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Gift and Benefit Reporting and Registration Procedure

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Section 1 - Purpose and Context

(1) The Gift and Benefit Reporting and Registration Procedures outline the requirements for staff to report gifts or benefits they have received or accepted in accordance with the Gift and Benefit Acceptance and Management Policy. These procedures should be read in conjunction with the Gift and Benefit Acceptance and Management Policy.

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Section 2 - Definitions

(2) Refer to the Gift and Benefit Acceptance and Management Policy.

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Section 3 - Policy Statement

(3) Refer to the Gift and Benefit Acceptance and Management Policy.

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Section 4 - Procedures

Reporting of Bribes, Potential Bribes and Solicitation of Gifts

(4) Bribes and potential bribes, and the witnessing of the solicitation of a gift/benefit must be reported as soon as possible.

(5) An employee who is offered a bribe, or believes the offer of a gift or benefit is a bribe, or believes that they have witnessed another employee soliciting a gift or benefit in order to undertake a specific action, must notify his/her supervisor or another senior manager of the incident as soon as possible. This initial notification should occur within 24 hours of the incident (excluding weekends and public holidays for non-shift workers) if possible and it can be in either verbal or written form. If the incident involves the employee's supervisor the employee must notify another senior manager.

(6) The employee must follow the initial notification with the submission of a written report. The written report must be submitted within 48 hours to whoever the employee made the initial notification. The report should include:

  1. the name(s) of those involved and their contact details (if known),
  2. the date, time and place of the offer/presentation/solicitation,
  3. the circumstances of the offer/solicitation, e.g. what it involved and what the employee thinks it was intended to persuade him/her to do,
  4. any action the employee took at the time, e.g. what the employee said or did at the time,
  5. any other relevant details, and
  6. the employee's signature and date on which the submission was lodged.
The employee must retain a copy of the report.

(7) When a supervisor or senior manager receives an initial notification they must report the incident to theVice-President, People and Advancement. On receipt of an initial notification, the Vice-President, People and Advancement must assess the situation on a case by case basis and make a determination as to if and how to pursue the matter. In circumstances where the recipient is at or above Deputy Vice-Chancellor and Vice-President level, reporting is automatically escalated one level, e.g. if the DVC/VP is the recipient, the report is submitted to the Vice-Chancellor and President.

(8) Where it is determined by the Vice-President, People and Advancement that the reported incident involves or is likely to involve corrupt conduct the Vice-Chancellor and President must be notified. The Vice-Chancellor and President will report such incidents in accordance with Section 11 of the Independent Commission Against Corruption Act, 1988.

(9) Where necessary the Vice-President, People and Advancement or Vice-Chancellor and President will immediately initiate appropriate action in regard to disposal of the gift/handling of the incident.

(10) Following investigation, deliberations and management of the incident, if it is determined that the gift can be accepted (i.e. that there was no corrupt dealings), the gift or benefit must be recorded on the University Gift Register by emailing corporategifts@westernsydney.edu.au . The Office of Human Resources will provide advice on this.

Reporting Gifts of Appreciation

(11) All offers of gifts of appreciation should be reported to an employee's supervisor within 14 calendar days of the offer.

(12) Where a gift of appreciation is above the nominal value it must also be reported to the employee's unit head and be recorded on the University Gift Register by emailing corporategifts@westernsydney.edu.au . Such reports must include a recommendation as to the utilisation of the gift/benefit if accepted which can include a request by the employee to retain the gift. The unit head will determine the outcome of the recommendation. The following information should be supplied:

  1. The name of the recipient;
  2. The date on which the offer/presentation occurred;
  3. The type of gift - e.g. gift of appreciation;
  4. The name(s) of those involved in presenting the gift;
  5. The outcome of the offer - e.g. refused/accepted/approved by the unit head for the employee to retain for personal use;
  6. A description of the gift;
  7. An estimation of the value of the gift, or actual value if known;
  8. The location of the gift, if displayed.

Reporting Token Gifts

(13) Token gifts are gifts that are of nominal value or less, as determined by the University, and do not need to be recorded on the University Gift Register.

