Gifts & Hospitality Policy

1. Introduction and Purpose

This Gifts and Hospitality Policy (the "Policy") sets out the standards and procedures that Alcohol Ltd (Company Number: 04854930) ("the Organisation") adheres to in relation to the giving and receiving of gifts and hospitality.

As an organisation engaged in lobbying and advocacy on behalf of the UK alcohol industry, we recognise the importance of operating with the highest standards of transparency, integrity, and ethical conduct. This Policy is designed to:

• Prevent bribery and corruption in accordance with the Bribery Act 2010;
• Ensure compliance with the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 and other relevant UK legislation;
• Maintain the Organisation's reputation for ethical conduct and good governance;
• Protect employees, directors, and stakeholders from any perception of improper influence or conflicts of interest;
• Provide clear guidance on what is acceptable and unacceptable in relation to gifts and hospitality.

2. Scope and Application

This Policy applies to:

• All directors, officers, employees, contractors, consultants, and representatives of Alcohol Ltd;
• Any person acting on behalf of the Organisation in any capacity;
• All business dealings and interactions with public officials, civil servants, parliamentarians, local government officials, industry stakeholders, suppliers, and other third parties.

This Policy covers both the giving and receiving of gifts and hospitality in all forms, whether directly or indirectly, in the UK or abroad.

3. Definitions

4. General Principles

All gifts and hospitality must be:

• Reasonable and proportionate: Modest in value and appropriate to the business context;
• Transparent: Declared and recorded in accordance with this Policy;
• Legal and ethical: Compliant with all applicable laws and regulations, including the Bribery Act 2010;
• Non-reciprocal: Not given or received with the expectation of receiving something in return;
• In good faith: Intended to build and maintain legitimate business relationships.

5. Prohibited Gifts and Hospitality

The following are strictly prohibited under all circumstances:

• Cash or cash equivalents: No cash payments, loans, or cash equivalents (e.g., gift cards, vouchers that can be exchanged for cash) may be given or received;
• Gifts or hospitality intended to influence: Any gift or hospitality given or received with the intention of improperly influencing a decision, securing preferential treatment, or creating an obligation;
• Excessive or lavish gifts or hospitality: Anything that could reasonably be perceived as excessive, lavish, or disproportionate to the legitimate business purpose;
• Gifts or hospitality to or from public officials without prior approval: Any gift or hospitality involving public officials must be pre-approved in accordance with Section 7 of this Policy;
• Frequent or regular gifts or hospitality: Repeated gifts or hospitality to or from the same individual or organisation that could create a perception of improper influence;
• Gifts or hospitality during procurement or tender processes: No gifts or hospitality may be offered or accepted during any competitive tender, procurement process, or contract negotiation;
• Personal benefit: Gifts or hospitality that primarily benefit an individual personally rather than serving a legitimate business purpose.

6. Financial Thresholds and Approval Requirements

Note: Values are calculated as the total value of the gift or hospitality per person, per event or occasion. Where multiple items are received or given within a short period (e.g., 3 months) from or to the same source, the cumulative value must be considered.

7. Public Officials: Enhanced Requirements

Given the Organisation's status as a registered lobbying company under the 2014 Act, all gifts and hospitality involving public officials are subject to enhanced scrutiny under this Policy.

When seeking approval, the following information must be provided:

• Name and position of the public official;
• Nature and estimated value of the gift or hospitality;
• Business purpose and justification;
• Date and location (if applicable);
• Any potential conflicts of interest or reputational risks.

The Organisation will maintain a separate, detailed register of all gifts and hospitality involving public officials, which will be subject to regular audit and review.

8. Declaration and Record-Keeping

All gifts and hospitality, whether given or received, must be declared and recorded in the Organisation's Gifts and Hospitality Register.

8.1 Declaration Requirements

Declarations must be made within 5 working days of the gift or hospitality being given or received and must include:

• Date of gift or hospitality;
• Name and organisation of the giver or recipient;
• Description of the gift or hospitality;
• Estimated monetary value;
• Business purpose and context;
• Approval reference (if applicable);
• Name and signature of the person making the declaration.

