Version 7 - 13 February 2023

Introduction

The activities of UMi often involve staff in commercial relationships and close working with other organisations, including customers and suppliers. It is therefore important that the conduct of all staff responsible for the management of such relationships should be beyond reproach.

Conflicts of interest may arise if there is a contractual or pecuniary relationship with an external party which would be in conflict with a member of staff’s duties. A conflict of interest may also arise from close connections with other companies or organisations arising from family ties or personal relationships.

Conflicts of interest may also be ‘perceived’ to exist, for instance through the receipt of gifts and hospitality. Staff involved directly with customers and suppliers therefore need to be particularly mindful of this issue.

Purpose

This policy has been developed to outline the process that UMi will adopt in relation to the receipt of gifts and hospitality by staff as a direct consequence of their position within the group.

Scope

This policy applies to all staff which includes directors, employees and associates of UMi. For directors and associates the term ‘line manager’ will be used to refer to their UMi representative or chief executive.

The policy covers all offers of gifts and hospitality, which may include, but is not limited to:

• Cash or vouchers of any value
• Gifts
• Customer/supplier products or services
• Discounts on customer/supplier products or services
• Tickets or free attendance at events, such as sport or theatre
• Meals

The policy excludes normal courtesy gifts and hospitality, for example

• Refreshments at meetings, in the normal course of business
• Business lunches
• Corporate calendars, diaries, pens (of limited value)
• Attendance at corporate events when representing UMi
• Small gifts valued at less than £5

This policy should be read in conjunction with the following policies and procedures:

• Gifts and hospitality registration

Process

As a general rule UMi does not believe that the giving and receiving of gifts is appropriate to the efficient conduct of its business, and therefore staff must not accept any remuneration, gift or reward from any customer or supplier in connection with UMi business without prior permission of their line manager. To do so may leave the member of staff open to accusations of inappropriate relationships and/or corruption.

It is not the intention of UMi to prevent staff accepting normal courtesy hospitality, nor to refuse small value gifts of an innocent nature (eg calendars, diaries, pens). But care must be taken to ensure that whenever outside hospitality or gifts are accepted no obligation to the organisation offering the hospitality or gift is therefore created.

Any gifts or offer of hospitality (beyond normal courtesy mentioned above) to staff in connection with their work must be reported to their line manager by the member of staff. Forms for this purpose are available from the Toolkit (gifts and hospitality registration form).

Line managers have authority to approve the receipt of gifts and corporate hospitality up to a value of £25. Beyond that value, the form must be authorised by a member of the executive.

Offers of cash or discounts relating to customer/supplier products or services should never be accepted.

All forms should be passed to the Chief Financial Officer (CFO) for retention; completed forms will be reviewed by the CFO on an ongoing basis.

As an alternative to the individual member of staff retaining a gift, UMi encourages support of local charities by raffling to staff all such items throughout the year. Staff are therefore encouraged to donate any gift offered. The receipt of the gift must still be recorded.

If a member of staff is in any doubt, then they should consult with their line manager or CFO before accepting any offer or gift or hospitality.

Authority, responsibility & decision making levels

• Individuals are responsible for recording the receipt of any gifts and/or hospitality by completing the gifts and hospitality registration form and seeking appropriate
• Line managers are responsible for authorising gifts and/or hospitality up to a value of £25.

• Executives are responsible for approving anything with a value above £25; in doing so they should consider whether the gift is appropriate and whether it could be used for a purpose where one person does not solely benefit, for instance by sharing with the team or donating to a

Compliance and review

UMi will ensure compliance through periodic review and audit.

This policy will be reviewed at least annually and amended in line with any changes to the relevant legislation. It will also be reviewed as part of any investigations into complaints or suggestions for improvement if appropriate.