Eurosai presentation: acceptance of gifts and hospitality

1. An investigation into the acceptance of gifts and hospitality
2 February 2017
An investigation in the acceptance
of gifts and hospitality
Paul Wright-Anderson

2. An investigation into the acceptance of gifts and hospitality
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

3. An investigation into the acceptance of gifts and hospitality
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

4. An investigation into the acceptance of gifts and hospitality
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.

5. An investigation into the acceptance of gifts and hospitality
Findings 2: Senior officials’ acceptance of gifts and
hospitality, by department, 2012-2015

6. An investigation into the acceptance of gifts and hospitality
Findings 3: Senior officials accepted hospitality
frequently from some organisations, 2012-2015

7. An investigation into the acceptance of gifts and hospitality
Findings 4: Providers of hospitality to MOD
project/procurement trading arm, 2014-15

8. An investigation into the acceptance of gifts and hospitality
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

9. An investigation into the acceptance of gifts and hospitality
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

10. An investigation into the acceptance of gifts and hospitality
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!

11. An investigation into the acceptance of gifts and hospitality
Significant interest in the media

12. An investigation into the acceptance of gifts and hospitality
Impacts
• Responses in case study departments
• More prompt publication of transparency
data
• Departments sharing good practice -
network set up
• Audit Committee interest

13. An investigation into the acceptance of gifts and hospitality
Thank you!
Any questions?