Overview
You must not solicit entertainment or gifts. You must not accept or offer in your official capacity, any fee, gratuity, gift, hospitality, or entertainment of any kind, from or to a Bank customer, supplier, or any other person, without authority from your Manager/Head of Division (HoD).
This policy is part of Our Code, which all colleagues are required to attest to on joining the Bank and annually thereafter.
Why do we need this policy?
The Bank’s position as a public body means that it has to apply, and be seen to be applying, high standards of ethical behaviour.
Additionally, under the Bribery Act 2010 it is an offence for a Bank colleague to offer, promise or give a bribe (financial or other advantage) to another person, or to request, agree to receive or accept a bribe from another person, and individuals may be subject to prosecution.
Who does this policy apply to?
This policy applies to all colleagues employed by the Bank. This includes consultants, contractors and agency colleagues.
What you must know or do?
1: General Principles
The following principles apply to all colleagues. If the acceptance of entertainment or gifts by an individual colleague was challenged it would be necessary to show that acceptance was appropriate, consistent with the Bank’s requirements, and did not give grounds to a perceived or actual conflict of interest or concern that personal judgement or integrity had been compromised.
These rules are the minimum standard to which we must all adhere. Executive Directors and Directors may need to adapt the rules should more stringent rules be required for the particular circumstances of their business area. Stricter rules will usually be required when colleagues have a direct commercial involvement with an organisation or individual through their work; for example, purchasing, tenders and contracts, financial market operations. Business areas will also need to consider their approach to the receipt of entertainment and gifts when individuals are heavily engaged in activities or projects over particular periods which might result in unusual levels of business contact.
Prior approval from the Secretary must be sought before the implementation of business area rules.
2: Entertainment
Offers of entertainmentfootnote [1] may be accepted or made where they are necessary to develop and maintain outside contacts relevant to work responsibilities. They should be restricted to working lunches or similar events as far as possible.
Approval should be sought for any entertainment unless it is provided by a public authorityfootnote [2] on that public authority’s premises as part of a work trip.
You should decline any offer of entertainment that might be seen as excessive, as putting the recipient under an obligation, as offered to influence a procurement decision, as in doubtful taste or as liable to bring the Bank’s name into disrepute. ‘Excessive’ includes offers of entertainment that are time consuming, over-frequent (part of a pattern of invitations to one area from a particular organisation that, taken together, appears inappropriate); or disproportionately lavish or expensive.
Invitations from firms regulated by the Bank or the FCA, or from professional advisers require the prior approval of an Executive Director or Governor (which may be a general permission rather than case by case).
Business contacts may also be personal friends. If you are offered any corporate hospitalityfootnote [3] by a personal friend and you accept it as part of your official Bank role (eg through your day to day Bank role, or your role on a Bank employee network) you need to seek approval. If the invitation from a personal friend is offered to you in a purely personal capacity (so not linked to your role at the Bank) and does not involve corporate hospitality, no approval is needed.
If you are invited to an event accompanying your spouse or partner, you should treat the invitation as though it was to yourself at the Bank and apply these rules accordingly. For example, you should consider if the invitation is from a Bank or FCA regulated firm; from professional advisers; or from an organisation that you have contact with as part of your role.
If in doubt about whether it is appropriate to accept an invitation, please discuss with your manager/HoD or seek advice from the Secretary’s Department before accepting the entertainment offered.
3: Gifts
You should not accept the presentation of gifts. Only where refusal would cause offence or embarrassment may a gift be accepted.
You must not accept cash or retail vouchers (except for commemorative coins/specimen notes), or electronic devices (for security reasons).
Colleagues may wish to consider providing the following sentence in advance to discourage the giving of gifts ‘Bank staff are discouraged from accepting gifts, due to our role as public officials. As such, please be aware that gifts may be required to be donated to charity in line with the Bank’s Entertainment and Gifts policy’.
You must not solicit gifts, including from a Bank supplier, for yourself or any other purpose.
Where a gift has had to be accepted (where refusal would have caused offence or embarrassment) approval for retention of the gift should be sought from:
- HoDs for items up to and including a value of £50;
- the Secretary or the Conflicts team for gifts over £50.
Gifts with a value over £100 cannot usually be retained and will be required to be passed to the Community team for the benefit of charitable organisations.
