General Policies:

1.3 - Gifts and Gratuities

PURPOSE

To define the practice with regard to the acceptance of personal gifts from vendors.

It is Rensselaer's objective to award business on the basis of such considerations as quality, service, pricing and technical ability; to obtain grants from and contracts with private and governmental agencies based upon mutual intellectual interest; and to avoid the appearance or actuality of impropriety in the receipt of personal gifts, gratuities, favors, and/or kickbacks in connection.

POLICY

The solicitation or acceptance of personal gifts, gratuities, favors, or kickbacks by a Rensselaer employee is prohibited, except when it might be inappropriate or insulting to refuse the gift offered and the value of the gift is nominal.

This policy is not intended to supersede the appropriate sections of the Handbook for Academic Staff, which deals with developing and maintaining faculty consulting relationships nor the Human Resource Management Policy and Procedure Manual concerning the right of exempt and non-exempt staff to do likewise provided there is no conflict of interest.

This policy is not intended to eliminate ethical activities such as business luncheons or the exchange of token mementos of nominal value. However, such activities should be kept to the minimum level necessary for maintaining effective business relationships.

DEFINITIONS

Gift/Gratuity/Favor:

The use of property or facilities, gift certificates, entertainment, or other items of value extended to Rensselaer employees or their families, subcontractors or consultants.

Kickback:

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 a procurement. This is consistent with the Anti-Kickback Enforcement Act of 1986.

PROCEDURE

Every effort should be made to refuse politely all offers of gifts from vendors.

When it might be inappropriate or insulting to refuse a gift offered, the gift is to be accepted in the name of Rensselaer and, if over $100, must be reported to the Vice President of Institute Advancement. This Vice President will determine a suitable distribution for the gift.

Violations of this policy should be reported to the Human Resources Office, which will work with the Director of Internal Auditing in investigating. Consistent with Rensselaer policy in the Handbook for Academic Staff and the Human Resource Management Policy and Procedure Manual, disciplinary action will depend upon the extent of or potential for damage to Rensselaer and can range from reprimand to termination of employment.

Questions on this policy interpretation can be addressed to either the Human Resources or the Director of Internal Auditing.


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Revised 3/02