The Institute has a policy that forbids Institute community members from soliciting or accepting gifts, gratuities, or special favors of any kind from outside vendors, contractors or companies with whom they do business on behalf of the Institute. The Institute has adopted this policy to ensure that vendors, contractors and other business associates are selected fairly and engaged only for appropriate business reasons. Accepting gifts and gratuities would tarnish a business relationship and cause the appearance of favoritism or conflict of interest. (For more information about this topic, see Conflicts of Interest in this manual.)

Gifts and gratuities may include, but are not limited to:

• Cash rebates to an individual making a purchase on behalf of the Institute
• Free tickets to a sporting, cultural or entertainment event
• Personal discounts
• Personal commissions
• Tangible items of value (such as liquor, securities, real estate, etc.)

An occasional, nominal business courtesy, such as a lunch, dinner, or promotional item provided by a vendor, contractor or outside company, is acceptable under this policy. Gifts, gratuities or favors valued in excess of $25, however, are not acceptable, nor is a cash distribution of any amount. If the value of a gift is undetermined, it should by default be considered unacceptable. If a community member receives a gift or gratuity, he or she should notify the supervisor or the Associate Director and Treasurer and return the gift to the donor. The donor may also be advised that it is acceptable to credit the Institute’s account as an alternative to giving a personal gift or reward.

All supervisors are responsible for ensuring that employees are aware of and adhere to this policy. Each Institute community member interacting with third parties is responsible for informing them of this policy.