Policies and Procedures

The Royal Victorian Eye and Ear Hospital is using the social media channel Twitter to share information with our followers about news and events around the hospital. All Eye and Ear publications and events promoted via social media will also be made available on our website, as hardcopies, and via other relevant channels as appropriate.

The Eye and Ear follows relevant organisations, companies, and bodies and may re-tweet information provided by these organisations. Information originating with organisations and outlets not currently active on Twitter may also be shared. The Eye and Ear does not automatically follow organisations or individuals who follow us. Being followed by the Eye and Ear does not imply endorsement of any kind.

The Marketing and Communications team manages all Eye and Ear social media accounts and the team will aim to ensure content remains up-to-date and relevant.

The Eye and Ear welcomes feedback and ideas from members of the public and will attempt to respond to comments posted on our Twitter account as quickly as we can. We update and monitor the Twitter account during ordinary business hours Monday to Friday.

With the exception of direct messages exchanged between users, all messages (or ‘tweets’) are public and visible for all to read, comment and share.

Any feedback on a specific service, occurrence or member of staff should be given through the feedback form on the website, so that appropriate procedures can be followed.
Twitter may occasionally be unavailable and we accept no responsibility for lack of service due to Twitter downtime.

The Eye and Ear will not provide health or medical advice using social media.
Patients wishing to contact the Eye and Ear for a change of appointment or other treatment-related queries should contact the Eye and Ear directly, by phone or email. The usual ways of contacting us are detailed in the Contact Us section of the Eye and Ear website.

If a patient or member of staff of the Eye and Ear is referred to directly by name, including links to patient and staff stories on our website or within our publications, this will only occur with the express written permission of the patient (or legal representative of the patient) or staff member in the form of a signed consent document.

Under no circumstances will a patient’s or staff member’s personal details, such as address, date of birth, religious or political affiliations or other details of a private nature, be referred to.

The Eye and Ear does not capture or record the contact details of organisations or individuals following our Twitter account. Any information identified as or deemed confidential or private is treated in accordance with the Eye and Ear Privacy Statement.

The Eye and Ear Twitter account, and any of our other social media sites, are intended to serve as a forum for interaction with members of the public. We ask that you are respectful in your actions and comments when interacting with Twitter or those other social media sites.

Please do not post:

• profanity, abusive language or personal/character attacks
• material that is unlawful, obscene, defamatory, threatening, harassing, abusive, slanderous, hateful or embarrassing to anyone else (and we will exercise our discretion about matters of this type)
• advertisements or business solicitations
• chain letters or spam.

We reserve the right to remove posts we deem offensive or inappropriate, and to terminate involvement by anyone who posts such content.

Views, comments, ideas and opinions expressed by external parties on any social media site of the Eye and Ear, do not necessarily represent the views and opinions of the Eye and Ear.

We cannot be held responsible or liable for the accuracy, currency or reliability of information posted by external parties.

The Eye and Ear does not tolerate improper conduct by its employees and has developed a range of policies and procedures in relation to matters such as bullying and harassment, equal opportunity and consumer feedback.

The Eye and Ear particularly recognises the importance of accountability so it supports those who make disclosures about serious misconduct, corruption and other forms of improper conduct. We will take all reasonable steps to protect people who make those disclosures from any detrimental action or reprisal in accordance with the objectives of the Protected Disclosure Act 2012 (Vic).

For more information about the Eye and Ear’s policy regarding protected disclosures and detrimental action, click here.

The purpose of this procedure is to provide guidance on the individual and organisational accountabilities for responding to offers of gifts, benefits and hospitality. This includes a guide on the recording of gifts, benefits and hospitality and to encourage behaviours that will earn and sustain public trust and reinforce the Victorian public sector values of accountability, impartiality and integrity and the appropriate use of public resources.

This procedure applies to all Royal Victorian Eye and Ear Hospital employees and Board Directors.

The Eye and Ear encourages the individual to determine whether the offer represents an actual, potential or perceived conflict of interest or has a legitimate business benefit to the organisation.

Gifts or benefits to or from a relative, friend or acquaintance outside of the course of official hospital business and which are not an actual or perceived conflict of interest do not fall within the scope of this procedure.

This procedure is based on, and must be read consistently with, the Victorian Public Sector Commission’s minimum accountabilities for gifts, benefits and hospitality. Where this procedure differs, it is intended to be at least as strict as those minimum accountabilities.

Accepting and refusing gifts and hospitality:

All employees must comply with the following minimum requirements.