8.2 Register Maintenance

The Gifts and Hospitality Register will be:

• Maintained by the Compliance Officer or designated administrator;
• Subject to quarterly internal review by senior management;
• Audited annually by an independent party where appropriate;
• Retained for a minimum of 6 years in accordance with statutory requirements;
• Made available for inspection by regulatory authorities upon request.

8.3 Transparency and Public Disclosure

In line with best practice for lobbying organisations, Alcohol Ltd commits to publishing an annual summary of gifts and hospitality involving public officials on our website. This summary will include aggregated data while respecting privacy and confidentiality where appropriate.

9. Approval Process

Where prior approval is required under this Policy, the following process must be followed:

1. Submit Request: Complete the Gifts and Hospitality Approval Form and submit it to the relevant approver (Director, Senior Manager, or Compliance Officer) at least 5 working days in advance where practicable.
2. Review: The approver will assess the request against the criteria set out in this Policy, considering value, business purpose, potential conflicts of interest, and reputational risk.
3. Decision: Approval may be granted, granted with conditions, or refused. The decision will be communicated in writing with reasons provided if approval is refused.
4. Record: All approvals and refusals will be recorded in the Gifts and Hospitality Register.

10. Compliance with UK Lobbying Regulations

Alcohol Ltd is committed to full compliance with the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 and the Register of Consultant Lobbyists.

Where required, the Organisation will:

• Register with the Office of the Registrar of Consultant Lobbyists;
• Submit quarterly information returns detailing lobbying activities and clients;
• Disclose any gifts or hospitality involving public officials in accordance with statutory requirements;
• Adhere to the UK Public Affairs Council Code of Conduct and other relevant industry standards.

11. Refusal of Gifts and Hospitality

If a gift or hospitality is offered that does not comply with this Policy, or if acceptance would create a conflict of interest or reputational risk, it must be politely declined.

If a gift or hospitality has already been received and subsequently deemed inappropriate, it must be:

• Returned to the giver with a polite explanation;
• Donated to charity (with the giver's consent where appropriate);
• Disposed of in an appropriate manner;
• Reported to a Director or the Compliance Officer.

12. Training and Awareness

All employees, directors, and representatives will receive training on this Policy and the Organisation's ethical standards as part of induction and on an ongoing basis.

Training will cover:

• The requirements of the Bribery Act 2010 and UK lobbying regulations;
• How to identify and manage conflicts of interest;
• The approval and declaration procedures;
• Real-world scenarios and case studies;
• How to raise concerns or report suspected breaches.

13. Reporting Concerns and Whistleblowing

If you become aware of, or suspect, a breach of this Policy or any conduct that may constitute bribery or corruption, you must report it immediately.

14. Consequences of Non-Compliance

Failure to comply with this Policy may result in:

• Disciplinary action, up to and including dismissal for employees;
• Termination of contracts for contractors and consultants;
• Criminal prosecution under the Bribery Act 2010 or other applicable legislation;
• Regulatory sanctions, including fines and deregistration from lobbying registers;
• Reputational damage to the Organisation and individuals involved.

15. Governance and Review

This Policy is owned by the Board of Directors and is subject to:

• Annual review: To ensure it remains current with legal requirements and best practice;
• Updates: As required in response to legislative changes, regulatory guidance, or incidents;
• Board oversight: The Board receives quarterly reports on gifts and hospitality activity and compliance.

The Compliance Officer is responsible for day-to-day administration of this Policy, maintaining the Gifts and Hospitality Register, and providing guidance to staff.

16. Related Policies and Guidance

This Policy should be read in conjunction with:

• Anti-Bribery and Corruption Policy;
• Conflicts of Interest Policy;
• Code of Conduct;
• Whistleblowing Policy;
• Data Protection and Privacy Policy.