Guidelines for Gifts and Gratuities

Guidelines for Gifts and Gratuities

The following guidelines are provided to assist academic appointees and employees and their supervisors in determining whether any gift, gratuity or benefit may be accepted in accordance with the Principles of Ethical Conduct, and what steps to take if the proposed gift, gratuity or benefit may be perceived as unethical. These guidelines apply to the academic appointee’s or employee’s position at Indiana University and do not impinge on the ability to have outside consulting arrangements, where such arrangements are in accord with the Conflicts of Commitment and Ghost Employment section of the Conflicts of Interest and Commitment policy

1. The acceptance of the following gifts, gratuities, or benefits are considered consistent with the Principles of Ethical Conduct:

• Items of de minimus annual aggregated value below $100;
• Conference registration waivers where Indiana University benefits from  the academic appointee’s or employee’s attendance at the conference or where  the academic appointee or employee is a speaker, moderator or other participant;
• Meals, beverages, and entertainment as part of a business meeting or discussion or in conjunction with attendance at a conference, convention, or similar event; 
• Payments from government or not-for-profit entities for:
  1. participation in conferences, seminars, lectures or other educational activities, or
  2. participation on boards, advisory committees or review panels.

2. The following steps should be taken if an academic appointee or employee is concerned that a gift, gratuity, or benefit may be perceived as unethical:

• Consult with the supervisor, whether that be a department chair, dean, or unit head. It is the duty of supervisors to oversee and manage situations where even the perception of impropriety may occur.
• In determining whether the proposed gift, gratuity, or benefit  may be accepted consistent with the Principles of Ethical Conduct, the supervisor should consider whether the gift, gratuity, or benefit:
  1. Serves a legitimate university business purpose and provides a net benefit to the university;
  2. Meets customary industry practices and conventions;
  3. Puts the academic appointee or employee in a questionable ethical position; and
  4. Its acceptance is otherwise allowed by this policy and in compliance with all other university policies, including the Conflicts of Commitment and Ghost Employment section of the Conflicts of Interest and Commitment policy.
• Questions about individual situations may be directed to the University Compliance and Policy Office.

3. Any gift, gratuity, or benefit received by an academic appointee or employee as a result of the appointee’s or employee’s work for the university should be reportable in the academic appointee’s or employee’s annual Conflicts of Interest and Commitment Disclosure.

4. Individual units may create internal policies that are more restrictive than this policy, but not less restrictive.  (See, e.g., the Indiana University School of Medicine’s Industry Relations Policy for Medicine; FIN-PURCH-09 (Purchasing Ethics)).