• Must not solicit gifts, benefits or hospitality.
• Must refuse all offers of gifts, benefits or hospitality that could give rise to an actual or perceived conflict of interest or may adversely bring the organisation of public health sector into disrepute, or are non-token offers without legitimate business benefit.
• Refuse all offers of gifts, benefits or hospitality from people or organisations about whom they are likely to make business decisions involving:
  • Tender process
  • Procurement
  • Enforcement
  • Licensing; or
  • Regulation.
• Must refuse all offers of money, items used in a similar way to money, or items easily converted to money such as shares.
• Refuse bribes or inducements and report inducements and bribery attempts to the Chief Executive Officer and to the Victoria Police or the Independent Broad based Anti-corruption Commission.
• If unsure how to respond to an offer of a gift, seek advice from a manager.
• Prior to accepting an offer the staff member must first consult and gain approval from their manager and complete the Eye and Ear declaration.
• Declare all non-token offers (valued at $50 or more) of gifts, benefits and hospitality (whether accepted or declined) on the declaration form which will be recorded on the organisational register.
• Repeat offers from the same individual or organisation, even if individually token in value, must be refused if their cumulative effect could reasonably be perceived as influencing behaviour or decision making.
• Official gifts or items of cultural, ceremonial, religious or historic significance which are accepted on behalf of the organisation, must be declared regardless of value, and remain the property of the Eye and Ear unless expressly approved otherwise.
• Where prior approval could not reasonably be obtained, employees must seek retrospective approval as soon as practicable and no later than five business days after receipt of the offer.

Providing gifts and hospitality:

• Staff should ensure that any gift or hospitality is provided for a business purpose in that it furthers the conduct of official business or other legitimate organisational goal or policy objective.
• Staff should ensure that any costs incurred are proportionate to the benefits obtained for the Eye and Ear and would be considered reasonable in terms of community expectations.

Providing gifts and hospitality to external guests:

• Modest hospitality in relation to external guests may be provided for the purposes of:
• Receiving guests (for example a visiting delegation from another organisation or hosting a meeting held over lunch time);
• Facilitating relationships between third party organisations that are in the interests of the State (for example, an event where community sector organisations can meet business organisations to establish partnerships);
• Celebrating the opening of an event, exhibition, or launching an initiative.
• When considered appropriate, the giving of a gift for the purposes of making guests feel welcome and provide a reminder of the visit, is acceptable. The gift should normally be symbolic rather than financial in value.

Providing gifts to staff:

The provision of token gifts to staff is permissible as part of:

• Reward and recognition programs or events;
• Celebrating length of service milestones and/or retirements; and
• At the discretion of the Chief Executive Officer or Executive.
• A token, such as a card and/or flowers, may also be sent to family members to acknowledge a staff member’s contribution to the workplace in the event of their death. Doing so can also assist their colleagues with their bereavement.
• Celebrations of events such as birthdays, marriages or the birth of children should not be funded using public monies.

The audit committee reviews the gifts register or the gifts declarations on file to assure the organisation that there is transparent reporting of accepted gifts, benefits and hospitality, and there is no evidence of attempts to improperly influence the decisions or actions taken by its employees.

Bribes: Money or other inducements given or promised to employees to corruptly influence the performance of their role. Bribery of a public official is an offence punishable by a maximum of ten years imprisonment.

Conflicts of interest: occur when an employee’s private interests conflict with their public duty. Employees have a duty to resolve a conflict in the public interest, not their own. This may mean that they decline a gift if this is identified as being in the public interest. There can be situations that entail significant legal risks such as public tender processes. Failure to manage conflicts of interest in these situations can compromise the integrity of the tender and may result in legal action by dissatisfied bidders.

Employees: are the directors, chief executive and all other employees of The Royal Victorian Eye and Ear Hospital.

Conflict of interest:

• Actual – there is a real conflict between an employee’s public duties and private interests.
• Potential- an employee has private interests that could conflict with their public duties. This refers to circumstances where it is foreseeable that a conflict may arise in future and steps should be taken to mitigate that future risk.
• Perceived – the public or third party could form the view that an employee’s private interests could improperly influence their decisions or actions now or in the future.

Gifts: are the free or discounted items and any item that would generally be seen by the public as a gift. These include items of high value (e.g. artwork, jewellery or expensive pens) low value (e.g. a small bunch of flowers) and consumables (e.g. chocolates). Fundraising that is consistent with relevant legislation and government policy is not prohibited under the minimum accountabilities.

Benefits: include the preferential treatment, privileged access, favours or other advantage offered to an individual. They may include invitations to sporting, cultural or social events, access to discounts and loyalty programs and promises of a new job. While their value may sometimes be difficult to quantify in dollars, they may be highly valued by the intended recipient and therefore used to influence their behaviour.

Hospitality: is the friendly reception and entertainment of guests. Hospitality may range from light refreshments at a business meeting to restaurant meals and sponsored travel and accommodation.

Reportable gifts: are those that must be recorded on a gifts declaration form and/or gifts register. At a minimum, reportable gifts include accepted gifts, benefits and hospitality that exceed a nominal value of $50. They could also include gift offers of any value, whether they are accepted or not. The gifts may have been offered to an employee directly or extended to them as a guest of their partner or other close relation.

Gifts Declaration Form: is the form an employee uses to declare reportable gifts. (Appendix 1)

Gifts Register: is to be made available on the organisations’ website and is a register of reportable gifts (Appendix 2 ). It records the date a gift was offered, information about the donor and recipient, the nature of the gift, its estimated value and how it was handled. People and Culture maintains the register which is reviewed by the organisation’s audit committee.

