Employee Personal Gifts Policy
Effective: 8/18/09; Reviewed: 10/13/21
Updated: 12/7/16
Contact: Human Resources
The purpose of the William Jewell College Employee Personal Gift Policy (the “Policy”) is to provide employees with an understanding of acceptable behavior regarding personal gifts offered by vendors, potential vendors, customers, potential employees or any other outside individual or organization. This Policy does not apply to gifts to the College through our fund raising efforts.
Covered Persons
This Policy applies to all employees of William Jewell College.
General Policy
It is the Policy of the College that all employees shall comply with the provisions of state and federal law governing the acceptance of gifts and gratuities and applicable conflict of interest regulations. In addition, employees must avoid the appearance of favoritism with regard to business relationships and are expected to act with integrity in the performance of their College responsibilities. College employees are expected to consult with their supervisor if there is a question or uncertainty on this Policy or its intent.
Acceptable Gifts
- Acceptance of modest entertainment such as a meal or refreshments in connection with attendance at professional meetings and events sponsored by industrial, technical, professional, or educational associations is permissible. Moderately priced entertainment is also permissible as part of business meetings that advance the College’s interests and relationships. Moderately priced entertainment is considered to be less than $75 per gift or event. The employee should not receive more than two gifts from one vendor per calendar year.
- Gifts presented to College officials as dignitaries representing the College at events are acceptable. Gifts of nominal value for representing the College or speaking at events such as conferences and civic organizations, or for participating in activities as a representative of the College are also acceptable as are reasonable Honoraria.
- Cards, thank you notes, certificates, or other written forms of appreciation and recognition.
Unacceptable Gifts
- Cash, stocks, bonds or other negotiable instruments regardless of the dollar amount.
- Any items with a value in excess of $75 without advance written approval from the Vice President for Finance & Operations. The approval request should document the business reason for accepting this gift.
- Gift cards, regardless of value, unless they are presented as a gift for speaking at an event or representing the College in an activity. In such case, the value of the card should not exceed $75.
- Employees whose responsibility is the procurement of goods and services may not accept any gifts. Likewise, employees serving on committees that are evaluating products or services may not accept any gifts from vendors bidding on these items.
Items Not Considered Gifts
- Items received at conferences, seminars or training events that are distributed to all attendees. These items would include t-shirts, pens, trade show bags or similar giveaways. Likewise, food and beverages provided to all attendees at receptions, breaks or dinners are also not considered gifts. Door prizes awarded at these events are also not considered gifts, provided that all attendees had an opportunity to register and receive the prize.
- Plaques, trophies or similar awards that recognize the accomplishment of an employee.
- Discounted admission to conferences, trade shows or seminars whose sole business purpose is to assist the College in becoming proficient with a particular product or software or learn more about a particular service or industry. These items are not considered as gifts, since the College and not the employee is the beneficiary of this discount.
- De minimis items such as pens, mugs, calendars and other trinkets valued at less than $25. It is deemed that these items are not significant enough to influence a person’s decisions.
- Complimentary trips to vendor operations, user conferences, client visits or other travel that is conducted as part of the College’s due diligence in researching a product or service. These are not considered a gift provided that all potential vendors are afforded the same opportunities.
- Discounts provided to all College employees by vendors through a College contract or in conjunctions with the Human Resources Department.
- Gifts from potential donors or sponsors in connection with College fund raising efforts. Examples of these could include golf fees, meals, or travel expenses paid for by donors for College employees in their fund raising efforts.
- Complementary tickets to productions that are for the purpose of College employees evaluating performers who may enter into a professional relationship with the College.
Employee Responsibility When Gifts Are Received
- Employees are to professionally inform vendors, potential vendors and others of this Policy and request that they comply.
- If an employee or department receives a gift that does not comply with this Policy, the gift should be returned to the vendor and the vendor requested to comply in the future.
- All exceptions to any aspect of this Policy must be approved in advance and in writing by the Vice President for Finance & Operations.
- The Vice President for Finance & Operations must receive advance approval from the President for paragraphs 5 and 18 of this Policy.