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Part 5 - Code of Conduct for Employees

This Code of Conduct includes confidential reporting procedure (whistle-blowing) for employees other than for staff in educational establishments (for whom a separate code exists).

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  1. Staff should not accept gifts or hospitality over a minimal value (£25). Any offers of gifts, prizes hospitality or sponsorship should be recorded in the Council’s Gifts & Hospitality Register held by each Director or, in the case of Directors the Chief Executive. The register must include all offers of gifts, etc whether accepted or declined. Permission should be sought from the Directors before any gift, hospitality or sponsorship is accepted. When in doubt the employee should always refuse such gifts. A standard form is available on the Gifts and Hospitality page.
  2. An employee should not personally receive a gift, prize, hospitality or sponsorship that:
  • could compromise their judgment
  • could appear to be a conflict of interest
  • could damage relationship with others; or
  • could indicate any favouritism or prejudice in relation to any particular person or group of people
  • bring the council into disrepute

3.    When hospitality, prizes or gifts have to be declined, the person making the offer should be informed of the procedures and standards operating within the Council, in relation to gifts, prizes, hospitality and sponsorship.

Gifts (including bequests)

  1. Gifts offered by persons who are providing, or seeking to provide, goods or services to the Council, or who are seeking decisions from the Council, should be refused and returned, as should gifts (other than those of a trivial nature e.g. calendars, diaries, desk sets) offered by those receiving services from the Council.
  2. In all cases relating to the receipt of gifts it is wise to err on the side of caution: an obviously expensive gift must be tactfully declined or, if appropriate, donated to the Council for official use, and the relevant Director or the Chief Executive should be advised of the action taken. If a gift is simply delivered it must be returned to the donor or, if appropriate, be donated to the Council for official use, and the relevant Director or the Chief Executive must be advised of the action taken. All such gifts must be registered in accordance with paragraph 52 of this Code.
  3. On occasions an employee may become a beneficiary of a will of a service user; this may be the way a service user wishes to express gratitude for the service they have received.
  4. Those teams/services which provide personal services to service users have written policies concerning the receipt of bequests by employees. Such policies have been drawn up to protect the interests of both service users and members of staff. Staff should ensure that they have read and comply with such policies.


  1. Employees may only accept offers of hospitality if there is a genuine need to exchange information or represent the Council in the community. Offers to attend purely social or sporting functions should be accepted only when these are part of the life of the community within Gloucestershire and where the Council should be seen to be represented. All such hospitality must be properly authorised and recorded by Directors or, in the case of Directors the Chief Executive. Exceptions to this rule must be properly authorised and recorded by Directors or the Chief Executive.
  2. Acceptance of hospitality through attendance at relevant conferences and courses is acceptable where the hospitality is corporate rather than personal, or where the Directors (or Chief Executive in the case of Directors) gives consent in advance and where it is clear that any purchasing decisions are not compromised.
  3. An offer of hospitality to individual employees calls for special caution particularly if the host is undertaking, or applying to do business with the County Council or hoping to obtain a decision from it. It is very important to avoid any suggestion of improper influence.
  4. A working lunch of modest standards to allow the parties to discuss business would normally be acceptable; this is a case where the hospitality is secondary to a specific working arrangement. On the other hand, it would not be acceptable conduct for an employee to accept such things as: -
  • a holiday
  • tickets for concerts, theatre or sporting events
  • the use of a company flat or hotel suite
  • expensive meals or entertainment
  1. Hospitality must not be accepted unless the acceptance can be readily acknowledged in public or is similar to that which the Council would provide in the same circumstances.
  2. There are occasions when an offer of hospitality of any kind must be declined e.g. when the person offering the hospitality has a current issue with the Council such as a tender under consideration or is involved in a contract dispute.
  3. Offers of hospitality accepted or rejected must be registered by employees to their Directors or, in the case of Directors to the Chief Executive. The details to be registered must be in accordance with that shown in paragraph 52 of this Code.


  1. Where outside organisations, contractors or potential contractors wish or seek to sponsor a Council activity, the basic conventions concerning acceptance of gifts or hospitality apply.
  2. Where the Council acts as a sponsor for an event or service, neither an employee or any partner or relative must benefit from such sponsorship without there being full disclosure to an appropriate manager of any such interest. Similarly, where the Council through sponsorship, grant aid, financial or other means, gives support in the community, employees should ensure that impartial advice is given and that there is no conflict of interest involved.

Bribery Act 2010

  1. The Bribery Act 2010 provides a modern legal framework to combat bribery in the UK and internationally. Staff need to be aware of their obligations under this Act, which sets out the criminality of accepting and giving of bribes. This applies to both individual staff and the Council corporately.
  2. The Bribery Act 2010 creates the following offences:
  • Active bribery: promising or giving a financial or other advantage;
  • Passive bribery: agreeing to receive or accepting a financial or other
  • Bribery of foreign public officials; and
  • The failure of commercial organisations to prevent bribery by an associated
    person (corporate offence).

The penalty under the Bribery Act 2010 is an unlimited fine and/or imprisonment up to a maximum of 10 years.

Full details of the Act can be found on the Bribery Act 2010 page.

Page updated: 09/10/2020 Page updated by: Gloucestershire County Council

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