Gifts & Gratuities
Office of Origin: Financial Services
Date Adopted: 08-24-10
Date Reviewed: 01-15-12, 11-20-17, 1/23/18
Last Date Modified & Approved: 11-20-17, 1/23/18
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.
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.
- 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.
- Initial Response– 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.
- Value Limitations – Non-monetary gifts valued at $25 or less may be accepted without disclosure, subject to the remaining guidelines.
- 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.
- Disclosure Process – Any College employee must fully disclose receipt of any non-monetary gift valued at more than $25 in writing via the Gift Disclosure Form. This form should be submitted to the employee’s supervisor or the appropriate Cabinet member 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 supervisor or Cabinet member must acknowledge in writing the disclosure and identify recommended disposition.
- Acceptable Gifts – Certain gifts are considered acceptable due to their nature, such as:
- Calendars, desk novelties, or similar marketing 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 or 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. Disclosure guidelines must be followed when accepting any gift cards or gift certificates for department use.
- Perishable gifts such as fruit baskets or flower arrangements that cannot easily be returned should be shared or distributed among department employees.
- Event tickets, golf outing invitations, or convention and seminar admission fees provided such are rotated among department or College employees.
- Participation in Sponsored Activities – College employees who participate in vendor sponsored events or activities during the regular work day must have the supervisor approval. Such participation may require the time away be charged as vacation leave.
- Dollar Value Threshold – The Director of Finance will periodically review the dollar value threshold in this policy and revise such in accordance with Internal Revenue Service limits on business gift deductions.
Responsibility: Chief Financial Officer
References: Internal Revenue Service Publication 463, Travel, Entertainment, Gift, and Car Expenses