Office of Origin: Finance
Responsibility: Chief Financial Officer
Original Date Adopted: 8/24/10            
Dates Reviewed: 1/15/12, 11/20/17, 1/23/18, 7/28/21, 1/21/26 (C) 
Last Date Board Approved: 9/21/21

This policy establishes direction for acceptance of gifts, gratuities, and honoraria that might arise during 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 entities but rather to ensure that College interests are not compromised by establishing expectations for ethical business practices, including avoidance of actual or appearance of conflicts of interest, and to provide direction for disclosing offers and receipt of gifts and gratuities.

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. It is essential to both the College that all decisions and actions regarding purchasing are based upon proper business considerations and not influenced in any way by personal obligations. 

As a basic condition of employment, employees have a duty to act in the College's best interest in business relationships related to their employment. This duty means that employees must not engage in any business practice that will interfere with their College obligations, damage the College's reputation, compromise the independence of College business activities, or reasonably be seen as doing so. 

Policy
In general, acceptance of any gift or gratuity by employees from an outside entity is prohibited; this includes merchandise, cash, services, entertainment, and other courtesies. However, insignificant non-monetary gifts (defined below) may be accepted in the interest of maintaining positive business relationships, subject to compliance with the requirements below.

Except for fund-raising activities where gift solicitation has been formally approved, employees are strictly forbidden from soliciting gifts of any type or value for themselves, their family, friends, or favorite organizations.

Requirements
1.    Acceptance of monetary or near-money items such as cash, gift cards, gift certificates, business credits, tokens, and other cash substitutes is strictly prohibited unless used for work supplies, equipment or for a meal for College employees (e.g., gift card for pizza). Disclosure must be made when accepting such as noted below. 
2.    Insignificant non-monetary gifts are those valued at $25 or less, which may be accepted without disclosure. Examples include:

• Calendars, novelties, mugs, t-shirts, hats, or similar marketing items 
• Reasonably priced meals in settings where College business is conducted
• Books, media, software, or similar work-related items 
• Perishable gifts such as candy, fruit baskets, or flower arrangements. When received, these should be shared with or distributed among employees. 
• Event tickets, golf outing invitations, convention and seminar admission fees, and similar items if rotated among department or other employees. Employees who participate in vendor-sponsored events or activities during the employee’s regular workday must have supervisor approval. Participation may require the time away be charged as vacation leave.

Upon offer or receipt of any gift (other than as noted above), the employee should attempt to either not accept or to return the item to the provider, reminding provider that College policy discouraging receipt and acceptance of gifts.

Disclosure Process
Employees must fully disclose receipt of any gift (other than as noted above) in writing to their supervisor or the supervising Cabinet member as soon as possible after receipt of gift. Disclosure should include details such as name of provider, item description, and estimated value. The supervisor or Cabinet member must acknowledge in writing the disclosure and identify recommended disposition. 

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