Key information
Decision type: Director
Reference code: DD2372
Date signed:
Decision by: Martin Clarke (Past staff), Executive Director of Resources
Executive summary
This decision form sets out the GLA’s process for dealing with corporate gifts.
Decision
Part 1: Non-confidential facts and advice
Occasionally the GLA receives corporate gifts from stakeholders. Corporate gifts are gifts to the organisation as a whole rather than to particular individuals within the organisation. They must be declared to the Monitoring Officer in the normal way (as set out in the GLA Gifts and Hospitality Policy and Procedure), but do not need to be recorded against an individual’s declarations of gifts and hospitality (which are published on the GLA’s website).
This decision form sets out the GLA’s process for dealing with corporate gifts.
The approach to corporate gifts will be to:
• Relay the GLA’s gratitude to the donor, once the decision has been taken by a senior officer to receive a particular corporate gift with a clear reason for why it is appropriate to do so (e.g. maintaining good stakeholder relations);
• Hold on to the corporate gift for an appropriate length of time which would normally be at least the length of one Mayoral term (i.e. four years) so as to demonstrate the organisation’s gratitude and maintain good relations; and
• Consider the scope for donating the corporate gift to benefit a suitable charitable cause, once the length of time referred to above has elapsed.
In terms of the last point, the following would apply:
• It would need to be clear to the GLA what the valuation of the corporate gift at that point of time is;
• That charitable cause would need to be of benefit to London and Londoners (e.g. the Mayor’s Fund for London); and
• Appropriate records would need to be kept as to the course of action taken.
The lead senior officers in such cases would be:
• The Executive Director of Resources; and
• The Monitoring Officer.
It is viewed that the approach set out above is appropriate in the circumstances and beneficial to both the GLA and to London.
There are no specific equalities issues arising.
The GLA will act with impartiality at all times when dealing with the receipt and disposal of corporate gifts.
Finance officers will ensure that corporate gifts are securely stored while held by the GLA and that they have valuations attached to them for insurance purposes.
There are no budget implications for the GLA as no income from corporate gifts is budgeted for and so there are no financial implications arising from corporate gifts being donated to a charity.
Any additional insurance costs arising from holding corporate gifts are marginal.
Section 2 of the Bribery Act 2010 makes it a criminal offence to request, agree to receive, or accept a financial or other advantage, intending that, as a result, a relevant function or activity should be performed improperly, or as a reward for such improper performance. The GLA Gifts and Hospitality Policy and Procedure also applies in respect of gifts accepted on behalf of the GLA, providing that such gifts should be registered with the Monitoring Officer in the normal way. . The GLA as a public body must conduct itself impartially and without being influenced by any improper inducement. Further, neither the retention by the GLA of a corporate gift, nor any indication of gratitude by the GLA for a corporate gift, should be reasonably perceivable as indicating any departure from impartiality or normal procedures in favour of the donor of the gift. Accordingly, careful consideration should be given as to whether a corporate gift should be received, and if received, retained.
Officers must ensure that any subsequent donation by the GLA of corporate gifts received as referred to above does not have the effect of providing recipients with an unfair advantage in the market in which they operate. Among other things, the value of the gift will be material here; if there is any doubt, legal advice should be taken.
GLA Gifts and Hospitality Policy and Procedure which is available via the GLA’s website: /who-we-are/governance-and-spending/good-governance/our-procedures
Signed decision document
DD2372 Corporate gifts