This policy will provide guidance to employees on what is ethical when receiving gifts from outside organizations, vendors and individuals.
Dartmouth College strives to maintain the highest standards of ethical conduct in its dealings with its business associates, including vendors and potential vendors, customers and business partners. Acceptance of gifts may create conflicts of interest and has the potential to influence decisions. College employees, and their immediate family members, are prohibited from receiving gifts from outside organizations, vendors or individuals, with the few exceptions that are noted below.
Any employee representing the College in their business operations.
Any individual that has a supervisory role at the College.
This policy is a guide for employees representing the College in business operations. Employees are expected to uphold the integrity of the institution while conducting business with outside organizations, vendors and individuals. All employees are expected not to compromise any business transaction, even in appearance, in exchange for personal benefit such as gifts.
Federal regulations, which govern procurement under contracts and grants, impose a like prohibition mandated by Public Law 99-634, known as the "Anti-Kickback Enforcement Act of 1986." "Kickback" is defined as 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 procurement under a federal contract or grant.
Internal Controls Services
Promotional items of insignificant value, of an advertising nature, an occasional business meeting meal, or other items of small value may be accepted. Gifts outside of these guidelines would be deemed unacceptable and shall be declined, or returned if already accepted.
College employees can accept the following:
It is permissible to accept meals and lodging, and participate in social events, at conferences conducted by Dartmouth business associates.
An employee should consult with his/her supervisor if there is uncertainty of the appropriateness of accepting a gift. Dartmouth staff should be mindful that the acceptance of a gift may create an appearance of a conflict of interest and this appearance should also be weighed in the decision as to whether to accept a gift.
Gift – A tangible or intangible item of any value given to a College employee, directly or indirectly, from an external source. Gifts can be in the form of cash, gift certificates, tickets to sporting events, etc.
Immediate Family Members – An 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, or any person living in the same household.
All employees are responsible for becoming familiar with and adhering to this policy. Supervisors are also responsible for ensuring that this policy is known by their direct reports and that all employees are following it. If this policy is breached, it should be brought to the attention of one of the departments within the Contacts/Responsibilities section of this policy or by going to the Dartmouth Compliance and Ethics Helpline.