Financial Services & Procurement Division
Expenses Policy
2013 Edition
Part 3: Hospitality & Entertainment
Policy
Guide to personal expenses for hospitality and entertainment
when working on College business.
Valid from November 2013
Imperial College London
Expenses Policy (2013 Edition)
Part 3: Hospitality & Entertainment Policy
Contents
1.
Introduction ............................................................................................................. 3
2.
Alcohol policy .......................................................................................................... 3
3.
Staff and student entertaining ................................................................................ 3
3.1.
What you can claim.......................................................................................... 3
3.1.1.
Hospitality for meetings (including working breakfast or lunch) ................. 3
3.1.2.
Entertaining staff or students .................................................................... 4
3.1.3.
Staff social functions and tax .................................................................... 4
3.1.4.
Away days/strategy days/team building events ......................................... 4
3.2.
4.
4.1.
What you cannot claim..................................................................................... 5
Business entertaining ............................................................................................. 5
What you can claim.......................................................................................... 5
5.
Which analysis code should I use when making a claim? ................................... 5
6.
Gifts and hospitality: The Bribery Act .................................................................... 6
7.
Hall warden’s entertainment: use of amenities funds .......................................... 6
Appendix A: Contacts for enquiries .................................................................................. 7
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Expenses Policy (2013 Edition)
Part 3: Hospitality & Entertainment Policy
1.
Introduction
This part of the Expenses Policy deals with what you can claim if you are entertaining staff,
students or external visitors - that is, providing food, drink or other hospitality on College
business.
It is important to establish the nature of the event:
2.

Is the event to primarily entertain College staff and students with some (or no)
visitors attending? This is classed as staff and student entertaining.

Is the event to primarily entertain visitors with some College staff and students
attending? This is classed as business entertaining.
Alcohol policy
In line with the College’s Alcohol, Drugs and Other Substance Misuse Policy the provision of
any alcoholic drinks must be moderate in relation to the cost of food consumed and be
complemented by a selection of non- alcoholic alternatives. The College also expects that
staff who consume alcohol for the purpose of hospitality must have already finished work for
the day or not be required to return to work.
3.
Staff and student entertaining
The College is a charity, and a major recipient of public funds. All hospitality must therefore
be modest in scale.
Expenditure on hospitality is usually inadmissible on sponsored research accounts.
This section deals with what you can claim if you are entertaining - that is, providing food,
drink or other hospitality - anyone who is a College staff member or registered College
student. Please ensure a record of all the attendees and their department names are kept as
this must be included with the claim. All expenditure should be reasonable and appropriate.
3.1. What you can claim
3.1.1. Hospitality for meetings (including working breakfast or lunch)

Tea, coffee and soft refreshments should only be provided for internal meetings
where the meeting needs to be for two hours or longer. Refreshments can be
provided at all meetings that involve a person or organisation from outside the
College regardless of the length of the meeting.

Food (including pastries. sandwiches and fruit) can only be provided when it is
necessary to hold a meeting during a normal meal time (breakfast: before
9.00am; lunchtime: between 12.00 and 2.00pm; or evening: after 6.00pm), and it
is not practical to expect staff to bring their own food.
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Expenses Policy (2013 Edition)
Part 3: Hospitality & Entertainment Policy

Where possible the meeting should be held on College premises and food
provided by the College’s Catering department at:
http://www3.imperial.ac.uk/conferenceandevents/catering
3.1.2. Entertaining staff or students
Staff and student entertaining means food or drink for two or more members of staff or
registered College students. It includes seasonal celebrations (Christmas parties etc.), end
of project/term celebrations, working lunches, dinners, team-building events, leaving and
retirement functions. You must have approval from the Head of Department or Departmental
Operations Manager before organising or paying for any staff or student entertaining.
The cost of staff and student entertaining should not exceed £25 per head.
3.1.3. Staff social functions and tax
Any expenditure on social functions should be approved in advance by the relevant approver
(see part 1 section 15).
HMRC rules state that staff entertaining is a taxable benefit for the recipient. However,
providing that any entertainment is undertaken in accordance with (and subject to the
financial limits contained within) this Policy, the College will deal with any tax liability arising,
so that individual employees do not need to include items in their personal tax returns.
The College can however spend up to £150 per year including VAT per person attending on
either one major event or several smaller events without tax costs (this is an HMRC limit).
These should be annual events, such as Christmas parties, summer balls, spring socials,
etc. The events need to be open to all employees, or all employees of a given department, in
order to qualify. Events with a selected invitation list (e.g. directors or Heads of Department
only) are not allowable.
In addition to the £150 per year HMRC limit, the £25 per head staff and student
entertainment limit also applies on a per event basis.
Costs for major staff entertaining functions (for example an annual social) should be invoiced
directly to the College, not claimed on expenses, unless the most senior person present
pays the bill and claims through expenses.
3.1.4. Away days/strategy days/team building events
If a team-building event takes place away from the office (e.g. staff away days) meals are
usually included as part of the event. If they are not you can claim food and drink allowances
(to a maximum of £25 per head) provided the event consists of genuine work-oriented
exercises.
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Expenses Policy (2013 Edition)
Part 3: Hospitality & Entertainment Policy
3.2. What you cannot claim
4.

