Approved by: Board of Trustees
History: Issued              -- March 14, 2001
Revised            -- January 29, 2013
Last Reviewed --
Related Policies: Conflict of Interest Policy for Staff and Faculty
Additional References:
Responsible Official: Vice President for Finance and Treasurer tel. (202) 319-5606

I. Introduction


For University officials to conduct business in an arm's length and responsible manner, it is essential that employees maintain independence from vendors, contractors and others doing business with the University. In accordance with the University's Conflict of Interest Policy for Staff and Faculty, all employees shall avoid any conflicts between their personal interests and the interests of the institution. Such individuals are expected to avoid even the appearance of impropriety with respect to the performance of their duties and must never use their positions or knowledge gained on the job to inappropriately influence decisions for their advantage, or for the advantage of their family and friends, to the detriment of the University.

This policy applies to all faculty and staff employees and to student organizations.

II. Requirements


A. Gifts to the University


Should a contractor/vendor indicate to any employee a wish to make a gift of services or equipment to the University, the employee must refer the contractor or vendor to the Vice President for Finance and Treasurer who will coordinate with the Vice President for Institutional Advancement to determine if the gift is something the University wishes to accept consistent with its mission, and then to process the gift, determine the value of the gift and properly receipt the gift for the donor's tax records. No other office may accept/process an unsolicited gift of services or equipment from a contractor or vendor.


B. Gifts to Employees


Employees may not accept gifts from contractors/vendors, with whom the University does business currently, has done business, or could reasonably anticipate doing business in the future. An exception may be made for traditional Christmas gifts of insignificant value, business-related meals, small advertising novelties and occasional tickets to sporting events or other entertainment events. While employees may accept such gifts, any gifts in value greater than $100 or gifts which in total exceed $100 per year must be reported in writing to the Chief Ethics and Compliance Officer at tel. (202) 319-6170 or no later than two weeks after receipt. Acceptance of these gifts or gratuities, however, shall not obligate or be construed by any party to obligate the University to conduct further business with the contractor/vendor.

Travel or accommodations offered by a contractor/vendor to a University employee may not be accepted without express, advance permission of the cognizant Vice President.