Guidance

Hospitality and Gifts

Published 27 October 2026

Introduction

This Nuclear Waste Services Guidance (NWSG) provides guidance and information to support the Nuclear Waste Services Process Map (NWSPM) 00.03.01 (Gifts and Hospitality).

Scope

This document sets out the process for declaring Gifts and Hospitality (defined in section 3) and the preparation and maintenance of the Gifts & Hospitality (G&H) Register. It applies to all NWS employees (including permanent or fixed term contractors) (“Employees”) and to the following categories of applicable non-employees (in all cases only to the extent the gift or hospitality is offered or provided in connection with their work at NWS) – i) non-executive directors; ii) secondees to NWS; iii) all contingent labour with whom NWS is contracting with at the relevant time); and apprentices and graduates (employed by Energus) (“Relevant Non-Employees”).

Key Definitions

Gift refers to all products, services, cash (or cash equivalents such as vouchers), gratuities, discounts, favours, or other things of value (including internships or work experience) for which the recipient does not pay the fair market value (even if nominal) and/or go through the appropriate HR or Procurement process. Gifts do not include Hospitality (as defined below) as separate provisions apply to Hospitality.  

Hospitality means meals, drinks, entertainment (including, but not limited to, tickets or invitations to sporting or cultural events), recreation, travel, accommodation (such as hotel stays) and other courtesies which are of any value, even if nominal and for which the recipient does not pay the fair value. It is not considered Hospitality for the purpose of this process if the provider and recipient are Employees of NWS (or Relevant Non-Employees) and another NDA group company – although the Travel & Expenses (T&S) Policy would apply.

Procedure

Overarching Purpose

This procedure is intended to help promote a high standard of business integrity and mitigate the risk of bribery and corruption that exists through the giving and receiving of Gifts and Hospitality. It also supports its Employees and Relevant Non-Employees in meeting their obligations in respect of Managing Public Money. Those to whom this Procedure applies must always keep in mind (when offering Hospitality) that public money is being used and must actively reflect this consideration in deciding whether Hospitality is appropriate.

We recognise that Gifts and Hospitality can in certain circumstances help build business relationships, and this Procedure does not seek to prevent it (although overall, accepting Gifts is not encouraged). However, any benefit must be balanced with upholding (and being perceived as upholding) high standards of propriety and guarding against any reasonable suggestion of conflicts of interest, or an undue obligation being created. This Procedure requires individuals to exercise good judgment in deciding whether it is appropriate to accept a Gift or accept or offer Hospitality.

Gifts - key considerations

Subject to the provisions of section 4.4 below (“G&H Conditions”) – which must always be applied, accepting gifts is not encouraged but is permissible. Offering gifts is never acceptable.  

However, token value (up to a value of £25 each) corporate branded goods such as notebooks (both accepted and offered) are not considered gifts for this purpose and are acceptable, and no G&H Return is required in respect of these items. 

Cash and cash equivalents (including vouchers) are never acceptable, whether offered or received.  

If gifts are received from overseas in the context of international relations, HMRC provides guidance (OFGIF2100) concerning tax relief and this must be considered by the recipient, and this should be discussed with the Company Secretariat team.

Hospitality – key considerations

Subject to the provisions of section 4.4 below (“G&H Conditions”) – which must always be applied, it is permissible to accept or offer Hospitality.  

Basic refreshments: Minor hospitality such as coffee, refreshments in a meeting or sandwich lunches, with an estimated value of £15 or less are always acceptable and do not require a G&H Return. More substantial meals offered by third parties (including service providers or suppliers) are acceptable subject to meeting the G&H Conditions. 

Industry Conferences: Attendance at a relevant industry conference does not require a G&H Return if tickets have been paid for by NWS, and nor do associated refreshments. If free tickets, transport, or accommodation is provided by the organisers or third-party sponsors, or provided as part of an invitation to speak at such an event it may be accepted provided the G&H Conditions are met and should be recorded.  

NWS organised conferences with external attendees: If NWS is organising a conference or event, the costs and covering or reimbursement of travel, accommodation and meal expenses of external speakers/ service providers do not need to be recorded for the purposes of this process. The T&S Policy must be followed, and the G&H Conditions must be met. 

NDA group events: When Hospitality is provided by NDA or another NDA group company and it is predominantly an event for those working in NDA group companies, a G&H return is not required, but the T&S Policy must be followed.

G&H Conditions

The person accepting the Gift or accepting or offering the Hospitality must consider that each of the following conditions are met, on every occasion that a Gift is accepted, or Hospitality is accepted or offered:  

• The Gift will be accepted, or Hospitality will be accepted if offered in good faith and is not disproportionate in the context of the relationship in terms of value and frequency.  

• The Gift or Hospitality will not compromise judgement or integrity or create some form of obligation to the other party or create the impression that it has or could do so. 

• The acceptance of a Gift or acceptance or offering Hospitality will not cause embarrassment to NWS. 

• The Gift or Hospitality should be to / from organisations that have a business connection to NWS, and there must be a legitimate business reason for it.  

• The Gift or Hospitality must not have been requested by the recipient.  

• The Gift or Hospitality must not be provided to a party with whom NWS is in a live procurement process, where either person has material involvement or influence in the decision-making process. If in any doubt, check a supplier’s status with the commercial directorate. 

