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PUBLIC DOMAIN

Gifts, Benefits and Hospitality PolicySubTitle

TRIM ID: CD/12/152678Date: 12 September 2017Version: 3.1

Contents

1 Document purpose......................................................................................................................

2 Background..................................................................................................................................

3 Scope............................................................................................................................................

4 Responses to offers of gifts and hospitality.............................................................................4.1 Exemptions..........................................................................................................................4.2 Exclusions...........................................................................................................................4.3 Acceptance & the GIFT test................................................................................................4.4 Approval authority................................................................................................................4.5 Declarations........................................................................................................................4.6 Gifts/hospitality & asset registers.........................................................................................4.7 Attestation...........................................................................................................................

5 Provision of gifts and hospitality...............................................................................................5.1 Parameters and approvals authority....................................................................................5.2 Containing costs................................................................................................................5.3 Providing alcohol...............................................................................................................5.4 HOST test..........................................................................................................................

6 Glossary.....................................................................................................................................

7 Related policies and other documents....................................................................................

8 Policy status..............................................................................................................................

9 Modification and review............................................................................................................9.1 This policy is subject to regular review (at least annually) and will be amended and

the changes communicated to staff in order to ensure that it remains current..................

Appendix 1. Frequently Asked Questions Fact Sheet.....................................................................

Appendix 2. Gift and Hospitality Declaration Form.........................................................................

1

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Draft – 0.1 PUBLIC DOMAIN of 17

1 Document purposeThe Victorian Commission for Gambling and Liquor Regulation (VCGLR) must demonstrate high standards of integrity, impartiality and responsible use of resources to ensure public trust.

This document sets out the VCGLR’s approach for its staff, contractors, consultants, directors and commissioners on providing, accepting, approving, declaring and recording gifts, benefits and hospitality associated with VCGLR duties.All those to whom this Policy applies should read and be familiar with it and the related documents.

Failure to adhere to the provisions outlined in the Policy may result in disciplinary action.

2 BackgroundThe Public Administration Act 2004 (PA Act) specifies that public officials should:

• demonstrate integrity by avoiding any real or apparent conflicts of interest• demonstrate impartiality by making decisions and providing advice on merit and

without bias, caprice, favouritism or self-interest• demonstrate accountability by seeking to achieve best use of resources and

submitting themselves to appropriate scrutiny.

The Public Sector Standards Commissioner, under the PA Act, has issued a number of binding codes of conduct including the Code of Conduct for Victorian Public Sector Employees 2015 (Code of Conduct) and the Victorian Public Entity Directors’ Code of Conduct 2006.

The Public Sector Standards Commissioner has issued the Gifts, Benefits and Hospitality Policy Framework Victorian Public Sector Revised April 2012 (Framework). Heads of public sector bodies are required to ensure that they have in place organisational gifts, benefits and hospitality policies and processes consistent with the Framework. In some situations, asking for, or inappropriately providing or accepting gifts, benefits and hospitality may be:

• a breach of the PA Act, the Code of Conduct and the Framework• a crime under the Crimes Act 1958 (Vic).

The role of the VCGLR as a regulator to the (liquor and gambling) hospitality industry provides particular challenges in ensuring the appropriate separation and classification of regulatory activities and stakeholder engagement from gifts, benefits and hospitality. Specific guidance is provided at section 4.2

3 ScopeThe Code of Conduct prescribes behavioural standards of how Victorian Public Sector (VPS) staff are to conduct business and treat the public, clients and colleagues. Contravention of the Code may be regarded as misconduct.

This Policy provides additional guidance in relation to the specific situations that may arise in respect of VCGLR activities. The Code of Conduct and the Policy are to be read together. If any inconsistency arises between the two then the Code of Conduct takes precedence.

This Policy provides the framework for the regular consultation of staff and relevant external stakeholders to understand the gifts, benefits & hospitality risks.

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4 Responses to offers of gifts and hospitalityThe policy requires that gifts and hospitality shouldn’t be accepted. However, there are exemptions and exclusions to this principle.

