Recording, reviewing and monitoring practice

The authority should keep sufficient information to support decisions made about gifts, benefits and hospitality. Records support transparency and allow actions and decisions to be scrutinised.

To record decisions made about gifts, benefits or hospitality, the authority should:

• decide whether officers must declare accepted and declined offers of gifts, benefits and hospitality
• be aware that if token gifts are not required to be declared and registered, integrity risks, such as continual offers and the acceptance of token gifts, may go undetected
• ensure the declaration and registration processes contain enough information to monitor, assess and report to the authority’s senior leadership team or audit committee
• set a timeframe for completing declaration forms, registers and other records so they are up to date and accurate.

Gifts, benefits and hospitality declaration form

Declaration forms allow officers to record details about offers of gifts, benefits and hospitality, and record reasons for accepting or declining them. Declaration forms also encourage officers to think about whether or not they should be accepting offers.

This sample declaration form can be customised to suit the authority’s circumstances.

The authority’s policy position determines what information is recorded. A declaration form should stand alone, and require no additional context to understand the decision made and why. The form should include:

• whether the acceptance of gifts, benefits and hospitality presents any conflict of interest and, if so, how these are to be managed
• a description of the nature of the relationship between the person or organisation offering and the officer accepting
• previous offers from the same person or organisation over a certain period, including any known offers to other officers in the business area
• a declaration that the information is true and accurate
• name and position of the delegated approver, and relationship to the officer
• what decision has been made in relation to the gift, benefit or hospitality, for example to accept and retain, accept and dispose, or decline.

The information gathered in the declaration form should be entered into a centralised gift, benefit and hospitality register to assist with monitoring.

Gifts, benefits and hospitality register

A register contains some or all of the information from a declaration form. The authority can maintain this as a physical or electronic document in the context of the its risks and legislative obligations. The register should be secure and held centrally. Some authorities are required to publish their registers while others may choose to publish them to aid transparency. Authorities should be mindful of any privacy or confidentiality requirements that may apply.

A gifts, benefits and hospitality register should include:

• description and estimated value of the gift, benefit or hospitality
• name and position of the person or organisation making the offer
• relationship between the parties involved
• reason for the offer
• confirmation of whether the gift, benefit or hospitality was accepted or declined
• approval by an authorised delegate, including the name and position of the officer.

This sample register can be customised to suit the authority’s circumstances.

Reviewing and monitoring declaration forms and registers are how an authority:

• gauges whether officers are following ethical codes and policy
• identifies emerging integrity issues before they become cause for concern.

The authority should identify who is responsible for reviewing and monitoring, and how it is to be done. For example, the register is to be maintained by an independent officer, and monitored and reviewed by an internal auditor.

Reviews involve both collecting and analysing quantitative and qualitative information. The authority should look for trends and patterns which need addressing. Patterns that might indicate the need for further scrutiny include:

• increase in the number of offers being made and/or accepted over a period of time, for example the last 12 months
• regular provision of gifts, benefits or hospitality from the same client, supplier or stakeholder
• officers in identified high risk positions, functions and activities accepting gifts, benefits and hospitality
• regular late declarations in a particular business area
• regular approvals by a particular manager or in a particular business area.

The authority should examine internal and external reporting on non-compliance with ethical codes and policy, and any disciplinary cases that involve the acceptance of gifts, benefits and hospitality. It should also consider ad hoc audits in high risk business areas.

Reports from monitoring and reviews should be made periodically (at least annually) to the authority’s senior leadership team or audit committee. Reports should seek to assure leaders about the effectiveness and proper administration of its controls. Reports should also include analysis of the authority’s gifts, benefits and hospitality risks, risk management approaches and any recommendations to inform continuous improvement, for example a need to update policy, refresh training or increase communications.

• Sample gifts, benefits and hospitality declaration form
• Sample gifts, benefits and hospitality register
• Gifts, benefits and hospitality template text: Information for public officers
• Accountability for managing tickets and hospitality checklist
• Decision-making tool: GIFT test
• Decision-making tool: HOST test