SIGA Policy on Gifts and Entertainment
Rules on Gifts and Entertainment
Gifts and Entertainment are a normal part of business life, but in the context of SIGA’s leadership role in sports and sports related business, its goal and mission, and in order to safeguard its reputation, it is important to ensure that we are aware and sensitive to the fact that Gifts and Entertainment can present increased reputation risk, even if a person giving or receiving has honourable intentions.
Your good judgement and ethical standards are therefore important when giving and receiving Gifts and Entertainment. Simply following applicable laws and regulations may not be enough in this context: Reputation risks can easily arise and the negative perceptions that can arise from providing or receiving seemingly lavish Entertainment and Gifts can be highly damaging and can be difficult to justify and live down.
The principles set out in this Policy are obligatory and outline what is acceptable when giving or accepting Gifts or Entertainment; but if you ever are in any doubt, do not hesitate to contact the CEO, Designated Ethics Officer, a member of the Council or their designee before accepting or giving a Gift or Entertainment.
This Policy is also designed to support everyone with a formal SIGA role in pre-empting situations, where giving/receiving gifts/entertainment would create any reasonable expectations of favours in return, while at the same time appreciating the cultural importance of gifts in many countries as a token of appreciation of a good business relationship and social events as an important means of building and maintaining good working relationships.
This Policy, whilst rightly expecting the highest ethical standards of members of SIGA’s Internal Organs must strike the right balance of appreciating the voluntary nature of their role and the fact that their paid day-to-day jobs might sometimes be subject to different expectations regarding gifts and entertainment.
Providing and receiving Gifts and Entertainment must always be moderate and tasteful, respectful of cultures and gender.
Gifts given by SIGA and received by SIGA staff must never be more than nominal tokens of regard or appreciation, modest and reasonable in context. For example giving or accepting a low value item or a branded gift after participating in a conference would be acceptable.
Gifts or Entertainment may never be made in such a way that they could be interpreted (or intended) as bribes or other improper forms of compensation, inducement or payment.
Applicability / Scope
This Policy applies to all SIGA employees, Contractors, Directors and Members of SIGA Internal Organs such as the Council, Standing Committees, Ethics Committee and Audit and Compliance Committee (‘SIGA Staff’).
SIGA Gift and Entertainment Register
A SIGA Gift and Entertainment Register is to be maintained by the SIGA Secretariat. Every time a member of SIGA Staff receives or gives any gift/entertainment, (s)he must make an entry into the Register. The SIGA Gift and Entertainment Register is to contain the following information about any gift/entertainment given or received by anyone with a formal SIGA role: Date, person/organization giving, person/organization receiving, nature of gift/entertainment, monetary value of gift/entertainment. If the monetary value of the gift/entertainment required prior written approval, the entry also has to include the name and date of the person providing approval.
The Register is to be made publicly available on the SIGA website with regular updating, at least every three months. If SIGA’s Ethics Committee finds that applicable personal data protection laws or best practices prescribe it, the names of persons giving/receiving gifts and entertainment can be anonymized in the publicly available version of the Register. All entries in the Register are subject to review by SIGA’s Ethics Committee once every three months. SIGA’s Audit and Compliance Committee reviews entries for members of SIGA’s Ethics Committee.
Rules on Gifts
Giving and receiving directly or indirectly any cash Gifts, loans or any such similar Gifts (such as vouchers, store cards or any cards of value) are prohibited without exception.
Gifts offered by customers, suppliers and other third parties should not be accepted if the actual or imputed fair value exceeds USD50. All gifts will need to be accounted for on the SIGA Gift Register.
SIGA staff should not contribute anything of value (including employee time and resources) to a political campaign or party without the prior written consent of the SIGA Ethics Committee.
Giving tickets to Sporting Events or associated Entertainment (such as but not limited to, access to VIP areas, boxes or lounges of any kind, Opening or Closing ceremonies such as to the Olympics, Cup Finals, Golf tournaments, etc) is prohibited. The only exception to this prohibition is if the SIGA Staff member is giving the tickets in the context of their role outside of SIGA, in which case the provision of tickets should be written up in the SIGA Gifts Register explaining the context of the gift and to whom it was given.
Receiving tickets to Sporting Events or accepting any associated Entertainment is not prohibited, but it is strongly discouraged and, in the case of SIGA employees, is subject to a case-by-case review that requires prior approval of the Line Manager of the employee or, in the case of the CEO, by the Designated Ethics Officer. In addition, the market value of the ticket and or Entertainment received by the SIGA employee must be paid in full by SIGA to the would be donor, alternatively a donation to charity in the corresponding amount that represents the market value of the ticket and or Entertainment must be made prior to attending, and recorded accurately and transparently in SIGAs books and records. In all cases, SIGA Staff receiving tickets to Sporting Events and/or associated Entertainment must make an entry in the SIGA Gifts Register regardless of the capacity in which they are receiving the tickets or entertainment.
Tickets to Sporting Events or Entertainment associated with Sporting Events that are offered or given to SIGA Staff may not be sold to any third party or given as a Gift to circumvent this Policy.
There are times when it may not be possible for SIGA Staff to decline a Gift without causing offence. In such circumstances, Gifts that exceed USD50 may be accepted at the time of giving but they must be disclosed in the SIGA Gifts Register and disposed of by being given to a charity or raffled/auctioned so that the proceeds can be donated to charity.
Most national governments and many regional and local jurisdictions have laws that restrict Gifts and Entertainment for Public and Quasi- Public Officials (including international organizations, sports governing bodies such as UEFA, FIFA, International Olympic Committee, other international sports bodies etc) and, in many instances, also their Immediate Family members. Even an unintentional and seemingly innocuous deviation from this policy can expose SIGA and possibly SIGA staff to regulatory fines and penalties, reputational risk and even criminal penalties.