4.1 Exemptions Consistent with the Framework issued by the Public Sector Standards Commissioner, this Policy does not apply to:

• stationery such as pens or pads handed out to everyone attending a conference • hospitality from a government host or government-sponsored entity • modest hospitality including light refreshments such as tea or coffee offered in the

course of a business meeting at the organisation’s premises, light refreshments such finger food at an opening ceremony or sandwiches at a conference or meeting, all of which are proportionate to the occasion.

The above can be accepted without approval and without completing a Gifts & Hospitality Declaration Form. Token commemorative/memento gifts from a government host or government-sponsored entity can be accepted without approval but a completed Gift and Hospitality Declaration Form is required.

4.2 Exclusions Commissioners & the Executive

The Chair, Commissioners, the CEO and members of the VCGLR Executive/Senior managers, as a part of their stakeholder engagement function, are expected to meet with companies and industry participants and representatives and attend or present at industry and/or peak body functions. Typically these functions will be at venues and with organisations which are regulated by the VCGLR. While this presents the potential for integrity and conflict of interest risk, interaction with the industry and its representatives is an essential element of effective regulation. All attendance as a representative of the VCGLR where is likely that some form of gift, benefit or hospitality will be provided must be declared, and appropriately approved, PRIOR to the event where possible (refer Section 4.4 Approval authority). Offers of free or discounted attendance at seminars, conferences, professional development or presentations or where attendance at a function results in the provision of a free meal and/or alcoholic drinks requires approval by the appropriate delegate PRIOR to attendance; this approval requirement applies to all staff. These types of benefits are typically provided by current or potential VCGLR vendors. For stakeholder engagement events or functions where a Commissioner or a member of the Executive is invited to speak or be a special guest at a community, industry or peak body function or conference and a gift/hospitality is provided, the gift and any other ‘free’ hospitality must be declared. To avoid any potential perception of conflict of interest attendance at the event should be notified and appropriately approved PRIOR to the event. Any gifts, benefits or hospitality arising may be declared after the event. As a representative of the VCGLR all standards of conduct and behaviour are expected to be in accordance with the Code of Conduct. All invitations for Christmas parties or other celebrations from entities (including industry and peak bodies) that the VCGLR regulates are to be declined.

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Gambling and Liquor Inspectors Inspectors are not permitted to accept gifts, benefits and hospitality from venues, however modest hospitality such as tea and coffee is acceptable.

All Staff Generally gifts, benefits and hospitality that are work related should be declined. Staff must not:

• solicit (ask for) a gift, benefit or hospitality • accept gifts that can easily be converted to money (eg shares) • accept bribes.

Staff must: • refuse all offers of gifts, benefits or hospitality that could reasonably be perceived

as undermining the integrity and impartiality of the staff member or the VCGLR • refuse all offers of gifts, benefits or hospitality from people or organisations about

whom the staff member is likely to make decisions involving tender processes, procurement, enforcement, licensing, and regulation (including all Christmas party invitations from entities that the VCGLR regulates)

• refuse bribes and these must be reported immediately to the CEO and to Victoria Police.

4.3 Acceptance & the GIFT test Occasionally there may be instances of offers of hospitality from a private or commercial source from which the VCGLR would benefit from representation. All staff, Directors and Commissioners must obtain prior approval to attend (refer section 4.4 Approval authority).

• Staff may accept gifts in some circumstances provided they are not excluded from doing so (refer section 4.2 Exclusions), obtain necessary approvals (refer section 4.4 Approval authority) and complete a Gift & Hospitality Declaration Form (refer section 4.5 Declarations).

Staff and Directors must consider the value, purpose and risk of accepting the gift or hospitality before making any decisions about acceptance. The GIFT test is a good reminder of what to think about when deciding whether to accept or decline a gift, benefit or hospitality. Table 1 GIFT Test

G Giver Who is providing the gift, benefit or hospitality and what is their relationship to the VCGLR staff member? Does the staff member’s role require the staff member to select contractors, award grants, regulate industries, issue licences or determine government policies? Could the person or organisation benefit from a decision the staff member makes?

I Influence Are they seeking to influence the staff member’s decisions or actions? Has the gift, benefit or hospitality been offered to the staff member publicly or privately? Is it a courtesy, a token of appreciation or highly valuable? Does its timing coincide with a decision the staff member is about to make?

