SENSITIVE EXPENDITURE POLICY - March 2019 | Version 1 - NZ Transport Agency

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SENSITIVE EXPENDITURE POLICY - March 2019 | Version 1 - NZ Transport Agency
SENSITIVE EXPENDITURE
POLICY
March 2019 | Version 1

Policy name: Sensitive expenditure policy
Date of issue: March 2019
Next review: March 2021
Policy owner General Manager Investment & Finance
Policy sponsor: General Manager Investment & Finance
Document management plan
Signed off by policy owner                   General Manager Investment & Finance, 20 November 2018

Signed off by policy sponsor                 General Manager Investment & Finance, 20 November 2018

Signed off by Board                          18 March 2019

Policy lifecycle                             This policy is to be reviewed every two years

Keywords
Travel, life events, mobile phones, gifts, training, entertainment, expenses, farewells, sensitive expenditure,
welfare, memberships, benefit, purchasing, credit card, finance, rewards, functions

Change record

Version       Description of change                                         Date          Updated by

                                                                                          Penny Johnson and
0.1           Initial draft                                                 25/09/2018
                                                                                          Helen Rickerby

                                                                                          Stephen Moore and
0.2           Final draft for SLT                                           7/11/2018
                                                                                          Lizette Marais

0.3           Updates from SLT                                              20/11/2018    Helen Rickerby

0.4           Reviewed by Transport Agency Board                            19/12/2018    Helen Rickerby

0.5           Updated to reflect Board comments                             24/01/2019    Stephen Moore

0.6           Small amendments based on Board feedback                      19/03/2019    Helen Rickerby

1             Published                                                     2/4/2019      Helen Rickerby

Policy name: Sensitive expenditure policy                                                                         2 of 8
Date of issue: March 2019
Purpose
This policy sets out the rules and responsibilities for staff when spending public money on sensitive business-
related expenses. The policy exists to ensure that spending is fair and equitable and ensure the NZ Transport
Agency is a responsible user of public money.

Scope
This policy applies to all Transport Agency employees, including permanent staff members (full-time and part-time),
temporary staff and contractors directly employed by the Transport Agency, irrespective of where they are working.
Items of sensitive expenditure that are specifically provided for by employment agreements are not covered by this
policy.

Definition of terms
Sensitive expenditure is discretionary expenditure by a public entity that provides, has the potential to provide, or
could be perceived as providing a private benefit to an individual staff member of a public entity that is additional to
the business benefit to the entity of the expenditure. It also includes expenditure by a public entity that could be
considered unusual for the entity’s purpose and/or functions.
One-up principle in financial delegations means that delegation holders cannot approve transactions involving
themselves or from which they could be seen to benefit, instead they must be approved by their one-up manager.

Key principles
Any spending must be consistent with the accountability and responsibility standards that the public expects of
public servants using taxpayer money, and be able to withstand scrutiny by the public and Parliament.

All sensitive expenditure decisions must follow these principles:

   • Expenditure must be clearly linked to the Transport Agency’s role and functions, and have a justifiable
     business purpose.
   • When undertaking Transport Agency business, employees should be neither advantaged nor disadvantaged
     by this policy (neither better nor worse off).
   • Expenditure must be moderate and conservative in the circumstances.
   • Decisions related to expenditure must be transparent and impartial.
   • The expenditure must be both actually, and perceived to be, appropriate (taking into account both the
     individual transaction and the total amount of sensitive expenditure in that area).
   • Expenditure must be properly authorised, clearly identifiable and accurately recorded in the Transport
     Agency’s financial systems.

Types of sensitive expenditure
The following areas are considered to be potential areas of sensitive expenditure and are covered by this policy:
   •   catering for meetings
   •   hospitality and entertainment
   •   farewells and retirements
   •   personal use of work mobile phones
   •   gifts for staff life events such as a bereavement
   •   work-related travel expenses, including meals, transportation and accommodation
   •   staff recognition and rewards
   •   purchase of prizes and incentives for customers, such as incentives for taking part in research projects
   •   functions and Christmas parties
   •   corporate clothing
   •   professional memberships, registrations fees and subscriptions

Policy name: Sensitive expenditure policy                                                                          3 of 8
Date of issue: March 2019
•   wellbeing benefits
   •   sponsorship of staff sports teams
   •   loyalty and rewards schemes benefits
   •   private use of Transport Agency suppliers
   •   any other expenditure that could be seen to benefit an individual staff member.