Rules on Entertainment
Where SIGA is offering the Entertainment, then at least one SIGA staff member must be present during any Entertainment; otherwise it is a Gift, and subject to the Rules on Gifts.
Entertainment may be offered and accepted as long as it is within a business context and there is no conflict of interest or the possible perception of such a conflict (for example; no Entertainment during a contract negotiation).
Entertainment should always be modest and reasonable. Where SIGA Staff are extending Entertainment, all expenses must be approved according to applicable rules and internal controls and recorded properly in SIGA’s books.
Accepting any Entertainment that is likely to be lavish or perceived as such, or is an exclusive or high profile event such as a Gala Dinner as part of an awards ceremony or any other similar entertainment should be carefully reviewed by the invitee together with the CEO or, where applicable, the Designated Ethics Officer. The review must consider whether there is any business element associated with attendance (such as networking to increase SIGA’s membership) and this must be weighed against any possible negative reputation risks. Risk mitigation measures should also be actively considered and implemented wherever possible and could include (but are not limited to) making a charitable donation corresponding to the value of the Entertainment. All Entertainment accepted must be entered into the SIGA Gifts Register.
Rules on Gifts and Entertainment
SIGA staff may not, directly or through a third party, offer, promise or give to, or request, agree to receive or request from, any third party or Public Official, including any and all sports-related organizations, leagues and their participants, any Gifts or Entertainment if:
- By doing so, the employee would violate this Policy;
- The Gifts and Entertainment could be perceived as a Bribe;
- Doing so is dishonest, illegal or misleading;
- By doing so, the recipient appears to be under obligation, or
- It is offered with the intent to influence or appear to influence, the Public Official or third party in any vote, action, inaction or decision, such as the allocation of funds or award of a contract.
- In all cases, when SIGA Staff travel in a SIGA context with the express approval of Line Manager or, where applicable, the Designated Ethics Officer, SIGA pays for their travel and accommodation. SIGA does not pay for travel and accommodation for anyone else, unless it is part of a contractual agreement, for instance with a consultant. When SIGA Staff participate in Entertainment, SIGA pays for its share of expenses. When SIGA offers entertainment, it only pays for SIGA Staff associated expenses. Everyone else participating covers his/her own associated expenses.
Immediate Family and close friends
Along the lines of the spirit of this Policy, SIGA Staff are required to proactively inform the SIGA CEO, if they become aware that any of their Immediate Family or close friends are about to receive gifts or entertainment of a nature that can reasonably be perceived to leave a SIGA Staff member with an indirect obligation of a favor in return which relates to SIGA in one way or the other. Members of SIGA’s Ethics Committee and SIGA’s Audit and Compliance Committee have to inform the Chair of SIGA’s Ethics Committee. The Chair of SIGA’s Ethics Committee has to inform the Chair of SIGA’s Audit and Compliance Committee.
For the purposes of this policy the following are defined:
- Gifts and Entertainment – anything of value (including meals, entertainment and gifts) that personally benefits any individual or organization.
- Immediate Family – Spouses, domestic partners, spousal equivalents, children and/or dependents.
- Public Official – an elected or appointed official, or any other official or employee of any federal, national, state, provincial or local legislature, executive branch, or other government agency, commission, board, authority, public fund, or any other governmental or quasi-governmental entity, including:
- Any officer or employee of government (including, but not limited to, any military personnel), or any of its departments, agencies, incorporated entities, or political subdivisions (including, but not limited to, wholly or partly state-owned and state-controlled enterprises)
- Any director, officer, or employee of any legal entity or joint venture that is controlled (qualitatively or quantitatively) or significantly owned by a government (including, but not limited to a military personnel) or any of its departments, agencies, political subdivisions, or incorporated entities (including, but not limited to, state-owned and state-controlled enterprises)
- Any officer or employee of any public international organization (including, but not limited to, The Organization for Economic Cooperation and Development, World Bank, United Nations, multilateral development banks, the International Monetary Fund, International Sporting Organizations including the International Olympic Committee, National Sporting bodies including national sports governing organizations)
- Any person that represents, or acts on behalf of, or in an official capacity for, any government or any of its departments, agencies, political subdivisions, or incorporated entities (including, but not limited to, state-owned and state-controlled enterprises), even if in an honorary capacity
- Any political party, party official, or candidate for political office
- Any member of a royal family or provincial or tribal government
- Any member of a legislative or judicial body including sports tribunals and courts of appeal.
- Anything of Value means anything having any value or tangible benefit at all including, but not limited to:
- Cash and cash equivalents
- Gifts (including, but not limited to, gifts or courtesies forming part of a local custom; wedding, funeral and personal gifts; jewellery)
- Political contributions
- Donations to charities or foundations at the behest of an Official or his/her family
- Entertainment (including, but not limited to, Sporting Events as defined herein, meals and tickets to venues and events including events sponsored by Third Parties)
- Travel and travel-related expenses Accommodation and hospitality
- Ownership rights or interests in joint ventures or other entities
- Inflated or excessive contract prices
- Below market leases or rentals
- Offers of employment (whether long-term or temporary), including consulting fees, speaking fees, or honorariums, scholarships, or internships.
- Sporting Event(s) for the purposes of this Policy includes sports matches, fixtures, opening and closing ceremonies associated with games and sporting tournaments.
SIGA currently makes charitable donations to a number of registered charities. Donations to any other charities must be approved by the SIGA Council, in advance of commitment and disbursement. All donations will be publicly disclosed on SIGA’s website.