The Code of Professional Conduct Policy The ... - Edinburgh Airport

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6.6 The EAL Executive Committee considers the compliance of each of our business areas with this policy on a six monthly basis. Each member of the committee is responsible for signing-off on compliance on behalf of their business area and the Chief Executive reports back to the board of EAL to confirm compliance. 7 No receipt of cash gratuities or tips 7.1 All services provided by EAL, for free or charged for, shall be provided without any payment of gratuities to EAL employees. Any offer (including an implied offer) of a tip, gratuity or other payment should be politely declined. 8 Gifts and hospitality 8.1 From time to time, you may be offered gifts or hospitality (which includes entertainment) by customers, suppliers or business partners. It is important that you are not compromised, and the interests of EAL are protected. Not only must you retain your impartiality at all times, but you must be seen to be acting in an open and honest way. No gifts or hospitality of any kind should place you under any obligation or be capable of being construed as an inducement. 8.2 As a general guide as to whether a gift or hospitality can be accepted, you should consider whether: (a) (b) (c) (d) (e) the frequency, type and value of the gift or hospitality is reasonable and proportionate in the circumstances – is it greater than EAL would provide in return or provide generally in the course of its business?; a reasonable third party might believe that the nature of the gift or hospitality is such that it could, or might reasonably be expected to, influence your business decisions; it is legal in the UK and in the country of the person providing the gift or hospitality; any judgement you make on acceptability could be comfortably discussed in an open forum (i.e. would you be embarrassed if your manager, a colleague or anyone outside EAL became aware of it?); and it is given openly or in secret. 8.3 No gifts or hospitality should be accepted from any parties involved in tender or contract negotiations with EAL or in dispute with EAL, without prior written approval from your Director (with the exception of business lunches not exceeding £10 per person). 8.4 It is not acceptable for you or someone on your behalf to: (a) (b) accept payment from a person if you know or suspect that it is offered with the expectation that it will secure a business advantage for them; or accept gifts or hospitality from a person if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by EAL in return. 8.5 When it is not easy to decide between what is and is not appropriate, the offer should be declined or advice sought from your line manager before acceptance. 9 Register of gifts and hospitality 9.1 Directors and Heads of Departments should establish requirements for a Register of Gifts and Hospitality (Appendix C) in their department and nominate managers to maintain the register.
9.2 The register may be subject to sample checks by Internal Audit from time to time and should be completed on at least a quarterly basis (even when there is nothing to be declared). 9.3 Where the register is submitted electronically, and is therefore unsigned, the electronic copy is considered to be evidence that the submitting manager is aware of the content of the register and has approved its submission. 9.4 Any gifts or hospitality with a value of £10 or more must be recorded in the register for the relevant department with details of the person giving and the recipient of the gift or hospitality and the date it was given or accepted. 9.5 Details of any gifts or hospitality offered but not accepted must also be recorded in the relevant department’s register, together with the reason for it being declined. 10 Gifts or hospitality provided or offered by or on behalf of Edinburgh Airport 10.1 On occasion, you may wish to provide gifts or hospitality to business associates from other companies. Any such offer should be reasonable and proportionate, be made in good faith and should not give the recipient any impression of an obligation to confer a business advantage to EAL or affect the recipient’s independence. 10.2 Any such offer should be treated in a similar way to gifts or hospitality being received and a record should be made in the relevant register. 10.3 It is not acceptable for you or someone on your behalf to: (a) (b) (c) (d) give, promise to give, or offer a payment, gift or hospitality with the expectation or hope that a business advantage will be received by EAL, or to reward a business advantage already given by EAL; give, promise to give, or offer a payment, gift or hospitality to a government official, agent or representative to facilitate or expedite a routine procedure; threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns about an actual or potential breach of this anti-bribery policy; or engage in any activity that might lead to a breach of this anti-bribery policy. 10.4 No gifts or hospitality should be offered to any parties involved in tender or contract negotiations with EAL or in dispute with EAL, without prior written approval from your Executive Committee Director (with the exception of business lunches not exceeding £10 per person). 10.5 You must not make or accept facilitation payments (“kickbacks”) of any kind. Facilitation payments are unofficial payments made to public officials to secure or expedite the performance of a routine or necessary action. 11 Donations 11.1 We do not make contributions to political parties and we only make charitable donations that are legal and ethical under local laws and practices. No donation must be offered or made without prior written approval of The Edinburgh Airport Community Board. 12 Compliance with applicable Professional Codes of Conduct 12.1 If you are employed in a role to which recognised professional standards apply, you are required to comply with those standards as set out in any applicable recognised professional code of conduct.
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