Part 9: Other types of expenditure

Controlling sensitive expenditure: Guide for public organisations.


A donation is a payment (in money, goods, or services) made voluntarily and without expecting reciprocation.

We expect public organisations to ensure that:

  • the purpose of the donation is consistent with the business purpose of the organisation; and
  • the cost of the donation is appropriate in the circumstances.

The principles of preserving impartiality, integrity, and being moderate and conservative are particularly relevant here. Making a donation should not result in any obligation on individuals or organisations, other than to apply the donation to the purposes of the recipient.

We expect donations to be:

  • lawful in all respects, including complying with parliamentary appropriations;
  • disclosed in aggregate (where required);
  • appropriately documented;
  • made to a recognised organisation by normal commercial means – not to an individual and not in cash;
  • non-political;
  • covered by a clear policy including delegations and authorisation; and
  • consistent with the objectives of the organisation making the payment.


Giving gifts

Public organisations can give gifts – such as a thank you for a speech or presentation, or when giving gifts is customary (for koha, refer to the additional guidance below).

Gifts usually take the form of a tangible object, but might also be in the form of, for example, free use of a corporate box at a sporting event or privileged access to goods or services.

Giving gifts presents significant risks, including that:

  • the value or nature of a gift is inappropriate or excessive to the occasion or the reason for giving it;
  • the gift is given in explicit or implicit expectation of favour in return; and
  • the gift is given in substitution for legitimate payment or remuneration.

The principles of a justifiable business purpose, being moderate and conservative, acting with integrity, and preserving impartiality are particularly relevant here.

Public organisations should have a policy on giving gifts, including specifying the purposes and occasions for when it is acceptable and the nature and value of gifts that are appropriate for particular occasions. An organisation might consider factors such as the staff member's service, the event the organisation is recognising, and the cost of the gift. See Part 6 for guidance on recognising achievements.

Receiving gifts

We recognise that receiving a gift is not strictly sensitive expenditure. This is because it does not involve expenditure on the part of the organisation or individual receiving a gift. However, it is still a sensitive issue that organisations need to manage carefully. It is important that receiving a gift does not affect an organisation's or an individual's decision-making because this could be perceived as acting without impartiality or integrity.16 Prizes received from a free competition entry obtained while carrying out an organisation's business are also considered to be receiving a gift for the purposes of this guide.

Cash gifts are unacceptable in any circumstances.

We expect public organisations to:

  • carefully consider whether it is appropriate for the organisation to accept a gift;
  • record the acceptance of all gifts, except for inexpensive gifts that are openly distributed by suppliers and clients, in a gifts register;
  • treat all gifts that are accepted as the property of the organisation, to be used for either the organisation's or the public's direct benefit;
  • consider recording in the gift register those gifts that were offered but turned down;
  • limit the gifts that staff are allowed to personally acquire to infrequent, inexpensive gifts that are openly distributed by suppliers and clients (for example, pens, badges, and calendars); and
  • have policies defining "infrequent" and "inexpensive" in relation to receiving gifts.


Koha is a gift, token, or contribution given on appropriate occasions including:

  • tangihanga;
  • attendance at an event/meeting;
  • for use on or for a marae; and
  • kaumātua support for pōwhiri, mihi whakatau meetings, or other events.

The probity issue associated with koha is that it is discretionary and usually un-receipted expenditure.

Public organisations should have a policy on, and controls over, giving koha that specifies the means of determining the cost of any koha, and requires all koha made to:

  • reflect the occasion;
  • be approved in advance at an appropriate level of authority; and
  • be clearly documented with the date, amount, description, and purpose.

Information communications technology resources

Information communications technology (ICT) resources17 are widely used in the workplace and some level of personal use of this technology is reasonable.

We expect organisations to have policies on personal use of ICT resources, including on reimbursement of costs, and to ensure that staff are well informed about them. We suggest that ICT personal use policies state that personal use of the organisation's ICT resources should be consistent with the organisation's values and policies and that usage must not:

  • include unlawful, offensive, or improper activities;
  • affect the business use of the ICT;
  • affect how people perform their duties;
  • be commercial in nature;
  • involve unreasonable use of resources (such as network bandwidth); and
  • include installation of communications technology to be used exclusively or predominantly for personal use.

See guidance on private use of a public organisation's assets, and an organisation's use of private assets, in Part 7.

16: Office of the Auditor-General (2020), Managing conflicts of interest: A guide for the public sector, Wellington.

17: ICT resources include email and web browsing on a desktop or laptop computer, a smartphone, or a tablet.