Gifts and Hospitality Policy

1. Introduction

Square Mile is committed to maintaining the highest standards and we conduct our business in accordance with best practice in Corporate Governance. At all times we will act with integrity, objectivity, accountability, openness and honesty.

All our Employees should at all times conduct themselves with integrity, impartiality and honesty and maintain a high standard of propriety and professionalism. We do not permit our employees to accept or to offer personal benefits in order to procure services or gain influence. To do so is not only unacceptable it is also illegal in terms of the Bribery Act 2010 and carries significant penalties.

2. Purpose

The purpose of this policy is to provide guidance to Directors and Employees on the action that should be taken in the event that:

• They are offered gifts and or hospitality by external organisations;
• Have a personal, financial or other beneficial interest in any transactions between Square Mile and a third party;
• They are in a position that requires them to offer gifts/hospitality.

This policy is designed to protect both Directors and Employees from accusations of bribery and corruption and thereby also protect our reputation and to ensure that:

• The interests of clients take precedence over the interests of employees;
• Regulatory requirements are complied with;
• Standards of corporate and individual conduct are maintained.

3. Scope

This policy applies to all Directors and Employees or any third party acting for Square Mile where they are offered gifts and/or hospitality in connection with their role whilst undertaking business on behalf of Square Mile.

4. Accepting Personal Gifts and Hospitality

4.1 Gifts

• No monetary reward or equivalent e.g. gift vouchers can be accepted from outside individuals or organisations.
• If unsolicited gifts of a value of more than £25.00 arrive from third parties, they should be returned with a polite explanation that our policies do not allow their acceptance. Where it is possible that the refusal and return of a gift may cause offence, this should be discussed with a Director, or if the Gift is to a Director with the Executive Management Team to determine whether the gift should be returned and on what terms;
• Should receipt of a gift of a value of more than £25.00 be unavoidable its receipt should be referred to the Executive Management Team and recorded as our property and raffled for charity;
• There are no circumstances where a Square Mile employee or a representative of Square Mile, either in a corporate or personal capacity acting on behalf of Square Mile, may provide a gift of cash or cash equivalent e.g. gift vouchers;
• Any gift which Square Mile wish to offer to clients must be agreed by the Compliance Officer (or deputy) prior to purchase.
  

4.2 Hospitality

All hospitality provided or received by Directors or Employees of Square Mile, with the exception of “ordinary business courtesies” specified below, should be designed to enhance the quality of service to our clients. Any hospitality that is not designed to enhance the quality of service to clients should be politely declined or paid for by the employee in a personal capacity. Where hospitality is offered and it is thought it will benefit our clients this should be assessed separately and distinctly prior to potential sign off by the Compliance Officer by completing the Declaration of Gifts and Hospitality Form (Appendix1).

4.3 Ordinary Business Courtesies

The only exception to this rule is if a Director or Employee of Square Mile gives or receives an ‘ordinary business courtesy’. Ordinary business courtesies include business lunches, dinners, drinks and other reasonable business entertainment that is neither repeated nor excessive (more than £50.00 per head or heads, if provided to more than one representative of the same organisation) and the main purpose of which is to further business relationships.

In such circumstances there is no requirement to seek prior permission from the Compliance Officer.

5. Registration of Gifts and Hospitality

Square Mile maintains a register in respect of the acceptance of offers of gifts and hospitality. All staff are required to record gifts, given or received, with a value in excess of £25.00 on the Gifts and Hospitality form (see Appendix One) within 5 working days of receipt and return to the COO. Ordinary Business Courtesies over £50.00 in value should also be declared on the Gifts and Hospitality form. All offers of Hospitality, irrespective of value (which are not ordinary business courtesies) require approval prior to acceptance. The Gifts and Hospitality form should be completed to ascertain whether approval would be given.

The disclosure form is available on Datto as follows.

https://eu.workplace.datto.com/filelink/5acc6-b54b5d3-76555408b8-2

These will then be recorded in the Gifts and Hospitality Register and open to inspection by the internal and external Auditors and may be published in accordance with the Freedom of Information requirements.

Each quarter each member of staff will be asked to confirm that they have complied with this policy.

The COO will provide an annual Report to the SMIS Board on the Register of Gifts and Hospitality.

It is the responsibility of each staff member to ensure that they comply with this policy and its related procedures.

6. Training

The Bribery Act 2010 requires that Firms have a zero-tolerance approach to bribery and corruption. Training and awareness measures seek to ensure that employees are aware of the prohibitions of the Bribery Act 2010 and Square Mile’s preventative measures that have been adopted.

The training and awareness procedures include the following:

• Upon joining SM, all employees are provided with a copy of this policy.
• In the event that contents of the policy are updated, all employees will then be provided with a revised version.
• This policy will be mandatory to read. All staff will be required to provide a signed undertaking confirming adherence to the requirements contained within on a quarterly basis.
• Periodic training will be provided to employees as determined by Compliance based upon any material changes to the regulatory or legislative regime.

7. Compliance, Breach and Escalation

Employees are responsible for ensuring the timely delivery of approval forms. If a member of staff is found to have not adhered to this policy, the Finance, Risk and Compliance Committee will determine the appropriate course of action. Any expense of a Gift or Hospitality made in violation of this policy may not be reimbursed. It will further be considered a breach of this policy if an Employee requests approval for a gift or entertainment after the event, when it would have been possible to request prior approval. Any significant or repeated breaches may result in formal action being taken against an individual.

8. Risk Identification, Management and Classification

The policy aims to mitigate the following identified risks:

• To ensure that any Gifts and Hospitality do not affect the quality of the firm’s service and do not impair it’s obligations to act honestly, fairly and professionally, and in the best interest of clients.
• To ensure that employees do not pay to or accept from any party any fee or commission.
• To ensure that employees of the firm do not provide to or receive from any party (other than a client or a person acting on a client’s behalf) any non-monetary benefit other than a minor non-monetary benefit.