Office of Origin: Finance 
Responsibility: Chief Financial Officer 
Original Date Adopted: 8/24/10
Dates Reviewed: 1/15/12, 11/20/17, 1/23/18, 7/28/21(C) 
Last Date Approved by Board: 9/21/21 

This policy establishes direction for acceptance of gifts, gratuities, and honoraria that might arise in the course of Lake Michigan College (the College) employee relationships with vendors, consultants, contractors, and others providing goods and services to the College.   

This policy does not seek to unreasonably restrict or interfere with maintaining good relationships with such entities but rather to ensure that College interests are not compromised by establishing expectations for ethical business practices, including avoidance of actual or appearance of conflicts of interest, and to provide direction for disclosing offers and receipt of gifts and gratuities. 

Employees are expected to conduct all business according to the highest legal and ethical standards.  For protection of the College as well as the employee, employees must maintain a high degree of integrity in dealing with all past, current, and potential vendors providing goods and services to the College. It is essential to both the College that all decisions and actions regarding purchasing are based upon proper business considerations and not influenced in any way by personal obligations.  

As a basic condition of employment, employees have a duty to act in the College's best interest regarding business relationships related to their employment.  This duty means that employees must not engage in any business practice that will interfere with their College obligations, damage the College's reputation, compromise the independence of College business activities, or reasonably be seen as doing so.  

Policy 

In general, acceptance of any gift or gratuity by employees from an outside entity is prohibited; this includes merchandise, cash, services, entertainment, and other courtesies. However, insignificant non-monetary gifts (defined below) may be accepted in the interest of maintaining positive business relationships, subject to compliance with the requirements below. 

Except for fund-raising activities where gift solicitation has been formally approved, employees are strictly forbidden from soliciting gifts of any type or value for themselves, their family, friends, or favorite organizations. 

Requirements 

1. Monetary Gifts – Acceptance of monetary or near-money items such as cash, gift cards, gift certificates, business credits, tokens, and other cash substitutes is strictly prohibited other than as discussed below.   
2. Insignificant Non-Monetary Gifts – Insignificant non-monetary gifts are those valued at $25 or less. These may be accepted without disclosure, subject to the remaining guidelines.   
3. Acceptable Gifts – Certain gifts are considered acceptable due to their nature, such as: 
   • Calendars, desk novelties, or similar marketing items  
   • Reasonably priced meals accepted in settings where College business is conducted 
   • Books, media, software, or similar work-related items for which there is not charge 
   • Perishable gifts such as candy, fruit baskets, or flower arrangements that cannot easily be returned should be shared or distributed among department employees.   
   • Gift cards or gift certificates that will be used by receiver’s department for supplies, equipment or for a department meal (e.g., gift card for pizza) may be accepted. Disclosure must be made when accepting these for department use.  
   • Event tickets, golf outing invitations, convention and seminar admission fees, and similar as long as such are rotated among department or other employees. 
4. Initial Response – Upon offer or receipt of any gift (other than Insignificant Non-Monetary or Acceptable Gifts), the employee should attempt to either not accept or to return the item to the provider, reminding provider of the College policy discouraging receipt and acceptance of gifts. 
5. Disclosure Process – Employees must fully disclose receipt of any non-monetary gift (other than insignificant non-monetary gifts) in writing via the Gift Disclosure Form.  This form should be submitted to the employee’s supervisor or the supervising Cabinet member as soon as possible after receipt of gift.  Disclosure should include details such as name of provider, item description, and estimated value.  The supervisor or Cabinet member must acknowledge in writing the disclosure and identify recommended disposition.  
6. Participation in Sponsored Activities – Employees who participate in vendor-sponsored events or activities during the employee’s regular work day must have supervisor approval.  Such participation may require the time away be charged as vacation leave. 

References:  Internal Revenue Service limits on business gift deductions per IRS Publication 463, Travel, Entertainment, Gift, and Car Expenses