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Acceptance of Gifts Policy

Adopted November 28th, 2011

As representatives of Wentworth Institute of Technology, all employees – faculty, administrators and staff - are expected to conduct themselves in a professional and ethical manner, maintaining high standards of integrity and the use of good judgment. Employees are expected to be principled in their business interactions and act in good faith with individuals both inside and outside the Wentworth community. They should act with due recognition of their position of trust and loyalty with respect to the Institute and its students, trustees and donors.

Employees shall not seek or accept for themselves or others, from any vendor as defined below, any gifts, favors, goods and services, travel, lodging, entertainment, discounts, payments without a legitimate business purpose, or loans (other than conventional loans at market rates from lending institutions).

For purposes of this policy a vendor is any person or business organization that does business with the Institute or seeks to do business with the Institute. This includes, but is not limited to, all suppliers of goods and services, creditors, bankers, lenders, and advisers.

Employees may accept common business courtesies associated with customary business practices, but a strict standard is expected with respect to acceptance of gifts, entertainment, or other consideration of greater than nominal value from vendors.

Guidelines

Examples of gifts that are or are not acceptable include the following:

  1. Gifts of tangible items such as clothing, electronics, furnishings, tools, etc. are not acceptable (unless they are acceptable under item 2 or item 13 below).
  2. Gifts of tangible items of small value from vendors such as calendars, pens, mouse pads, mugs, clothing with vendor logos, etc. are acceptable.
  3. Meals and/or refreshments with vendors as long as the invitation is extended by the vendor and the value of the meals and/or refreshments is $100 or less are acceptable.
  4. Meals and/or refreshments with vendors as long as the invitation is extended by the vendor and the value of the meals and/or refreshments is greater than $100 but not greater than $200 are acceptable only if the employee can demonstrate a legitimate business purpose for the meals and/or refreshments and their acceptance is approved by the employee’s division head (Vice President).
  5. Meals and/or refreshments with vendors are not acceptable if the value of the meals and/or refreshments is greater than $200 (unless they are acceptable under item 6 or item 7 below).
  6. Meals and/or refreshments when participating in a professional or educational program and the meals and/or refreshments are provided to all participants are acceptable.
  7. Meals and/or refreshments when participating in a bona fide charitable event and the meals and/or refreshments are provided to all participants are acceptable.
  8. Participation in a bona fide charitable event (such as golf tournament) sponsored by Wentworth is acceptable if offered by the vendor regardless of whether the vendor accompanies the employee to the event.
  9. Tickets to events (such as sports, arts, etc.) are acceptable if offered by the vendor and the vendor accompanies the employee to the event. These are not to be solicited by the employee and their acceptance must be approved by the employees division head (Vice President).
  10. Tickets to events (such as sports, arts, etc.) are not acceptable if the vendor does not accompany the employee to the event.  The tickets may be accepted if approved by the employee’s division head (Vice President) and the tickets are given to Human Resources, Studen Affairs, or Student Leadership Programs for use as a prize or incentive for students or employees.  
  11. Day outings (such as golf) are acceptable if offered by the vendor and the vendor accompanies the employee to the outing. These are not to be solicited by the employee and their acceptance must be approved by the employee’s division head (Vice President).
  12. Day outings (such as golf) are not acceptable if the vendor does not accompany the employee to the outing.
  13. Gifts of perishable items typically given during the holidays such as candy, cookies, nuts, flowers, etc., are acceptable as long as the value is $100 or less.  Employees are encouraged to share such gifts with their departments.
  14. Gifts of perishable items typically given during the holidays such as candy, cookies, nuts, flowers, etc., are not acceptable if the value is greater than $100.
  15. Use of vendor's facilities (vacation homes, etc.) by employees or families for personal use is prohibited.
  16. It is never permissible to accept a gift of cash, a cash equivalent such as stocks or other forms of marketable securities, a gift certificate or gift card, of any amount.

Compliance

Employees must exercise caution that frequent receipt of gifts, entertainment, or other consideration that are otherwise acceptable under this policy do not gradually accumulate into an embarrassing obligation (or violation of this policy).  Under no circumstances shall an employee accept a gift where prohibited by law, statute or regulation, or where the appearance of impropriety may occur.

Any violation of this policy will subject the employee to disciplinary action up to, and including, immediate discharge.  When questions arise concerning any aspect of this policy, contact the Vice President for Human Resources.

Where an employee is accused of violating this policy, and the employee has relied in good faith on the advice of supervisors or Institute legal counsel, after full disclosure of the material facts, no disciplinary action may be taken against the employee under this Policy.