The following policy is intended to provide guidance and clarification to all employees on what is and is not acceptable with respect to the giving and receiving of gifts and hospitality, especially in light of bribery and corruption.
The Bribery Act 2010 covers the criminal law relating to bribery and the penalties for committing a crime under the Act range from a maximum of 10 years imprisonment to an unlimited fine.
It is not the intention of this policy to prohibit the giving or receipt of normal, reasonable and appropriate hospitality and gifts aimed at maintaining and building good relationships with customers and suppliers. The giving and /or receiving of hospitality and gifts is only acceptable if certain conditions are met.
When is it acceptable to offer or receive gifts & hospitality?
The following tests should always be applied when deciding whether a gift or hospitality is appropriate, and reasonable:
The offer of the hospitality or gift is not made with the intention of influencing a third party to obtain or retain business, to gain business advantage, or in exchange for favour or benefit
The offer of the hospitality or gift is legal
The offer is in the company name and not in personal name
The offer is not given as cash or in cash value, e.g. gift cards / vouchers, loans, shares etc
The offer is appropriate in the circumstances, e.g. a ‘token’ gift at Christmas
Taking into account the reason for the offer, it is of an appropriate type and value, and given at an appropriate time
The offer is made openly and not in secret
The offer should not have political connotations or influence
If the above tests are not passed, the offer must be rejected or not made.
What is not acceptable?
To offer any gift or hospitality with the expectation, hope or intention that either
a business advantage will be received (by DPD Ireland) or a personal
advantage, or to reward any advantage already received
To accept from a third party any gift or hospitality, that you know (or suspect) is
offered with the expectation that it will obtain a business/personal advantage for
that third party from DPD Ireland
The soliciting by any employee (in their capacity as a DPD Ireland employee)
of personal benefits (including discounts) from suppliers / customers, in all circumstances.
To accept personal benefits which are intended to influence the decision making of the recipient arising as a result of their position within DPD Ireland (even if the personal benefit in question falls within the allowable gifts / hospitality as outlined within this policy)
Process for acceptance of hospitality and business gifts
Modest and infrequent hospitality and gifts from suppliers or customers (e.g.
meals, attendance at theatre/music/sports events, wine, hampers, chocolates) is an accepted courtesy of a business relationship, but it must be authorised in advance by either your immediate Head of Department (this is only a requirement if the hospitality is worth more than €50).
In all cases where the hospitality or gift is worth more than €50, and regardless
of whether the offer is accepted or rejected, the offer must be properly declared by completing the ‘Notification of Hospitality and Gifts - Received’ form (available in People Online), and sent to the Head of HR (who will place the entry on the Hospitality & Gifts Register).
All hospitality or gifts from suppliers or customers which would be considered
over and above the usual course of business (e.g. holidays, short breaks, overseas travel, watches/jewellery, paintings, electronic equipment, transport upgrade, luxurious clothing etc.), or is disproportionate to the type of business dealing to which it relates, must be politely refused.
Hospitality and gifts of any sort (regardless of value) should not be accepted during tender or contractual negotiations.
Employees should not accept anything from suppliers or customers that the taxation authorities would consider to be a taxable benefit. Revenue would consider anything over the value of €500 as taxable - please see below guidance provided directly from Revenue:
Employees should not accept anything from suppliers or customers that the revenue would consider to be a taxable benefit (revenue would generally consider anything over the value of €500 as taxable - please note all cash gifts are taxable, irrespective of amount).
If you are unsure whether an offer is acceptable, you should consult the Head of HR for advice.
If a gift (worth greater than €50) is sent unsolicited, and for whatever reason cannot be returned to the sender, the item must be:
• Properly declared (as described above)
• Raffled within the business and the funds donated to charity.
Under no circumstances should you actively solicit a gift or corporate hospitality.
Providing hospitality and business gifts to customers
Hospitality (attendance at theatre/music/sports events) or gifts offered to customers must be authorised by either your immediate Head of Department,
in advance of making the offer (this is only a requirement if the hospitality or gift
is worth more than €50).
In all cases where the hospitality or gift is worth more than €50, and regardless
of whether the offer is accepted or rejected by the customer, the hospitality and gifts offered to customers must be properly declared by completing the
‘Notification of Hospitality and Gifts - Offered’ form (available on People Online) and sent to the Head of HR (who will place the entry on the Hospitality & Gifts Register).
Each year at Christmas time the business sends out hampers/champagne to its largest customers. As this is done with full knowledge of the SMT, these gifts are exempt from the above mentioned rules.
In offering hospitality or gifts, the employee should not be seen to be deliberately trying to influence the judgment or impartiality of the customer (the DPD image/brand should be preserved at all times).
No hospitality or gifts should be offered to customers which a reasonable person would consider over and above the usual course of business (i.e. holidays,
short breaks, overseas travel, watches/jewellery, money, transport upgrade, paintings, electronic equipment, luxurious clothing etc), or, is disproportionate to the type of business dealing to which it relates, or, is likely to offend.
Hospitality or gifts of any sort should not be offered during tender or contractual negotiations (approved DPD Group Ireland marketing gifts such as umbrellas, keyrings, mouse mats, pens etc. are excluded from this, and can be given to customers in this instance.)
Policing the policy
This policy will be audited on an annual basis (for further details on this please
contact the Head of HR) to ensure the correct rules have been applied.
This will include contacting third parties such as customers and suppliers.
Any employee who has failed to comply with the policy will be subject to disciplinary action.
How to raise concerns
You are encouraged to raise any concerns you have regarding the giving and /or receiving of hospitality and gifts (either concerning yourself or others). This should be done at the earliest possible opportunity, either through:
Bringing it to the attention of your Supervisor
Contacting a senior manager or SMT member.
Contacting the People Operations Department
Contacting the Head of HR
The confidential DPDgroup Ireland whistleblowing hotline
For further information on this policy, please Click Here
Issue Date: 17th June 2024
Next Review Date: 15th January 2025
Documented by: Jess Lumley
Approved by: Mary Gaffey