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Gift Policy

Policy Name: Gift Policy
Effective Date: September 2014
Office with Primary Responsibility: Procurement Services
Offices with Secondary Responsibility: Controller's Office

Policy Summary

This policy will provide guidance to employees on what is ethical when receiving gifts from outside organizations, vendors and individuals.

Reason for Policy

Dartmouth College strives to maintain the highest standards of ethical conduct in its dealings with its business associates, including vendors and potential vendors, customers and business partners. Acceptance of gifts may create conflicts of interest and has the potential to influence decisions.   College employees, and their immediate family members, are prohibited from receiving gifts from outside organizations, vendors or individuals, with the few exceptions that are noted below.

Scope: Who should know this policy?

  • Any employee representing the College in their business operations.
  • Any individual that has a supervisory role at the College.

Policy Statement

This policy is a guide for employees representing the College in business operations. Employees are expected to uphold the integrity of the institution while conducting business with outside organizations, vendors and individuals. All employees are expected not to compromise any business transaction, even in appearance, in exchange for personal benefit such as gifts.

Federal regulations, which govern procurement under contracts and grants, impose a like prohibition mandated by Public Law 99-634, known as the "Anti-Kickback Enforcement Act of 1986." "Kickback" is defined as any money, fee, commission, credit, gift, gratuity, thing of value, or compensation of any kind that is provided by a supplier, directly or indirectly, to any employee for the purpose of improperly obtaining or rewarding favorable treatment in connection with procurement under a federal contract or grant.

Exclusions / Exceptions

Promotional items of insignificant value, of an advertising nature, an occasional business meeting meal, or other items of small value may be accepted. Gifts outside of these guidelines would be deemed unacceptable and shall be declined, or returned if already accepted.

College employees can accept the following:

  • A plaque or an award.
  • Items of insignificant value that are given to everyone (such as key chains, T-shirts, coffee mugs, pens, bags).
  • Information materials that are provided by vendors to everyone (such as booklets, audio or video tapes).
  • Non-cash raffle prizes or drawings at a conference or similar event where the employee is representing the College. (Any cash prize must be used to offset the expenses associated with the event/conference.)
  • An occasional business meal. Repetitive mealtime meetings should be discouraged. Meals associated with pure entertainment, where College business in not being discussed, are not considered business meals.
  • Plants, food or holiday gift baskets may be accepted if shared with other departmental staff.
  • Travel paid at a vendor's expense, with prior approval from the department head, when associated with speaking at a conference or viewing a potential vendor's site.

It is permissible to accept meals and lodging, and participate in social events, at conferences conducted by Dartmouth business associates.

An employee should consult with his/her supervisor if there is uncertainty of the appropriateness of accepting a gift. Dartmouth staff should be mindful that the acceptance of a gift may create an appearance of a conflict of interest and this appearance should also be weighed in the decision as to whether to accept a gift.

Definitions

Gift – A tangible or intangible item of any value given to a College employee, directly or indirectly, from an external source. Gifts can be in the form of cash, gift certificates, tickets to sporting events, etc.

Immediate Family Members – An employee's spouse or domestic partner, children or children of spouse or domestic partner, siblings or siblings of spouse or domestic partner, parents or parents of spouse or domestic partner, or any person living in the same household.

Related Information

You can also refer to the "Code of Ethical Business Conduct" at http://www.dartmouth.edu/~rmi/codeofethicalbusinessconduct.pdf

Ramifications if policy is breached

All employees are responsible for becoming familiar with and adhering to this policy. Supervisors are also responsible for ensuring that this policy is known by their direct reports and that all employees are following it. If this policy is breached, it should be brought to the attention of one of the departments within the Contacts/Responsibilities section of this policy or by going to the Dartmouth Compliance and Ethics Hotline http://www.dartmouth.edu/~rmi/.

Contacts / Responsibilities

Risk and Internal Controls Services
Phone: 603-646-2441
Risk.Management@Dartmouth.edu
http://www.dartmouth.edu/~rmi/ 

Procurement Services
Phone: 603-646-2811
Procurement.Services@Dartmouth.edu
http://www.dartmouth.edu/~control/departments/procurement/ 

Controller's Office
Phone: 603-646-3011
Controllers.Office@Dartmouth.edu
http://www.dartmouth.edu/~control/ 

General Counsel
Phone: 603-646-2444
Office.of.General.Counsel@Dartmouth.edu
http://www.dartmouth.edu/~legal/

Human Resources
Phone: 603-646-3411
Human.Resources@Dartmouth.edu
http://www.dartmouth.edu/~hrs/

Last Updated: 9/9/14