F Favour Are they seeking a favour in return for the gift, benefit or hospitality? Has the gift, benefit or hospitality been offered honestly? Has the person or organisation made several offers over the last 12 months? Would accepting it create an obligation to return a

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favour?

T Trust Would accepting the gift, benefit or hospitality diminish public trust? How would the staff member feel if the gift, benefit or hospitality became public knowledge? What would the staff member’s colleagues, family, friends or associates think?

In dealing with gifts and hospitality staff are reminded to consider your obligations under the following:

• the Code of Conduct, specifically sections 3.7 regarding conflicts of interest and 4.2 regarding gifts and benefits, and

• the VCGLR Values (particularly acting with integrity). If unsure about how to respond to an offer of a gift, benefit or hospitality seek advice from your Manager or Director. A Frequently Asked Questions Fact Sheet including case studies can be found at Appendix 1.

4.4 Approval authority Approval to accept gifts and hospitality is requested through the completion of the Gift & Hospitality Declaration Form (refer Appendix 2).

Gifts

• If the intention of the donor is for the staff member to receive the gift and the staff member is not excluded from acceptance (refer section 4.2 Exclusions) then: o if the benefit is under $50 and provided there is no potential conflict of interest, the staff member may keep/accept it without obtaining prior approval o if there is a potential for conflict of interest or the gift is valued at $50 or over, the staff member requires approval from their Director to keep/accept the gift.

• If the intention of the donor is for the gift to be for the VCGLR or the State (an official gift) then the gift becomes the property of the VCGLR. The staff member may be able to apply to their Director for approval to purchase and keep the gift if no other public entity has expressed an interest.

Hospitality

• The authority for acceptance of hospitality from a private or commercial source

requires prior approval and for:

o VPS Grades 1-6, the approval authority is the relevant Director

o Directors and STS7 roles, the approval authority is the CEO

o CEO, the approval authority is the Chair

o Commissioner, the approval authority is the Chair

o Chair, the approval authority is a Deputy Chair and one other Commissioner.

4.5 Declarations The Procedure is:

1. Determine whether the staff member is excluded from receiving gifts or hospitality (refer section 4.2 Exclusions).

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2. Apply the policy principles and the GIFT test to determine whether acceptance is appropriate.

3. If the staff member is offered or accepts a gift, benefit or hospitality, excluding those exemptions as detailed in the section 4.1, the staff member must complete the Gift & Hospitality Declaration Form.

4. If it is not possible to readily determine the value of a gift, the staff member may ask the gift donor for the actual or estimate cost of the gift. If it is inappropriate to ask the donor, the staff member’s Director will estimate the value of the gift.

5. In circumstances when approval is required, submit the Form to the staff member’s Director who will decide whether: o the gift, benefit or hospitality can be kept, accepted or purchased by the

staff member o the gift should be retained by the VCGLR, or

o the gift should be disposed of which could include donation of the gift (or the sale proceeds) to charity, or donation of gifts of cultural significance to an appropriate public institution.

6. Public entities such as the National Gallery of Victoria, State Library of Victoria and Museum Victoria retain a right of first refusal over any official gifts that are deemed to be of historical or cultural significance. To determine whether another public entity may want to accept and retain the gift, the Office of the CEO will send an email to the Arts Victoria describing the item and seeking advice on its retention.

7. Forward the Gift & Hospitality Declaration Form to the Executive Divisional Coordinator, Corporate Services for recording on the Gift and Hospitality Register within 14 days of the offer.

4.6 Gifts/hospitality & asset registers The Gifts & Hospitality Register contains details about gifts and hospitality and their treatment, i.e. whether they were kept, sold or disposed of. The Executive Divisional Coordinator, Corporate Services will manage the Register. The VCGLR Audit and Risk Management Committee (ARMC) will, every six months, review a report on the number and type of gifts and hospitality received. If a gift is accepted for VCGLR’s ownership and is over $5000, the relevant Director should ensure it is recorded on the on the VCGLR Asset Register. If the gift is over $500 and under $5000 the relevant Director should ensure it is recorded on the Portable and Attractive Assets Register if applicable. For further information, please contact the Chief Financial Officer.