Official business: is work that is consistent with the Hospital’s functions and objectives, and an employee’s role.

Value: is the estimated or actual value of a gift in Australian dollars. It is also the cumulative value of gifts offered by the same individual or organisation within a 12-month period. Significant gifts may warrant independent valuation.

Token offers: is of trivial value and does not create and any conflict of interest. They may include promotional pens and notepads received at a conference, light refreshments at a meeting and/or receiving a box of chocolates after presenting at a conference

Non token offers: Nominal value refers to the monetary value of acceptable token gifts. The nominal value for RVEEH is up to $50. Irrespective of dollar value, a gift offer that could create a reasonable perception that an employee could be influenced must be refused. An example of a non-token offer may include tickets to entertainment events that do not relate to duties at work.

The following principles will apply to the acceptance, rejection, recording and approval of all gifts, benefits and hospitality:

1. The Eye and Ear encourage a culture of ‘thanks is enough’. Employees are encouraged to decline offers of gifts, benefits or hospitality even where acceptance may be permitted under this procedure.
2. Employees must refuse all offers of gifts, benefits or hospitality, irrespective of the value, where it could be reasonably perceived as undermining the integrity and impartiality of the Hospital or themselves.
3. In some circumstances it may be appropriate for employees to accept a token gift, benefit or hospitality of nominal value (up to $50 in value) and it is not required to record the gift or seek approval.
4. In circumstances where it is appropriate to accept an offer, employees may accept a non-token gift, benefit or hospitality over the value of $50 and ensure the offer is recorded on the Gifts/Benefits Declaration Form and is approved by the Chief Executive Officer. In the case of the Chief Executive Officer, approval must be from the Board Chair. Approval must be received before the gift is accepted.
5. An offer may be accepted that is a second or subsequent gift with a combined value over $50 from one gift giver within a 12 month period. This is in circumstances where the offer is recorded on the Gifts/Benefits Declaration Form and is approved by the Chief Executive Officer. In the case of the Chief Executive Officer, approval must be from the Board Chair. Approval must be received before the gift is accepted.
6. Any offers of bribes or money must be declined, recorded on the Gifts/Benefits Declaration Form, reported to the Chief Executive Officer and to the Victoria Police.
7. Employees must report a colleague who tries to solicit a bribe to the Chief Executive Officer.
8. The Eye and Ear will support and protect employees who raise concerns or report suspected breaches of this procedure in good faith. Any form of victimisation will be treated seriously.

Declaration forms should be completed by the relevant employee then submitted to the relevant manager for recommendation and then to the Chief Executive Officer for approval. These steps must be followed before a gift is accepted. All refusals must be recorded using the Gifts/Benefits Declaration Form.

Completed forms are to be emailed to PeopleandCulture@eyeandear.org.au and will be kept on file. The Declaration form is available on the intranet and in appendix 1.

People and Culture will maintain the Gift Register and will provide the Gift Register to the Board Audit Committee annually. The Gift Register displayed internally on the intranet will record the following information:

• Date offered
• Offered to (individual’s name, position, unit/division) – [Name may be de-identified when published on the organisation’s website]
• Description of the gift, benefit or hospitality
• Estimated or actual value
• Cumulative value of offers made by individual/organisation
• Offered by (name of individual/organisation making the offer)
• Reason given by offeror for making the offer
• If accepted would an actual potential or perceived conflict of interest exist; or would it bring the individual, the organisation or the public sector into disrepute?
• Is there a legitimate business benefit to the organisation, public sector or State for accepting the offer
• Decision regarding the offer
• Approvals – if offer accepted, state who approved the individual accepting the offer and decision on ownership (name, position, unit/division of individual’s manager or senior decision-maker who approved acceptance.)

The Gift Register displayed on the external website will cover the previous financial year and be published within four months of each new financial year. It will record the following information:

• Date offered
• Offered to (individual’s position only for public register)
• Description of the gift, benefit or hospitality
• Estimated or actual value
• Offered by (position of person and organisation making the offer)
• Decision regarding the offer
• If accepted, the business reason for doing so.

Employees who breach this procedure, including failure to formally declare a reportable gift, benefit or hospitality as required by this procedure, may face disciplinary action which may include counselling, warning, suspension, transfer, demotion or dismissal.

Gifts, Benefits and Hospitality Policy Framework, Victorian Public Sector Commission, Gifts, benefits and hospitality – VPSC
View the gift register here.

In 2023-2024, there were two consultancies where the total fees payable to the consultants were $10,000 or greater.  The total expenditure incurred during 2023-2024 in relation to these consultancies is $33,750 (excl. GST).  Details of these consultancies can be viewed at www.eyeandear.org.au

Consultant	Purpose	Start date	End date	Total approved project fee (excluding GST)	Expenditure 2022-2023 (excluding GST)	Future expenditure (excluding GST)
Management Consultant	Board planning days.	Sep-23	Nov-23	$ 11,180	$ 11,180	$0
Procurement Consultant	Review of procurement function	May-24	May-24	$ 22,570	$ 22,570	$0