• The other party’s organisation permits the offering of such Gifts or accepting or offering Hospitality under the same circumstances.  

• The Gift or Hospitality is not being given in a personal capacity to circumvent this process.  

• Both the provider and recipient must be in attendance (except for accommodation and travel if otherwise allowable).  

If these conditions cannot be met, then the Gift should not be accepted. 

In respect of offering Hospitality, the T&S Policy must be applied, and the processes set out in the T&S Policy regarding the use of purchase orders must be followed. Important considerations are set out below:

• In-house catering services must be considered as a cost effective first choice for offering Hospitality.  

• Where NWS pays or reimburses costs for Hospitality for Third parties, for example Site Stakeholder Group members, these costs must be in line with the levels set by NWS’s T&S Policy for meals, drinks, accommodation, and travel expenses.  

• The cost must be commensurate with that expected by the nature of the event and the cost per person must not exceed £40 (of which a maximum of 2 alcoholic beverages are permitted) unless approval is provided in advance of booking, in writing by the Chief Financial Officer.

Approvals

Approval from the relevant Head of function (or in the case of the CEO or Non-Executive Directors, from the Chair) (“the Approver”) is required for accepting Gifts and accepting or offering Hospitality that meet the threshold for completing a G&H Return (per s4.6 below) (i.e., more than £15 for Hospitality and not a corporate branded item with a value of £25 or less) as follows: 

• Offering Gifts – NWS does not have any delegated authority to offer Gifts and so no Gifts may be offered. However, token value (up to a value of £25 each) corporate branded items are acceptable, and no G&H Return is required in respect of these items.  

• Accepting Gifts - Approval must normally be obtained in advance (or as soon as possible afterwards). If approval is not given, the Gift must be politely returned or subject to the Approver’s discretion, donated to a charitable organisation, library or if deemed appropriate put to another use, e.g. displayed in offices.  

• Offering Hospitality - This must be in line with the levels and process set out in the NWS T&S Policy for meals, accommodation, and travel expenses. Approval must normally be obtained in advance (or as soon as possible afterwards).  

• Accepting Hospitality – Approval must normally be obtained in advance (or as soon as possible afterwards).

Both the requestor and Approver must consider the application of the G&H Conditions. Further guidance may be sought from the Company Secretariat function. 

In circumstances where Employees / Relevant Non-Employees are offered Gifts or Hospitality without prior notice they are responsible for accepting or declining any Gifts or Hospitality. The allocation of any Gifts is a decision for the Approver.  In reaching their decision consideration should be given as to whether the gift should be put to another use (e.g. donated to a charity or a library, displayed in offices etc) and the risks to the reputation of NWS associated with the retention of the gift by an individual. In no circumstances may an individual sell an accepted gift for monetary gain.

The Gifts & Hospitality Return

A Gifts & Hospitality Return (“G&H Return”) which can be obtained from Company Secretariat or online must be completed whenever you accept a Gift or accept or offer Hospitality that is over £15. This must be done as soon as reasonably possible (within one calendar month).  Details of the approver and the date given must be provided. 

There is no need to record Hospitality which is not accepted unless it is either: 

• a substantial offer with no or minimal related business purpose (for example, corporate hospitality to a sporting event); or 

• a substantial personal invitation with some related business purpose (for example, a conference in Dubai). 

Gifts which have been offered to Employees or Relevant non-Employees but not accepted must be recorded on a G&H Return.

Gifts and Hospitality Policy Breaches

Under the Bribery Act 2010, it is a criminal offence for employees in an official capacity to accept any gift or consideration as an inducement or reward for: 

• doing or not doing anything; or 

• showing favour or disfavour to any person. 

As a result, allegations of breaches of the Gifts and Hospitality policy should be reported using the methods detailed within the Fraud, Bribery and Corruption Policy, options include using Safecall, direct to a Line Manager, or to the Head of Enterprise Risk and Assurance or General Counsel/Company Secretary. Investigation will take place in line with the Fraud, Bribery and Corruption Response Plan and subsequent action may be taken in line with the NWS Disciplinary policy.

Gifts and Hospitality Register Publication

Company Secretariat maintain a G&H Register based on the G&H Returns received.  

The G&H Register lists: 

• the name of the person accepting the Gift or accepting or offering the hospitality.  

• the job title and directorate of the person.  

• the date the Gift or Hospitality was offered.

• the name of the individual and organisation who offered the Gift or Hospitality or the name of the individual and organisation to whom the Hospitality was offered. 

• the type of Gift or Hospitality. 

• an estimated value of the Gift or Hospitality. 

• whether the Gift or Hospitality was accepted or rejected.  

• any further comments. 

The Company Secretariat Department will send the G&H Register to the Chief Executive Officer for review on or around 1 May and 1 November.

Documentation

See also 

• Cabinet Office: NDPB Guide to Openness and Accountability 

• The Civil Service Code 

• HM Treasury: Managing Public Money 

• T&S Guidance 

• Fraud, Bribery & Corruption Policy 

• Fraud, Bribery & Corruption Strategy 

• Fraud, Bribery & Corruption Response Plan 

• OFGIF2100 - General principles: tax treatment of gifts received by UK ministers and officials during the course of overseas visits - HMRC internal manual - GOV.UK (www.gov.uk)