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2201 Gifts from External Parties to Employees
Office of the Controller
September 7, 2005
August 16, 2006
Employees representing the University conduct business with outside organizations, vendors and individuals. This Policy provides broad guidelines on gifts given by external parties to University employees. This policy does not cover gifts given to the University Policy 2200 or Gifts purchased from University funds Policy 3303.
This policy sets guidelines to employees who represent the University in their business operations. Employees are expected to uphold the integrity of the University in the highest manner when conducting business operations of the University with outside organizations, vendors and individuals. Along with prudent business judgment, employees are expected not to compromise business transactions in exchange for personal gifts.
In general, employees cannot accept gifts from outside sources for personal benefit. In some instances, if it furthers the University goals, promotional materials and business meals may be acceptable.
The provisions of this policy must be applied consistently to all University institutional activities.
Reason for the Policy
To maintain the highest ethical standards for conducting University business in accordance with Standards of Business Conduct issued by the University.
It is defined as a tangible or intangible item of any value received from external sources, directly or indirectly by the employee of the University.
Immediate Family Member
Immediate family is defined as employee’s
- spouse or domestic partner
- children or children of spouse or domestic partner
- siblings or siblings of spouse or domestic partner
- parents or parents of spouse or domestic partner
- grandparents or grandchild
Gifts in the form of cash, gift certificates, vacations, or volunteered services to University employees or their immediate family members are prohibited, with a few exceptions as noted below. Unsolicited gifts should be returned to the donors.
Buyers and certified buying agents or members of their immediate family may not accept personal gifts or entertainment from any vendor by any means, directly or indirectly, at any time of the year. This includes but is not limited to items of value, quasi-social invitations, credits for vendor promotions, etc. Please refer to Purchasing Policy 3201 for more details.
University employees can however accept the following:
- A plaque or an award;
- Items of insignificant value that are commonly given to everyone;(e.g., key chains, T-shirts, coffee mugs, bags)
- Informational materials that are commonly given by vendors to everyone;(e.g., booklets, audio or video tapes)
- A non-cash raffle prize or draw at a conference or similar events, where the employee is representing the University; (Any cash prizes must be used to offset the expenses associated with the event/conference.)
- Goodwill exchange gifts when University officials are on a mission abroad or visiting other domestic institutions or when officials from other institutions visit Yale University. Because a refusal of a gift could offend the hosting officials, such gifts can be accepted. If the gifts are of significant value (i.e. greater than $150), they become the property of the University and should be discussed with the head of the department;
- Business meals with a prospective vendor or at professional meetings and conferences are allowed if the University gains from such attendance. For example:
- When individuals authorized to issue purchase orders visit the vendor’s business as part of an investigation of a vendor’s capability to service the University, or to review a new product or new facilities;
- When individuals perceive that continuing discussions with a vendor through mealtime has particular merit.
Repetitive mealtime meetings should be discouraged. Meals associated with pure entertainment, where University business is not discussed, are not considered business meals.
The University allows payment for reasonable and necessary meal expenses incurred during a business meeting involving external parties if the purpose of the meeting is to discuss University business. Refer to the on Policy 3302 Business Meals, Entertainment and Social Events.
Roles and Responsibilities
Responsible for interpretation of this policy.
Adherence to this policy.