Key accountabilities and responsibilities
Failure to comply with this policy, may result in disciplinary action.

Staff responsibilities
Staff must ensure that:
   • when deciding to spend money on any of these areas they:
      o follow the key principles above when deciding if expenditure is appropriate
      o consult any other relevant policies and the Sensitive expenditure guidelines below to inform their
         decision-making
      o have expenditure approved by their one-up manager
      o obtain approval for significant expenditure before it occurs
      o ensure that any external function or entertainment expenses are incurred by the most senior employee
         present, to preserve the one-up principle
   • all sensitive expenditure is correctly coded and appropriate supporting documentation, such as invoices, are
     retained and submitted to support approvals
   • all sensitive expenditure claims are made promptly, including complying with the regular cycle for credit card
     approvals.

Budget/financial delegations holders
Managers must ensure that:
   • all approved expenditure follows the one-up principle
   • before they approve any expenditure, they are satisfied that there is a justified business purpose and that the
     standards, principles and requirements in this policy and any other relevant policy are met
   • there is appropriate budget and they have delegated authority to approve it
   • the correct expenditure coding is used
   • all supporting documents are filed
   • explanations are documented for any expenditure that could appear unusual.

Claims and documentation
Claims relating to sensitive expenditure need to:
   • clearly state the business purpose of the expenditure – in instances where the business purpose is not clear
     further clarification may be requested
   • be accompanied by adequate original supporting documentation, such as tax invoices or other validating
     documentation – credit card statements or EFTPOS slips do not constitute adequate documentation for
     reimbursement
   • document the date, amount, description, and purpose of minor expenditure when receipts are unavailable
     (for example, for tips or purchases from vending machines)
   • be correctly coded
   • be submitted promptly after the expenditure is incurred.

Monitoring and reporting
   • Budget holders use monthly profit centre reporting to monitor activity in their areas of responsibility.
   • The Transport Agency uses data analytics to identify transactions that may not comply with policy. The Risk
     and Assurance or Financial Processing teams follow up these transactions with individuals and their
     managers throughout the year.
   • The Chief Financial Officer will prepare regular sensitive expenditure reports for review by the Executive
     Leadership team (ELT), with data split by type of sensitive expenditure between business groups.

Policy name: Sensitive expenditure policy                                                                     4 of 8
Date of issue: March 2019
• Risk and Assurance will conduct an annual review of sensitive expenditure. This identifies whether the
     Transport Agency has effective oversight and controls over expenditure that is sensitive in nature, in order to
     demonstrate honesty and financial prudence.
   • A review of sensitive expenditure will also form part of the Transport Agency’s annual external audit
   • A summary of sensitive expenditure incurred by the Executive will be provided quarterly to the Audit and Risk
     Assurance (ARA) Committee of the Board.

