To avoid a conflict of interest or the appearance of a conflict of interest, at no time should a University employee solicit personal gifts from current or potential vendors, contractors or their agents, local businesses, University Departments, or others with whom there is a potential or ongoing business or professional relationship.
All employees are responsible for becoming familiar with and adhering to this policy. Supervisors are responsible for ensuring that this policy is known by their employees and that all employees are following it.
Employees may accept ordinary business courtesies, such as routinely-distributed advertising novelties of insignificant value, or payment for a modest meal or event Bona Fide. If the value of the gift is undetermined, it should be returned.
Any gift that is not an advertising novelty should be reported to the employee’s supervisor. Gratuities or gifts of money to the employee, including gift certificates, cannot be accepted at any time and should be returned immediately to the donor.
In the decision as to whether or not to accept any gift, employees should use proper business judgment and avoid in all cases any actual conflict of interest or the appearance of any conflict.
If unsure whether accepting a gift would be appropriate, employees should ask themselves the following questions:
- Is this gift related to a business purpose?
- Would I feel embarrassed if anyone from work or in my family knew I accepted such a gift?
- Would I feel beholden to the vendor who gave me the gift?
- How would I feel if someone else I worked with accepted such a gift from a vendor?
For example, University officials are often offered goodwill gifts when on a mission abroad, visiting other domestic institutions, or when officials from other institutions visit Lesley University.
Because a refusal of a gift could offend the hosting officials, such gifts may be accepted. If the gifts are of significant value (i.e. greater than $100, consistent with IRS policy), they become the property of the University and should be discussed with the head of the department.
Employees are encouraged to discuss proposed gifts with their supervisors or the General Counsel if they are unsure of the appropriateness of the gift in question.