4.7 Attestation The VCGLR Chair, as head of a public entity (the VCGLR) is required to make an annual attestation to the Secretary of the Department of Justice & Regulation, about the operation, review, promulgation and scrutiny of the VCGLR gifts, benefits and hospitality policies and processes. The ARMC:

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• provides assurance annually to the Commission that the Chair may sign the attestation by providing adequate information about the risks, the effectiveness of

existing controls and any additional required mitigation activities • reviews a report on the Gifts and Hospitality Register to identify trends and

emerging risks, and recommend how to address these every six months.

5 Provision of gifts and hospitality To maintain integrity, there are limits imposed on the provision of hospitality by VCGLR

staff. This section deals with those circumstances where hospitality may be provided. 5.1 Parameters and approvals authority

Hospitality may be provided in the circumstances detailed in Table 2 to: • ensure that any gift or hospitality is provided for a business purpose in that it

furthers the conduct of official business or other legitimate organisational goals, or promotes and supports government policy objectives and priorities

• ensure that any costs are proportionate to the benefits obtained for the State, and would be considered reasonable in terms of community expectations

• ensure that when hospitality is provided, individuals demonstrate professionalism in their conduct, and uphold their obligation to extend a duty of care to other participants.

Table 2 Providing gifts and hospitality Audience and

purpose Parameters Approver*

Functions with external participants

Receiving guests (for example a visiting delegation from another jurisdiction, or hosting a meeting held over lunch time) Facilitating relationships between third party organisations that are in the interests of the State (for example, hosting industry information sessions focussed on enhancing education and/or compliance) Celebrating the opening of an event or launching an initiative.

CEO or relevant Director (or their authorised delegate)

Gifts for external stakeholders

Minor gifts which are symbolic, rather than financial, value may be provided if gifts are provided to support the Commission’s functions, are for the purposes of protocol or a public relations and would be considered acceptable in accordance with community expectations.

If valued less than $150 (not including commemorative/ memento gifts), the relevant Director or approver must be advised in writing. If valued more than $150, written approval from the CEO is required.

Catered staff functions

Staff-related events, such as a training course, workshop, planning day seminar or conference. To recognise an organisational or individual staff achievement.

CEO or relevant Director (or their authorised delegate)

Gifts for staff Token gifts may be provided as part of the VCGLR’s formal rewards and recognition process,

CEO or relevant Director (or their authorised

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or to celebrate retirements. delegate)

Note: Approval to expend funds must be in accordance with the VCGLR purchasing framework and financial authorisations.

5.2 Containing costs In order to contain costs:

• where possible, events should be held at a time of day least likely to attract expectations of, or a need for, hospitality

• any event should not exceed two hours in duration • public sector venues should be selected in preference to private venues; external

venues should only be used if required, and where value for money can be demonstrated

• catering should be proportionate to the number of attendees • the size of the event and number of attendees should be aligned with intended

outcomes • catering should be procured at competitive rates and avoid inclusion of more

expensive menu options.

5.3 Providing alcohol • Any event where alcohol is served should be held at a time which minimises the

risk of staff returning to work impaired by alcohol. For example, the event should be held in the late afternoon or early evening.

• Any event should not exceed two hours in duration. • No more than two standard drinks per person should be provided. • The provision of alcohol should be incidental to the overall level of hospitality

provided.

5.4 HOST test The HOST test is a good reminder of what to think about when deciding whether to provide a gift or hospitality.

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Table 3 HOST Test

H Hospitality To whom is the gift or hospitality being provided? Will recipients be external business partners, or employees of the host organisation?

O Objectives For what purpose will hospitality be provided? Is the hospitality being provided to further the conduct of official business? Will it promote and support government policy objectives and priorities? Will it contribute to staff wellbeing and workplace satisfaction?

S Spend Will public funds be spent? What type of hospitality will be provided? Will it be modest or expensive, and will alcohol be provided? Will the costs incurred be proportionate to and less than the benefits obtained?

T Trust Will public trust be enhanced or diminished? Could staff publicly explain the rationale for providing the gift or hospitality? Will the event be conducted in a manner which upholds the reputation of the public sector? Have records in relation to the gift or hospitality been kept in accordance with reporting and recording procedures?