Sensitive expenditure guidelines
These guidelines are to help you make decisions related to sensitive expenditure. Where there is an amount
specified, it should be seen as a maximum rather than a target. All dollar amounts include GST.
As part of our responsibilities as a government entity, all expenditure must be seen to be cost effective, and
justifiable.
All expenses must be approved by the relevant manager.
                                • Catering is normally only provided for meetings with external participants who
Catering for meetings
                                  are official representatives of their organisations. However, there may be
                                  times when it is appropriate and more cost- and/or time-effective to provide
                                  food for meetings or training days where only Transport Agency staff are
                                  present, such as when the meeting is longer than three hours or spans a
                                  meal time.
                                • Where catering is provided, it must have prior approval from the relevant
                                  manager.
                                • Costs should be reasonable – generally no more than $17 per head for lunch
                                  and $9 per head for morning and afternoon tea.
                                • Transport Agency funds are not to be used for the purchase of alcohol.
                                • If you are required to wear corporate clothing and/or personal protective
Corporate clothing
                                  equipment as part of your role, that will be paid for in full by the Transport
                                  Agency.
                                • All other employees are entitled to an annual subsidy of up to $50 for
                                  Transport Agency-branded corporate clothing from within their team’s budget.
                                • If you leave the Transport Agency, any clothing or equipment purchased for
                                  you because it was required for your role should be returned to your
                                  manager.
                                • A Senior Manager may approve funding for corporate clothing over and
                                  above your annual subsidy if it supports you in your business function.
                                • Business units may provide a modest morning or afternoon tea for a
Farewells and
                                  colleague who is leaving (excluding contractors or other short-term staff) to
retirements
                                  recognise their valued contribution. Staff from other units may be invited as
                                  appropriate. The cost should be no more than $9 per person.
                                • Gifts are to be paid for by a collection, rather than by Transport Agency
                                  funds.
                                • For people who are leaving after a long career of 15+ years at the Transport
                                  Agency or in the predecessor organisations, additional funding for a function
                                  and a contribution towards a gift may be appropriate. This must be approved
                                  by a General Manager. Any contribution must be less than $150.
                                • Transport Agency funds are not to be used for the purchase of alcohol.
                                • The Transport Agency will subsidise each staff member to attend one social
Functions and events
                                  club Christmas party.
                                • Other team events, including Christmas lunches, should be self-funded, not
                                  paid for by the Transport Agency.
                                • Team Christmas lunches, if during work time, should be no longer than two
                                  hours.
                                • If alcohol is consumed during the working day, employees should not return
                                  to work and any additional time should be made up or taken as annual leave.
                                • It may be appropriate to recognise staff at key life events such as a
Gifts for life events and
                                  bereavement or the birth of a first child. Managers may approve expenditure
staff welfare
                                  for small gifts such as flowers, up to $70.

Policy name: Sensitive expenditure policy                                                                        5 of 8
Date of issue: March 2019
• It must be coded as ‘Fringe benefit taxable activity’ to ensure fringe benefit
                                 tax is managed correctly.
                               • When hosting guests or having meetings off-site with people who are official
Hospitality and
                                 representatives of their organisations, there may be times when it is
entertainment
                                 appropriate for Transport Agency staff to pay for food or drink.
                               • Costs should be reasonable - generally no more than $15 per head.
                               • For avoidance of doubt, ‘coffee meetings’ will only be reimbursed for a
                                 legitimate business reason for hosting an external guest offsite.
                               • Alcoholic drinks must not be charged to the Transport Agency without prior
                                 approval from the Chief Executive, and only in circumstances where the
                                 Transport Agency has approved hospitality for external stakeholders.
                               • Personal use of a work mobile phone is allowable, however if personal use
Personal use of work
                                 results in additional cost to the Transport Agency, the device user and cost
mobile phones
                                 centre managers will be notified to discuss usage and arrange
                                 reimbursement.
                               • The Transport Agency’s mobile phone plans allow for unlimited phone calls
                                 and texts to New Zealand and Australian numbers
                               • Exception reports will be run to monitor mobile phone data usage and if
                                 anomalies are found, the device user and cost centre managers will be
                                 notified.
                               • Work mobiles should not be used to make personal international phone calls
                                 (other than to Australia), to make donations, to pay for parking using text to
                                 park, or for personal use of premium text message services that incur
                                 charges.
                               • If you are travelling overseas you must familiarise yourself with the roaming
                                 options that are available before you travel – these differ between providers
                                 and the country or countries you are visiting.
                               • Individual professional memberships, registrations and subscriptions may be
Professional
                                 paid for by the Transport Agency where it is required by or clearly relevant to
memberships,
                                 the staff member’s duties. Only one professional membership will be covered
registration fees and            by the Transport Agency.
subscriptions
                               • On some occasions it may be appropriate for managers to give their staff
Rewards and
                                 some kind of tangible recognition for good work done.
recognition
                               • The amount spent should be appropriate to the occasion, and should not
                                 exceed $50 per individual.
                               • These rewards must be coded as ‘Fringe benefit taxable activity’ to ensure
                                 fringe benefit tax is managed correctly.
                               • The Wellbeing Fund supports initiatives that focus on health and wellbeing in
Sponsorship of staff
                                 local areas, such as sports teams. Applications are decided by the Health,
teams and other
                                 Safety and Wellbeing Committee in each region.
wellbeing initiatives
                               • You are generally prohibited from purchasing goods and services from
Use of Transport
                                 Transport Agency suppliers at preferential rates, unless explicit staff
Agency suppliers
                                 discounts have been negotiated.
                               • You must not use the Transport Agency as a source of credit, except as part
                                 of an approved scheme.
                               • You must not use purchasing privileges on behalf of any non-Transport
                                 Agency person, e.g. family members or friends.
                               • Any points or benefits from loyalty and rewards schemes gained from
                                 purchasing goods or services on Transport Agency business belong to the
                                 Transport Agency.