(14) Employees that receive token gifts must report these to their supervisor, by email, within 14 calendar days of receiving them.

Reporting Official Gifts

(15) The offer of official gifts must be reported to the employee's supervisor, the relevant Dean/Director. Acceptance of official gifts above the nominal value must be recorded on the University Gift Register at corporate gifts@westernsydney.edu.au. The following information should be supplied:

  1. The name of the recipient;
  2. The date on which the offer/presentation occurred;
  3. The type of gift - e.g. official gift;
  4. The name(s) of those involved in presenting the gift;
  5. The outcome of the offer - e.g. refused/accepted;
  6. A description of the gift;
  7. An estimation of the value of the gift, or actual value if known;
  8. The location of the gift, if displayed.

Reporting the Disposal of Official Gifts

(16) Where an official gift can be disposed of in accordance with the Gift and Benefit Acceptance and Management Policy, the disposal action must be reported to the employee's supervisor and must be recorded on the University Gift Register. The employee should email the University Gift Register at corporategifts@westernsydney.edu.au with the following information:

  1. The name of the recipient;
  2. A description of the gift and where it came from, including the name of the person(s) who gave the gift if known;
  3. The date on which it was disposed;
  4. How it was disposed - e.g. added to the University library, art or other collection, sold, or discarded.
  5. An estimation of the value of the gift, or actual value if known;

Reporting Gifts that form part of an Agreement

(17) Where the University has entered an agreement that incorporates the receipt of a gift, acceptance of such gifts will be recorded on the University Gift Register. The employee responsible for receiving such gifts under the agreement is responsible for emailing corporategifts@westernsydney.edu.au with the following information:

  1. The name of the recipient;
  2. The date on which the offer/presentation occurred;
  3. The type of gift - e.g. gift of appreciation or official gift;
  4. The name(s) of those involved in presenting the gift;
  5. A description of the gift;
  6. An estimation of the value of the gift, or actual value if known;
  7. The outcome of the offer - e.g. refused/accepted;
  8. The location of the gift, if displayed.

Reporting Gifts/Prizes received at a Conference or Trade Show

(18) Generally employees that attend trade shows do so because they are involved in decision making process within the University regarding the trade that is being shown. Any offer of a gift or prize could cause a conflict of interest for the employee and should be declined, however where an employee accepts a gift/prize received at a trade show they must report it to their supervisor within seven calendar days. Such prizes/gifts should not be retained by the employee. The employee must also record the gift/prize on the University Gift Register by emailing corporategifts@westernsydney.edu.au with the following information:

  1. The name of the recipient;
  2. The date(s) on which the prize was won/given;
  3. Details about the trade show and the name of the company that offered the prize;
  4. An estimation of the value of the prize;
  5. What the recipient has done with the prize (e.g. - the prize has been disposed of, the prize is offered to the Student Experience Office to use as a prize for students).

(19) An employee must report gifts/prizes received at conferences over the nominal value to his/ her supervisor and these must be recorded on the University Gift Register. The employee should email corporategifts@westernsydney.edu.au with the following information:

  1. The name of the recipient;
  2. The date(s) on which the prize was won/given;
  3. Details about the conference and the name of the company that offered the prize;
  4. A declaration by the recipient that they have no conflict of interest in accepting the prize;
  5. An estimation of the value of the prize;
  6. The intended use of the prize (e.g. - the employee retains, the supervisor retains for use by the unit, the prize is offered to the Student Experience Office to use as a prize for students).

Reporting Gifts of Hospitality

(20) An employee must report gifts of hospitality above the nominal value to his/her supervisor within 14 calendar days of accepting the offer. The notification should include the following information:

  1. The name of the recipient;
  2. The date(s) on which the hospitality was offered accepted;
  3. The name(s) of those who made the offer;
  4. A description of the hospitality and in what context it was offered;
  5. An estimation of the value.

(21) The supervisor will determine whether the hospitality should be recorded on the University Gift Register. The supervisor must request that the employee records the hospitality on the University Register if the hospitality is deemed to be extravagant or above that which the University would provide in a similar situation.

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Section 5 - Guidelines

(22) Nil.