is not appropriate.

Providing gifts to school staff

On occasions, the department or school may wish to recognise significant staff achievements and provide token gifts as part of:

• a reward and recognition event
• acknowledging length of service milestones or retirements.

A token gift, such as a card or flowers, may be sent to family members in the event of a school staff member’s death. This may also help their colleagues with their bereavement.

Authorised delegates must consider in providing any gifts if there have been multiple recent events that would result in the perception of excess.

School staff are required to seek approval from the school council when issuing non-token gifts to staff that are funded by public monies. However, school council cannot approve:

• gifts to other school councillors as this would raise an actual, potential or perceived conflict of interest
• expenditure on gifts that are outlined in ‘Unacceptable provision of gifts to personnel’ section below
• gifts that depart from the financial responsibility obligations set out in the Code of conduct for directors of Victorian public entities.

Funds sourced from staff collections do not constitute public monies.

Unacceptable provision of gifts to personnel

Public monies must not be used to provide gifts to school staff in other celebratory events such as:

• birthdays
• marriages
• the birth of children
• care packages, wellbeing packs or holiday hampers sent to all staff.

Items offered must be appropriate to the workplace context and preferably not involve alcohol. Gift vouchers are not permitted to be consistent with the Victorian Public Sector Commission requirement that school staff do not accept them.