6 Glossary Gifts are the free or heavily discounted items, intangible benefits or hospitality exceeding common courtesy that are offered to employees in association with their work for the VCGLR. Gifts may also be provided by organisations to, for example, a visiting delegation from another jurisdiction. They may be enduring such as a work of art or consumables such as a box of chocolates. They range in value from nominal to significant and may be given for different reasons.

Benefits are the preferential treatment, privileged access, favours or other advantage offered to an employee. They include invitations to sporting, cultural or social events, access to discounts and loyalty programs, and promises of a new job. While their value may sometimes be difficult to quantify in dollars, they may be highly valued by the intended recipient and therefore used to influence their behaviour.

Hospitality is the friendly reception and treatment of guests ranging from offers of light refreshments at a business meeting to restaurant meals and sponsored travel and accommodation. Hospitality may be offered to a public sector employee noting that there are restrictions.

Modest hospitality includes light refreshments such as tea or coffee offered in the course of a business meeting at the organisations premises, light refreshments such as finger food at an opening ceremony or sandwiches at a conference. Public sector organisation hospitality comprises o ‘Official State hospitality’ is that

hosted directly by an elected official and not a public sector organisation. This may include some diplomatic, consular and ceremonial activities, state contributions to the Australian system of honours and awards and the conduct of community cabinets. This type of hospitality is exempt from this policy framework. o ‘Official hospitality’ refers to the hosting of diplomatic and foreign government officials, community representatives and/or people from the private and academic sectors by public sector organisations, and state-sponsored events. The persons attending these events are usually from organisations other than those within the Victorian public sector although public sector employees may attend to accompany a Departmental secretary or executive and/or Minister and liaise with attendees.

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o ‘General hospitality’ is usually that provided by public sector organisations, often in the workplace and often involving internal stakeholders or fellow public sector employees. General hospitality can be provided for a range of purposes, from providing light refreshments, sustenance at a lengthy meeting through to celebrating achievements. It also extends to more generous forms of hospitality such as catered meals at functions, meals at restaurants, and may include the provision of alcohol Depending on the nature of the hosting organisation’s business, sometimes recipients of general hospitality may be external stakeholders or business partners.

Reportable gifts are those that must be recorded, typically on a gifts declaration form and/or a gifts register. The gifts may have been offered to an employee directly or extended to them as a guest of their partner or other close relation.

Conflicts of interest occur when an employee’s private interests conflict with their public duty. Employees have a duty to always resolve a conflict in the public interest, not their own. This may mean that they decline a gift or transfer the gift to their employer’s ownership if this is identified as being in the public interest.

Bribes are money or other inducements given or promised to employees to corruptly influence the performance of their role. Bribery of a public official is an offence punishable by up to ten years imprisonment.

7 Related policies and other documents Public Administration Act 2004

Victorian Commission for Gambling and Liquor Regulation Act 2011 Gifts, Benefits and Hospitality Policy Framework Victorian Public Sector Revised April 2012 Implementing the Gifts, Benefits and Hospitality Framework Victorian Auditor General’s Office 2015 VPS Conflict of Interest Policy Framework 2009 Crimes Act 1958 (Vic).

8 Policy status This policy is approved by and issued under the authority of the CEO of the Victorian Commission for Gambling and Liquor Regulation, approved by the Commission and endorsed by the ARMC and the People & Culture Committee.

9 Modification and review 9.1 This policy is subject to regular review (at least annually) and will be amended and the

changes communicated to staff in order to ensure that it remains current.

Appendix 1 Frequently Asked Questions Fact Sheet VCGLR Gifts and Hospitality Policy Can I accept gifts and hospitality related to my duties within the VCGLR?

• You must not accept gifts or hospitality where it could reasonably be perceived as undermining the integrity and impartiality of yourself or the VCGLR.

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• Commissioners and Directors should not accept gifts. • Those making decisions involving enforcement, licensing, regulation, tendering and

procurement must refuse gifts and hospitality.

Are there consequences for inappropriately accepting gifts and hospitality? In some circumstances, asking for or inappropriately providing or accepting gifts or hospitality may be a breach of the Code of Conduct for Victorian Public Sector Employees (No1 2007) or a crime under the Crimes Act 1958 (Vic). It is therefore important to familiarise yourself with this policy. Are there circumstances where I can accept an offer of a gift or hospitality?

