Hospitality and Gifts Policy

  1. Introduction
    • BBlluuee WWhhaallee MMeeddiiaa LLttdd (“the Company”) recognises that trust and confidence in the propriety of its activities is essential to its continuing success and In order to foster the trust and confidence that clients, suppliers, workers and the community in general have in the Company, it is important that the Company, its  employees  and  agents  behave,  and are seen to behave, appropriately and honestly at all times.
    • This Hospitality and Gifts Policy aims to:
      • Protect the reputation of the Company;
      • Protect employees from accusations of impropriety;
      • Ensure that all clients and suppliers are dealt with on an equal basis;
      • Avoid any potential conflicts between employees’ private interests and

professional duties;

  • Instil a strong anti-corruption culture in the Company and put in placea gift and hospitality monitoring process to further compliance with the Bribery Act
  • Employees are advised that, notwithstanding anything contained herein, where there is any doubt over the permissibility or propriety of accepting a gift or hospitality offer they should decline that offer. Nothing should be accepted which would bring the Company into
  • This policy applies to the Company and to any associated persons as defined by the Bribery Act

2. Receiving Gifts

  • Save for gifts of low value and which are mere tokens (such as promotional pens, calendars and stationery), excluding money, employees of the Company are not permitted to accept any gifts from customers, suppliers or other third parties involved with the
  • The Company recognises that there may be exceptional instances when refusing a gift will cause significant offence or embarrassment. In such instances the gift may be accepted and subsequently donated to a charity of the Company’s
  • Where practicable any employee minded to accept a gift should first seek approval from Stephanie Sweeney, Operation If it is not practicable to gain prior approval, the accepting employee should inform Stephanie Sweeney, Operation Director. as soon as possible after receiving the gift.
  • An accurate record must be kept of all gift offers made to the Company or to employees of the Company by third parties, and must be filed in the “Hospitality and Gifts Register” (“the Register”). Any employee who is offered a gift which is not merely a token should record, as soon as is reasonable practicable:
    • A description of the gift offered;
    • An estimation of the value of the gift offered;
    • Whether it was rejected or accepted;
    • If accepted, why it was accepted;
    • Whether prior approval was obtained, and if so, from whom; and
    • Who it is donated to (see sub-Paragraph 4 below).

3. Hospitality

  • “Corporate Hospitality”, for the purposes of this policy, is any form of accommodation, entertainment or other hospitality provided for an employee of the Company by a third party and which is extended to the employee solely or significantly due to his position as a representative of the Company. This excludes the classes of hospitality particularised at paragraph 3.2
  • For the purposes of this policy and for the sake of clarity, the following are not normally considered Corporate Hospitality and will not require any approval prior to acceptance:
    • Normal working lunches or refreshments provided during a business visit;
    • Hospitality extended to employees attending a Company approved seminar, conference or other external event, provided that such hospitality is extended to all who are in attendance;
    • Benefits derived from frequent traveller schemes, awarded during travel paid for by the Company
    • Free seminars, talks or workshops, provided that they are free to all in attendance and are not provided solely for employees of the
  • All employees are required to obtain approval before accepting any formof Corporate Hospitality which is offered to Approval must be sought from Stephanie Sweeney, Operation Director.
  • An accurate record must be kept of all Corporate Hospitality offered tothe Company or to employees of the Company for entry on the Register. Any employee offered any form of Corporate Hospitality must record, as soon as is reasonable practicable:
    • A description of the hospitality offered;
    • An estimation of the likely value of the hospitality;
    • Whether it was rejected or accepted;
    • If accepted, why it was accepted; and
    • From whom prior approval was

4. Hospitality and Gifts Register

  • The Register shall be held by Operation Director (“the Registrar”).
  • All offers of gifts or hospitality must be recorded on a Register Entry Form, available from https://bluewhalestaffportal.co.uk/register-of-gifts The Register Entry Form must be signed by the employee and countersigned by the relevant manager         before         being         returned          to the

5. Breach of this Policy

  • Compliance with this policy is essential to the protection of the Company’s reputation and that of its Any employee or associate person who is found to have acted in contravention of this policy or its principles maybe subject to disciplinary action, including summary dismissal where the breach amount to gross misconduct.
  • Any employee or any associated person (as defined by Section 8 of the Bribery Act 2010) found giving or receiving bribes or bribing a foreign official will face criminal charges under the provisions of the Bribery Act 2010. Anyone found guilty of bribery, will be responsible for bearing any related remedial costs such as losses, court fees or

This policy has been approved & authorised by: Name:         Stephanie Sweeney

Position:                                          Operation Director

Date:                                                 05:01:2021

Signed by: