eurosai presentation: acceptance of gifts and hospitality

An investigation into the acceptance of gifts and hospitality

2 February 2017

An investigation in the acceptance of gifts and hospitalityPaul Wright-Anderson


Ethics and trust in government

The problem: Potential conflicts of interest arise as officials engage with a range of external organisations to carry out their work effectively

UK civil service rules (set by Cabinet Office)• Officials are allowed to accept gifts and hospitality• They must guard against any reasonable suspicion of perceived or

actual conflicts of interest

United Nations• Officials are prohibited from accepting gifts or hospitality

from actual or potential suppliers to the UN

European Union• Officials should not accept direct or indirect gifts or hospitality from

third parties• The EU may authorise gifts and hospitality where it will not

compromise, or be perceived to compromise, objectivity and independence


What we did

• Reviewed policy and guidance• Considered what good practice looked like• Interviewed key individuals in Cabinet Office and 3 depts – HMRC, BIS,

MOD • Collected and analysed published data on gifts and hospitality• Obtained and analysed three case study departments’ gift and hospitality

registers• Estimated the monetary value of gifts and hospitality• Analysed civil service survey results


Findings 1: Assessment of the guidance and registers

All case study departments had guidance. Guidance was consistent with the Civil Service principles, but fell short of good practice in some areas• Some guidance was not clear on what constituted gifts and hospitality• Registers was sometimes hard to locate and were sometimes not collated

centrally• Most guidance did not require all offers to be recorded• Some departments did not require managers to review registers• Accounting Officer not given assurance in one department

5/17 departments had not published all of their transparency data for hospitality.


Findings 2: Senior officials’ acceptance of gifts and hospitality, by department, 2012-2015


Findings 3: Senior officials accepted hospitality frequently from some organisations, 2012-2015


Findings 4: Providers of hospitality to MOD project/procurement trading arm, 2014-15


Findings 5: Review against principles of civil service code

Small minority of cases where there were problems. Some examples where might not comply with ‘purpose’:• Football matches, art exhibitions, movie premiere, tours of

entertainment attractions, accompanied by partner and/or children.

Some examples where might not comply with ‘proportionality’:• People accepting hospitality from same provider 20+ times• Dinners in top restaurants – e.g. Savoy Grill• iPads

Some examples where risk of perception of a conflict of interest: • Defence suppliers, e.g. dinner and drinks for 26 officials on

completion of a project


Report conclusion

“Public officials are sometimes offered gifts and hospitality by external stakeholders which it is reasonable for them to accept. This can, however, present a risk of actual or perceived conflicts of interest, and undermine value for money or affect government’s reputation. While most, but not all, cases declared by officials appear on the face of it to be justifiable in the normal course of business, we found some weaknesses in the oversight and control of gifts and hospitality. This needs to be addressed by the Cabinet Office and departments.”Amyas Morse


Challenges in completing the audit

• Initial difficulty obtaining some registers• Possibility that registers were incomplete• Lack of detail in the records • Ensuring balanced presentation in report • We cleared report extracts with 70

organisations!


Significant interest in the media


Impacts

• Responses in case study departments• More prompt publication of transparency

data• Departments sharing good practice -

network set up • Audit Committee interest


Thank you!

Any questions?

eurosai presentation: acceptance of gifts and hospitality

Government & Nonprofit