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Acceptance of Personal Gifts and Entertainment
Tufts University is committed to the highest standards of honesty, integrity, and fairness in both actuality and appearance. This policy should assist all Tufts employees in understanding the university’s expectation regarding the acceptance of gifts and other benefits offered by vendors, contractors and others conducting business with Tufts. The policy prohibits the acceptance of gifts and favors, but recognizes the potential appropriateness of participating in sponsored events and the de minimis nature of certain gifts. Following this policy will avoid any conflict and will reduce the number and types of gifts and favors that will require reporting on the Annual Conflict of Interest submission.
In general, employees should not accept gifts from businesses and individuals that sell goods and services to the University. Gifts made to university personnel may be in the form of entertainment, travel, social invitations, sporting events, favors, personal property, services or discounts. Gifts from vendors, contractors and others conducting business with Tufts may appear to be a gesture of goodwill and appreciation, but all faculty and staff should be aware that gifts of higher value are generally given with the intent to maintain an existing or influence a future business relationship. This behavior is customary business practice, but such activity serves no useful purpose and can create conflicts of interest, particular when the gift is of significant value. It is the obligation of the employee responsible for a business relationship to handle gifts properly.
Consistent with this commitment, Tufts University employees and members of their immediate families are prohibited from soliciting any personal gift, gratuity, favor, service, or other benefit (collectively, a “gift”) from individuals or companies seeking any advantageous action by, or relationship with, the University.
The acceptance of a personal gift, even if unsolicited, is also prohibited in most instances. A gift valued in excess of $50 or of undetermined value, unless employed for a University purpose or shared widely within the University or a unit thereof, must be declined or returned immediately. Multiple gifts from a single source in any calendar year are prohibited. Employees are prohibited from accepting gifts of money or their equivalent, regardless of the amount, at any time. Gifts of promotional items without significant value that are routinely distributed by vendors to clients, and courtesy copies of professional printed matter, may be accepted.
Public law, 99-634 known as the “Anti-Kickback Enforcement Act” of 1986 is the Federal regulation which governs procurement under contracts and grants. It imposes a prohibition or “kickback” defined as any money, fee, commission, credit, gift, gratuity, thing of value, or compensation of any kind that is provided by a supplier, directly or indirectly, to any employee for the purpose of improperly obtaining or rewarding favorable treatment in connection with procurement under a federal contract or grant. Accordingly, employees involved in awarding, administering or fulfilling obligations pertaining to grants or contracts supported by federal or other government funds are prohibited by law from soliciting or receiving gratuities, favors, or anything of monetary value, in any amount, from current or potential contractors or sub-contractors supporting these activities.
In addition to the above, the expenditure of University funds for gifts to employees or students other than those provided through authorized recognition programs is prohibited. For further information, please refer to the university’s Business Expense Policy Guidelines, as posted within the Finance Division’s website.
Advisory Boards or Corporate Sponsored Travel
University employees may be asked to participate in vendor advisory board or attend vendor sponsored conferences and meetings that can often be paid by the vendor. Employees should abstain from accepting travel and entertainment support from vendors who do business with the University. Employees should give careful consideration prior to attending such events in light of potential appearance concerns and the vendor’s interest in seeking an advantage. If after consultation with your supervisor it is determined that the University’s interest is best served by your participating in the event then you should consider the cost of attending a University business expense and seek the appropriate approval and reimbursement.
Sponsored Activities by Outside Organizations
Meals or certain events are often sponsored at professional meetings or conferences by outside entities that have extended invitations to members of the Tufts University community to attend at no cost. Subject to supervisory approval, an employee may be allowed to participate as long as the invitation has been extended to a group of attendees from other organizations, is relevant to the employee’s work, or is supportive of Tufts’ mission. Employees should use discretion by avoiding events and activities that might be construed as extravagant.
Supervisors are responsible for ensuring that this policy is communicated to and understood by the employees in their unit and that it is effectively enforced.
Questions & Answers
A vendor servicing my department treats me to sporting events. Is this appropriate?
No. University policy prohibits employees from accepting gifts of any kind from vendors.
A consultant working with the University has offered to let me stay at his vacation home on Cape Cod for the weekend. Should I accept the invitation?
No. Acceptance of this gift would give the appearance of impropriety and therefore would be inappropriate for you to accept the invitation.
A vendor treats me to a meal occasionally. Is this appropriate?
No, it is not appropriate. This invitation would be interpreted as the vendor trying to influence you. This invitation should not be accepted.
In attending a conference, a vendor offers to pay for a round of golf and a group dinner or some type of hospitality event. Is this acceptable for me to participate?
Yes and No. The dinner is acceptable given that other conference attendees will be attending and covers items that would normally be considered a legitimate University business expense. You should not accept the round of golf as this is not considered a legitimate business expense.
I have been asked to join a vendor’s advisory board which involves two trips a year. The vendor has offered to pay for all my expenses. Is this appropriate?
You should discuss the benefits to the University of joining the advisory board with your supervisor. If approved by your supervisor you should treat the cost of attendance as a business expense and seek reimbursement from the University.