1. Introduction

1.1 BEN - Motor and Allied Trades Benevolent Fund is committed to the practice of responsible corporate behaviour and as such, is also committed to carrying out its business openly, fairly and honestly. We therefore maintain a zero-tolerance policy towards bribery, corruption and anti-competitive practices.

We recognise that trust and confidence in the propriety of our activities is essential to our continuing success and growth, and in order to foster the trust and confidence that clients, suppliers, workers and the community in general have in BEN, it is important that BEN, our employees and officers behave, and are seen to behave, appropriately and honestly at all times.

1.2 This Hospitality and Gifts Policy aims to:

1.2.1 Protect the reputation of BEN;

1.2.2 Protect employees and officers of BEN from accusations of impropriety;

1.2.3 Ensure that all clients and suppliers are dealt with on an equal basis;

1.2.4 Avoid any potential conflicts between employees' and officers' private interests and professional duties;

1.2.5 Instil a strong anti-corruption culture in BEN and put in place a gift and hospitality monitoring process to further compliance with the Bribery Act 2010.

1.3 Employees and officers are advised that, notwithstanding anything contained herein, where there is any doubt over the permissibility or propriety of accepting a gift or hospitality offer they should decline that offer. Nothing should be accepted which would bring BEN into disrepute.

1.4 This policy applies to:

1.4.1 BEN and to any associated persons as defined by the Bribery Act 2010, including (but not limited to) contractors, volunteers and trustees of the charity and of the closed final salary pension and life assurance schemes.

1.4.2 Certain contractors whenever they have contact with an individual or organisation outside of BEN for BEN business purposes, prospective and existing suppliers of BEN, public bodies with whom BEN has a non-commercial relationship and other charities.

For the purposes of this policy, the term ‘employees and officers' shall be taken to include anyone associated with BEN in any capacity stated above. This policy is non-exhaustive and all aspects of BEN's business should be considered within its spirit.

1.5 BEN staff are required to report internally amongst other things:

1.5.1. Any financial interest that they have or an associate of theirs has in an external person relationship. The term, ‘associate' could include spouses, partners or extended family members.

1.5.2. The offer and receipt of all forms of business related gift and hospitality with limited exceptions.

1.5.3. The rejection of the offer of any business-related gift and hospitality

1.5.4. Any form of improper behaviour by an external person or a work colleague.

The offer and receipt of certain types of business related gift and hospitality are prohibited to BEN employees or discouraged. These include personal payments that do not form part of legitimate business hospitality, gifts that are more than mere tokens, gifts and hospitality to family members, and all forms of gifts and hospitality that are offered during the process of bidding or tendering for contracts.

Any external contractor who disregards these requirements or otherwise acts improperly may find their relationship with BEN curtailed either at an individual or corporate level. Further action may be taken depending on the gravity of the situation.

2. Receiving Personal Gifts

2.1 Save for gifts of low value (under £15.00), employees and officers of BEN are not permitted to accept any gifts from customers, suppliers or other third parties involved with BEN. Gifts of cash should not be accepted under any circumstances.

2.2 Third parties wishing to make donations must have it made clear that such donations will be paid directly to the Finance Director's office to enable them to be allocated to the appropriate cost centre. All such donations must be acknowledged by a written receipt, with the sum identified, to the donor.

2.3 BEN recognises that there may be exceptional instances when refusing a gift will cause significant offence or embarrassment. In such instances the gift may be accepted and subsequently donated to BEN (by following the procedure outlined in 4.2).

3. Corporate Hospitality

3.1 "Corporate Hospitality", for the purposes of this policy, is any form of accommodation, entertainment or other hospitality provided for an employee or officer of BEN by a third party and which is extended to the employee or officer solely or significantly due to his position as a representative of BEN. This excludes the classes of hospitality identified in paragraph 3.2 below.

3.2 For the purposes of this policy and for the sake of clarity, the following are not normally considered Corporate Hospitality and will not require any approval prior to acceptance:

3.2.1 Normal working lunches or refreshments provided during a business visit;

3.2.2 Hospitality extended to employees and officers attending a BEN approved seminar, conference or other external event, provided that such hospitality is extended to all who are in attendance;

3.2.3 Free seminars, talks or workshops, provided that they are free to all in attendance and are not provided solely for employees and officers of BEN.

4. Hospitality and Gifts Register

4.1 The Register shall be held by the Finance Director/Company Secretary ("the Registrar").

4.2 All offers of gifts and hospitality must be recorded in writing, including all of the information specified in this policy and must be signed and dated by the employee or officer and the relevant manager before being given to the Registrar, who shall update the Register accordingly. See section 4.5 below on how to complete the register.

4.3 The written record must be completed as soon as is reasonably practicable, and be filed with the Registrar within 5 working days of the offer of the gift or hospitality.

4.4 It is anticipated that instances may arise where a gift accepted by BEN or one of its employees or officers has not been donated by the time that the relevant entry is made on the Register. In such cases the Register must be updated within 10 working days of the date on which the donation was made.

4.5 All employees and officers are required to obtain approval before accepting any form of gift or corporate hospitality which is offered to them. Approval must be sought from their Head of Department or, where the value of the gift or corporate hospitality is likely to be over £15, from their Director.

An accurate record must be kept of all gifts and corporate hospitality offered to BEN or to employees and officers of BEN for entry on the Register. Any employee or officer offered any gift or corporate hospitality must record, as soon as is reasonable practicable:

4.5.1 A description of the gift or hospitality offered;

4.5.2 An estimation of the likely value of the gift or hospitality;

4.5.3 Whether it was rejected or accepted;

4.5.4 If accepted, why it was accepted; and

4.5.5 From whom prior approval was obtained.

5. Code of Business Conduct

In line with this policy, BEN's Code of Business Conduct outlines our commitment to compliance with the Bribery Act 2010 to those external organisations and individuals with whom BEN conducts business dealings. The aim of this Code is to prevent bribery, corruption and anti-competitive practices.

As part of our commitment to compliance with the Bribery Act 2010, BEN undertakes to examine terms with all new providers and suppliers to find out whether they offer appropriate protection against bribery, corruption and anti-competitive practices.

It is possible we may seek revisions to the terms of the agreement with our existing providers and suppliers at a later date to ensure we have such protection.

Further details can be found in the Code of Business Conduct attached at appendix 1.

6. Breach of this Policy

6.1 Compliance with this policy is essential to the protection of BEN's reputation and that of its employees and officers.

6.2 Any employee or officer who is found to have acted in contravention of this policy or its principles may be subject to disciplinary action, including summary dismissal where the breach amounts to gross misconduct; refer to BEN's Disciplinary and Performance Improvement Policy which can be found in the Employee Staff handbooks and Bank Workers Handbooks for more details.

6.3 It is the responsibility of all BEN staff to ensure that bribery is prevented, detected and reported and all such reports should be made in accordance with BEN's Whistleblowing Policy which can be found in the Employee Staff handbooks and Bank Workers Handbooks.

6.4 Any employee or officer found giving or receiving bribes or bribing a foreign official will face criminal charges under the provisions of the Bribery Act 2010. Anyone found guilty of bribery, will be responsible for bearing any related remedial costs such as losses, court fees or expenses.

7. Status of this Policy

This policy is not part of your contract of employment and does not create contractual rights or obligations. We may amend it at any time.

8. The Law relating to this Document

The Bribery Act 2010.