Policy name: Sensitive expenditure policy                                                                    6 of 8
Date of issue: March 2019
Work-related travel        Meals while travelling within New Zealand
expenditure
                               • When travelling for work requires an extended working day (eg more than 10
                                 hours) it may be appropriate for the Transport Agency to pay for the
                                 reasonable costs for any meals and refreshments required. Travellers should
                                 normally restrict daily expenditure to:
                                   o   up to $25 for breakfast
                                   o   up to $20 for lunch
                                   o   up to $50 for dinner.
                               • Any alcoholic drinks must be paid for by the traveller, and are not to be
                                 charged to the Transport Agency.
                           Accommodation within New Zealand
                               • All travel and accommodation should be booked as far in advance as
                                 practicable and through a Transport Agency travel coordinator to ensure we
                                 get the best rates.
                               • Within New Zealand a general guide for acceptable rates are:
                                   o   $220 per night for Auckland, Wellington, Christchurch, Dunedin,
                                       Queenstown, Rotorua and Tauranga
                                   o   $180 per night for
                                   o   all other locations.
                           Travelling overseas
                               • For overseas travel we use the Ministry of Foreign Affairs and Trade per diem
                                 rates as a guide to the acceptable maximum daily cost of accommodation,
                                 meals and other costs. The rates can be found on the Ministry of Foreign
                                 Affairs and Trade website.
                           In-room entertainment and mini bars
                               • In-room entertainment such as videos and DVDs and items purchased from
                                 mini bars are considered personal expenditure and must not be charged to
                                 the Transport Agency, and will not be reimbursed.
                           Frequent flyers programmes
                               • Membership of programmes that provide access to airline lounges and other
                                 benefits, such as the Koru Club, is available to frequent travellers (more than
                                 15 return trips each year) whose travel is for genuine business reasons.
                                 Membership is at your General Manager or the Chief Executive’s discretion.
                               • All air points, such as Airpoints dollars, accumulated as a result of business
                                 travel remain the property of the Transport Agency
                               • For practical reasons, status points gained through business travel may be
                                 retained by the individual and contribute to an individual’s frequent flyer
                                 membership tier
                           Taxis and app-based small passenger services
                               • Taxis and app-based small passenger services may be used when
                                  necessary for work-related travel, provided it is cost-effective and efficient,
                                  relative to the other forms of transport.
                           See the Travelling for work policy, for more information, including guidance on air
                           travel and rental cars.

Policy name: Sensitive expenditure policy                                                                       7 of 8
Date of issue: March 2019
• The purchase of prizes or incentives may be appropriate to acknowledge a
Prizes and incentives
                                  customer or citizen’s time commitment and effort in assisting with Transport
for research
                                  Agency research, eg behavioural surveys.
participants
                                • The prize or incentive should take into account the type of research, the time
                                  commitment required, the level of involvement, whether any expenses have
                                  been incurred.
                                • The following examples should be used to determine an appropriate
                                  incentive:
                                • 5–10 minute interview with a passer-by in the street – chocolate bar or coffee
                                  voucher
                                • taking part in an online survey or online customer panel – entry to a prize
                                  draw up to win a debit card or voucher, up to $150 in value
                                • taking part in an interview, focus group or workshop – debit card or voucher
                                  to the value of $25 per 30 minutes, to a maximum of $250 per day.
                             Incentives or prizes in excess of this guidance must be pre-approved by the
                             sponsoring General Manager.

Further guidance
Related policies or guidance:
   •   Code of conduct
   •   Travelling for work policy
   •   Koha and payments for advice and cultural services policy
   •   Corporate credit card policy
   •   Significance policy
   •   Receiving gifts and hospitality policy

Relevant legislation and regulations
   • State sector code of conduct

Contact
For further information about this policy, please email finance@nzta.govt.nz.

Policy name: Sensitive expenditure policy                                                                    8 of 8
Date of issue: March 2019
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