• There may be circumstances when there is no real or apparent conflict of interest involved and where refusal of a gift or hospitality could cause embarrassment.

• Obtain approval prior to accepting substantial hospitality connected with your work. • Your Director will apply the GIFT Test to determine whether the offer can be accepted,

whether you can keep the gift or attend the function. G Giver Who is providing the gift, benefit or hospitality and what

is their relationship to me?

I Influence

Are they seeking to influence my decisions or actions?

F Favour Are they seeking a favour in return for the gift, benefit or hospitality?

T Trust Would accepting the gift, benefit or hospitality diminish public trust?

What gifts and hospitality are exempt from this policy? The following may be generally accepted without being approved or declared:

• stationery such as pens or pads handed out to everyone attending a conference or expo • with the exception of inspectors, modest hospitality such as tea or coffee offered in the

course of a business meeting at the organisations premises, light refreshments such as finger food at an opening ceremony or sandwiches at a conference all of which are proportionate to the occasion

• hospitality from a government host or government-sponsored entity. Do I have to advise anybody when I am offered or accept gifts and hospitality? The Gift & Hospitality Declaration Form, available on the VCGLR intranet must be completed by the person being offered the gift or hospitality and the required approvals obtained within 14 days of the offer and forwarded to the Coordinator Office of the CEO for recording on the Gift and Hospitality Register.

CASE STUDIES Grand Occasion

Can I accept an invitation to attend a liquor or gambling industry box at the Australian Open? No. Your attendance at such an event could be perceived to be a conflict of interest. You must complete the Gift and Hospitality Declaration Form.

He’s a Mate I was offered free tickets worth $150 to a band playing at a club as a thank you if I expedite a liquor licence application. I went to school with the Manager and he is a good bloke. No. Your personal relationship with the Client should not influence you. The offer of tickets could be perceived as an attempt to bribe and should immediately be reported to your Director who

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will subsequently inform the CEO. You should also complete the Gift and Hospitality Declaration.

Famished I was running late and missed lunch. During a visit to a venue I let it slip and I was offered a steak in the dining room on the house. Can I accept? No. Your comments could be perceived as soliciting a gift and you should decline the offer. Inspectors in particular are subject to stringent restrictions with regards to accepting hospitality and are not permitted to receive even modest hospitality such as tea and coffee from venues.

It’s the Social Club What should the Director Licensing do when they receive a dozen slabs of beer from a Licensee to be used at the VCGLR Christmas party as a thank you to Licensing staff for all their help? Whilst the Director believes this is a genuine gift, it could be perceived as a conflict of interest and so the gift should be declined and returned. A Gift and Hospitality Declaration Form should be completed.

Christmas Bash Can staff accept an invitation to a fully catered Christmas Party from a Company who operates hotels in Victoria? No. All invitations from organisations (including industry and peak bodies) that the VCGLR regulates are to be declined. A Gift and Hospitality Declaration should be completed.

Beautiful Bouquet Can I accept the flower bouquet (about $49), donated by a Hotel/Club and publicly presented to me for my assistance with arranging a liquor industry event? Yes. It would be embarrassing for both yourself and the audience to reject the gift. You must complete a Gift and Hospitality Declaration Form. If you do not perceive a conflict of interest you do not need your Director’s approval to keep the flowers as the gift is under $50.

Gorgeous Cake Do I declare the box of cakes (about $55) bought to the VCGLR by the Company who provides temporary staff during an on-site visit. No. This is modest hospitality at a business meeting although it is on VCGLR premises. The cakes can be accepted and a Gift and Hospitality Declaration Form does not need to be completed.

Chocolate!!!! Can I accept the chocolate egg given to me at Easter from a supplier. If you are involved in any aspect of the awarding of the contract or procurement activities surrounding the supplier (example preparing the purchase order, certification of receipt of goods, approval for payment), or it is a supplier you deal with frequently or you are a Director or a Commissioner you must not accept the gift. If the gift is under $50 and if you

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consider that there is no conflict of interest then you do not need your Director’s permission to keep the chocolate. You should forward the Gift and Hospitality Declaration Form directly to the CEO’s Office within 14 days.

