Office of Origin: Financial Services
Date Adopted: 08-24-10
Date Reviewed: 01-15-12
Last Date Modified & Approved: 01-15-12
The purpose of this policy is to establish guidelines for acceptance of gifts, gratuities, and honoraria that might arise in the course of Lake Michigan College (the College) employee relationships with vendors, consultants, contractors, and others providing goods and services to the College.
This policy does not seek to unreasonably restrict or interfere with maintaining good relationships with such outside entities but rather seeks to establish guidelines for ethical business practices and provide direction for disclosing offers and receipt of such items and to ensure that College interests are not compromised.
College employees are expected to conduct all business according to the highest legal and ethical standards. For protection of the College as well as the employee, employees must maintain a high degree of integrity in dealing with all past, current, and potential vendors providing goods and services to the College.
As a basic condition of employment, all College employees have a duty to act in the College's best interest in connection with business relationships arising from or related to their employment at the College. This duty means that employees must not engage in any business practice that will interfere with their obligations to the College, damage the College's reputation, compromise the independence of College business activities, or reasonably be seen as doing so.
In general, acceptance of any gift or gratuity by College employees from outside entities is prohibited. This includes merchandise, cash, services, entertainment, and other courtesies. It is essential to both the College and suppliers that all decisions and actions regarding purchasing are based upon proper business considerations and not influenced in any way by personal obligations.
However, insignificant non-monetary gifts may be accepted in the interest of maintaining positive business relationships with vendors, consultants, and contractors, subject to compliance with the guidelines below.
1. Prohibited Staff – Purchasing staff and any other staff member whose primary function is to oversee solicitation and selection of vendors to provide goods and services to the College are strictly prohibited from accepting any gift or gratuity, regardless of value.
2. Initial Response to Gift Receipt – Upon offer or receipt of any gift, each College employee should attempt to either not accept or to return the item to the donor, reminding donor of the College policy discouraging receipt and acceptance of gifts.
3. Value Limitations – Non-monetary gifts valued at $25 or less may be accepted without disclosure, subject to the remaining guidelines.
4. Monetary Gifts – Acceptance of monetary or near-money items such as cash, gift cards, gift certificates, business credits, tokens, and other cash substitutes is strictly prohibited other than as discussed below.
5. Disclosure Process – Any College employee must fully disclose receipt of any nonmonetary gift valued at more than $25.
6. Disclosure Method – All disclosures required by this policy must be in writing via the Gift Disclosure Form. This form should be submitted to the employee’s supervisory head or the appropriate College vice-president as soon as possible after offer or receipt of gift. Disclosure should include details such as name of donor, item description, and estimated value. The supervisory head or College vice-president must acknowledge in writing the disclosure and identify recommended disposition.
7. Gift Sharing – Perishable gifts such as fruit baskets or flower arrangements that cannot easily be returned should be shared or distributed among department employees. Other gifts that are approved for acceptance such as event tickets, golf outing invitations, or convention and seminar admission fees should be rotated among department employees.
8. Gift Solicitation – Except for fund-raising activities where gift solicitation has been formally approved, College employees are strictly forbidden from soliciting gifts of any type or value for themselves, their family, friends, or favorite organizations.
9. Acceptable Gifts – Certain gifts are considered acceptable due to their nature, including but are not limited to:
• Calendars, desk novelties, or similar advertising items valued at less than $25
• Reasonably priced meals accepted in settings where College business is conducted
• Books, media, software, or similar work-related items for which there is not charge
• Gift cards and gift certificates that will be used by receiver’s department for supplies, equipment or for a department meal (e.g., gift card for pizza) may be accepted provided department head approves in writing. Disclosure guidelines must be followed when accepting any gift cards or gift certificates for department use.
10. Exceptions – Exceptions to this policy include the College President, any employee working on behalf of the Lake Michigan College Foundation, or other College employee whose primary function includes fundraising or public relations. Except for the College President, receipt of gifts or benefits valued in excess of $25 requires disclosure. Any other exceptions to this policy should first be reviewed by the Director of Purchasing & Support Services who, together with the appropriate Vice President or Department Head, will determine if special circumstances exist to warrant the acceptance of a gift from a vendor or if a gift should be declined or returned. The Board of Trustees shall be kept informed of such decisions.
11. Participation in Sponsored Activities – Any College employee who participates in vendor sponsored events or activities during the regular work day must have the approval of the appropriate administrative supervisor. Such participation may require the time away be charged as vacation leave.
12. Dollar Value Threshold – The Director of Financial Services will review the dollar value threshold outlined in this policy annually and revise such in accordance with IRS limits on business gift deductions.
Responsibility: Vice President, Financial Services