Gifting Guidelines for 绿奴天花板 Employees

[December 2022] As we are nearing the holidays, in this inaugural "Compliance Chat" Mary Gower is joined by Andrew Harrington to discuss gifting compliance guidelines. They address four scenarios about employees receiving gifts and the best way to handle each situation.

Scenario one: (00:22)

A software vendor is taking their top university clients out for an expensive dinner. How should one proceed?

You should politely decline the invitation, or if you decide to go, you should insist on paying for your own $100 dinner rather than accepting the gift. As university employees we're not allowed to accept or receive gifts under circumstances in which it would reasonably be inferred that the gift is intended to influence our professional actions, or decisions, or judgment.

Scenario two: (01:28)

An employee at convocation wins  a university sweatshirt. What do they need to do?

As long as it was somebody from the university who was tossing out the sweatshirts, you're fine keeping the sweatshirt, and you don't have to report that as a gift. Anything that you get from our employer is not a gift. The Executive Branch Ethics Act focuses on gifts from third parties intended to influence our actions or judgment.

NOTE: While gifts from 绿奴天花板 to its employees need not be reported under the EBEA, 绿奴天花板 under certain circumstances may have to report the gift value to the IRS as employee income.  This applies to any cash or cash equivalent gift regardless of amount, and to non-cash gifts that exceed a de minimis value.

Scenario three (02:30)

A vendor sent me a tower of holiday treats with meats and cheeses - a $250 value. Can I keep this gift? Do I need to do any reporting on it?

You will need to report it. Take the perishables and try to give them to the food bank, or the soup kitchen: someplace that will be able to take advantage of them, because you cannot keep it for yourself. Next best would be to treat it as a gift to the entire university, and distribute those as widely as possible among your department, or your unit, or your university. Send a polite thank you note saying that you will not be able to accept gifts like that in the future.

(03:52) I see less expensive gifts over the holidays like a tin of popcorn, or a box of cookies, or things like that. Do those have the same rules?

State law says that a gift of under $150 does not need to be reported; and an occasional gift of fifty dollars or less is not presumed to be designed to influence our official actions or judgment. 

The university has a stricter standard. We're not supposed to accept any gifts from any entity that go above the level of something like a coffee cup or a pen or a calendar.

Scenario four (04:45)

I'm at a conference, and they do a drawing for next year's registration - thousand dollar value - and my name is drawn. How do I handle that in regards to compliance?

As long as that registration discount is available to the university rather than to you personally, then you can accept that, and whoever the university may decide to send the next year can take advantage of that discount. It's not benefiting your own personal or financial interest, that's benefiting the university.

Where do people go for more information? (06:12)

The General Counsel's office has a website specific to the Executive Branch Ethics Act and associated university policies. /counsel/ethics-information/

The state of Alaska has its own website specializing in the Executive Branch Ethics Act. https://law.alaska.gov/doclibrary/ethics/EthicsCode.html

For each one of the universities the HR senior business partner serves as the ethics designee. Or you can contact the General Counsel office. such as the Executive Branch Ethics Act (EBEA). Acceptance of gifts is covered in the EBEA, which serves at 绿奴天花板鈥檚 Standards of Ethical Conduct.  

 


鈥淐ompliance Chat鈥 videos are informal conversations where Senior Institutional Compliance Liaison Mary Gower meets with subject matter experts covering frequently asked compliance questions and issues in quick, bite-sized clips.