Clothing for entertaining, e.g. dress or suit hire, or hire of academic robes for
graduation ceremonies.

When being entertained, overnight accommodation should not be claimed nor
invitations for hospitality accepted if it involves an overnight stay.
Business entertaining
This section deals with what you can claim if you are entertaining anyone who is not a
College staff member. Business entertaining means food, drink or any other form of
hospitality provided to a visitor(s). College staff members may attend these events, but it can
only be classed as business entertaining if the main purpose of the event is to entertain a
visitor(s).
4.1. What you can claim
5.

The most senior person present should pay the bill for any business entertaining
and submit the claim.

Hospitality should be pre-approved by the relevant approver (see part 1 section
15). Where the actual costs exceed the allowances indicated below the claim
must be approved additionally by your Faculty Finance Officer (i.e. not by your
Head of Department or Department Operations Manager alone).

The cost should be appropriate and not exceed £15 per head for breakfast, £25
per head for lunch and £50 per head for dinner including alcohol and service.
Anything above this amount should be met from personal contributions.

A record of the number of attendees and the organisation(s) they represent must
be kept and included with the claim; this includes any College staff members
attending. The name of the main contact form the external organisation should be
given, to allow independent verification if necessary.

Employees who attend a business entertaining event in a support role, e.g.
greeting guests, without participating in the hospitality should not be included in
the numbers attending. Treat any costs arising from their attendance as part of
the cost of the function and claim them as such.

You cannot claim for clothing for entertaining, for example dress or suit hire.
Which analysis code should I use when making a
claim?

Entertainment provided to customers (including students) should be charged to
analysis code 169307.

Entertainment provided solely to College employees should be charged to code
169304. This is needed to enable us to calculate tax liabilities for staff-only
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Expenses Policy (2013 Edition)
Part 3: Hospitality & Entertainment Policy
entertainment. Examples of staff-only taxable entertainment, which should be
charged to code 169304, are:
6.
o
Sandwiches provided at Faculty or departmental staff meetings.
o
Tea/coffee etc. provided at Committee meetings.
o
Retirement dinners where those present are restricted to employees and
their spouses.
o
Head of Departments lunches hosted by the President & Rector.

Costs which are intended to fall within the HMRC concession for annual
hospitality should be charged to code 169305 (see section 3.1.3 above).

No attempt should be made to split costs of individual events between two codes.
The entire costs should be charged to one or the other, according to whether or
not clients (which might include students) were present at the event.

The appropriate analysis codes, indicated above, should be used regardless of
whether the payment is processed via an expense claim, a hospitality journal
from the College’s catering department or an invoice payment to an outside
caterer or restaurant.
Gifts and hospitality: The Bribery Act
Hospitality should neither be given nor received on a scale which might be construed
adversely within the terms of the Bribery Act 2010. Any expenditure which appears to be an
inducement to place a contract can potentially fall into this category.
All staff are obliged to report gifts and hospitality received in excess of £50 to their line
manager, and, if the amount exceeds £250, they must be recorded formally in the College’s
Hospitality Register. Generally speaking, at this level, it is safer to decline the offer of
gift/hospitality altogether (with due courtesy), rather than run the risk of falling foul of legal
sanctions at a later stage. The rules on acceptance of hospitality can be found at:
http://www3.imperial.ac.uk/secretariat/collegegovernance/provisions/policies
7.
Hall warden’s entertainment: use of amenities funds
Additional restrictions on the use of hall of residence amenity accounts are contained in the
Warden’s Manual.
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Imperial College London
Expenses Policy (2013 Edition)
Part 3: Hospitality & Entertainment Policy
Appendix A: Contacts for enquiries
Purchasing,
Accounts Payable &
Expenses Helpdesk
(including travel
booking enquiries)
Tel: +44 (0)20 7594 8593
Make an enquiry: http://www3.imperial.ac.uk/finance/go/ask
Website: http://www3.imperial.ac.uk/finance/go/helpdesk
Tax Manager
(taxation on benefits
in kind,
hospitality, etc.)
Tel: +44 (0)20 7594 3999
Email: [email protected]
Website: http://www3.imperial.ac.uk/finance/go/tax
Level 1 Faculty Building
South Kensington Campus
Level 1 Faculty Building
South Kensington Campus
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