Gifts that consist of perishable goods (food items that need to be consumed within one month of receipt of the gift) with a value of up to £50 can be consumed or shared amongst work colleagues for consumption. Approval for retention of the gift should still be sought.
Approval should be sought for any gift that has been accepted, even if you do not wish to retain the gift yourself. Such unwanted gifts should be donated to a charity of your choice or passed to the Community team for the benefit of charitable organisations.
HoDs, and recipients should ensure they are not authorising / accepting gifts that when added together have a cumulative effect for an individual.
No gifts (such as hampers or ‘goodie’ bags) should be broken up into individual gifts to reduce the value.
You do not need to seek approval for the acceptance of trivial or ephemeral items, such as calendars and diaries.
Please be aware that gifts include those that are virtual or take the form of ‘prizes’ offered by a corporate entity when you are on Bank business.
4: Speaking engagements
As a general rule, invitations to speak at a commercially sponsored conference should be accepted only when the relevant HoD has agreed that the occasion provides a good opportunity for the Bank to communicate information to a relevant audience.
If the organiser offers to meet travel and/or accommodation costs, then provided the condition in the point above is met, this can be accepted.
Where fees and expenses are offered for speaking engagements and other appearances, they should be accepted and surrendered to the Bank; this includes where the option of a fee or gift is offered. Any gifts received in respect of speaking engagements/articles/media appearances should be dealt with in accordance with the requirements on gifts set out above.
The application of this policy will be in accordance with the relevant data protection legislation. For information on how the Bank processes your data, please see our staff data privacy notice.
5: Requirements for all members of Court and the Statutory Policy Committees
All entertainment and gifts (over £100) received by Court members, and members of the statutory policy committees (the Financial Policy Committee, Monetary Policy Committee, Prudential Regulation Committee and Financial Market Infrastructure Committee), along with Executive Directors who are members of a statutory policy committee are published on the Bank’s website on a quarterly basis.
Key Policy Requirements
For all Colleagues
1. You must seek approval promptly via the Our Code Compliance system for any entertainment or gifts received in an official capacity.
2. Entertainment received from a public authorityfootnote [4] on that public authority’s premises as part of a working trip does not require approval and does not need to be entered into the Our Code Compliance system.
3. Entertainment from firms regulated by the Bank or the FCA, or from professional advisers requires the prior approval of an Executive Director or Governor (which may be a general permission rather than case by case).footnote [5]
For all Seniors Managers and Heads of Division
1. You must ensure that you and members of your team understand the requirements of this policy.
2. Senior managers are responsible for approving promptly advance requests for entertainment. HoDs (and above) are responsible for approving retrospective requests for entertainment and for gifts promptly. If a gift is more than £50 in value, it must be approved by the Secretary.
3. You must promptly review any entertainment or gift reporting via the Our Code Compliance system.
4. Contact the the Conflicts team if you have any questions about the entertainment or gift reporting you have received.
What support is available to help you comply with this policy?
The following link will aid your understanding of, and compliance with, this policy:
The application of this policy will be in accordance with the relevant data protection legislation. For information on how the Bank processes your data, please see our staff data privacy notice.
What is the impact of non-compliance?
If you realise you have breached – or suspect that you might have breached – a requirement in this policy please tell AskCompliance as quickly as possible, so that the issue can be reported and redressed under the Bank’s Breach Management Policy. The Bank gives credit for you taking prompt responsibility for your mistakes. You should be aware that failing to discharge your responsibilities could lead to disciplinary or other action.
January 2026
‘Entertainment’ includes all hospitality received including meals (eg working lunches, breakfasts, and dinners), drinks and paid-for outings of all kinds (including a complimentary paid-for place at an event such as a conference, any related travel, refreshments, accommodation and / or expenses). Tea, coffee, and biscuits received at the offices of a third party do not need to be reported.
‘a body substantially publicly funded which performs statutory duties, objectives and other activities consistent with central or local government functions.’ This includes other central banks, national public bodies or equivalent European and international organisations’.
Hospitality that is offered and paid for by a firm or organisation.
‘a body substantially publicly funded which performs statutory duties, objectives and other activities consistent with central or local government functions.’ This includes other central banks, national public bodies or European and international organisations’.
Directors who are not Executive Directors should seek delegated authority / a general permission from the relevant Deputy Governor in relation to such invitations to colleagues in their Directorship.