Government Hospitality Do I have to declare that I received lunch when I attended a program launch which was funded by the Victorian Government? Hospitality received from a government host or government sponsored entity can generally be accepted without completing a Gift and Hospitality Declaration Form or obtaining approval. However gifts received from a Government source should be declared (refer section .6.1 Exemptions). Networking Opportunity After a presentation during responsible gambling/alcohol week at the Casino can I accept the invitation (with approximate value of $49) to a Speakers Luncheon courtesy of the Casino? The acceptance of hospitality from this commercial source (including by Commissioners and Directors) may entail the appearance of a conflict of interest so a Gifts and Hospitality Declaration Form should have been completed prior to the event and approval from your Director/Approver obtained. If this has not occurred you cannot attend (refer section 6.4 Approval authority).

Around the world in …… I am attending two accord meetings at opposite ends of the City. I arrive at the second location and find the sandwiches have transformed into a dining room lunch at the venue. By the end of the day I will have been working for 12 hours. I have already driven for two hours and it will take me another 2 hours to get home. The real decisions will be made over lunch so I must attend. Do I just sit there whilst everybody eats? No. Common sense should prevail. You should have your lunch. The Commission does not expect you to work for 12 hours without eating, and certainly does not want you to drive a car without doing so. On your return to the office complete the Gift and Hospitality Declaration Form. If you are aware of the circumstances prior to the Accord meetings then you must complete the Gift and Hospitality Declaration Form in advance and obtain the approval of your Director. It may be decided to prepay your lunch.

ASK YOUR DIRECTOR OR MANAGER IF IN DOUBT AS WHAT TO DO WHEN YOU ARE OFFERED OR HAVE RECEIVED GIFTS AND HOSPITALITY

Appendix 2: Gift and Hospitality Declaration Form Completed by the recipient of a gift/hospitality within 14 days of the offer

Date offered:

Employee details

Name:

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Position:

Offered by

Name:

Position & Organisation:

Reason gift/hospitality was offered:

Description of gift/hospitality:

Gift/hospitality accepted? Yes No

Estimated value of gift/hospitality: $

First time offer or Previous offer(s) within the last 12 months by this individual

Signature of recipient: Date: / /

If the gift or hospitality is under $50 approval is not required. Forward declaration form to the Executive Divisional Coordinator, Corporate Services. If over $50 then approval is required before forwarding to the Executive Divisional Coordinator, Corporate Services.

Approval required? Yes No

Completed by manager, Director or Commissioner after discussion with the recipient for gifts and hospitality over $50

Decision regarding gift/hospitality

Signature:

Name: Position: Date / /

Gift and Hospitality register updated

Signature:

Name: Position: Date / /

Document information

Document details Criteria Details

TRIM ID: CD/12/152678

Document title: Gifts, Benefits & Hospitality Policy

Document owner: People & Culture

12 September 2017


Version control Version Date Description Author

V1.0 19/09/12 Final Johanna Schlesinger

V2.0 16/02/16 Final John Veale


Document approval This document requires the following endorsement and approval:

Name Organisation Date Endorsed/Approved

Executive VCGLR

ARMC VCGLR

Commission VCGLR

Reference material

Acronyms Description

VCGLR Victorian Commission for Gambling and Liquor Regulation

VPS Victorian Public Service

CEO Chief Executive Officer

GIFT Giver Influence Favour Trust

HOST Hospitality Objectives Spend Trust

ARMC Audit and Risk Management Committee

10

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Document details

Criteria DetailsTRIM ID: CD//12/152678

Document title: Gifts, Benefits & Hospitality Policy

Document owner: People & Culture

Version control

Version Date Description Author

V0.1 19/09/12 Final Johanna Schlesinger



Document approval

This document requires the following approval:

Name Organisation Date EndorsedExecutive VCGLR

ARMC VCGLR

Commission VCGLR

Reference material

Acronyms DescriptionVCGLR Victorian Commission for Gambling and Liquor Regulation

VPS Victorian Public Service

CEO Chief Executive Officer

GIFT Giver Influence Favour Trust

HOST Hospitality Objectives Spend Trust

ARMC Audit and Risk Management Committee

12 September 2017


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