Teachers College
Columbia University

Gifts and Benefits Disclosure

POLICY 404

1.0   PURPOSE

       To establish the reporting requirements for accepting personal gifts related to carrying out the responsibilities of a College position.

2.0   SCOPE

       This policy applies to all employees.

3.0   RESPONSIBILITY

        The interpretation and administration of this policy shall be the responsibility of the General Counsel.

4.0     POLICY

    4.1     In order to avoid an actual, potential or perceived conflict of interest, employees should not solicit or accept personal gifts (for himself/herself or any family member) from current or potential vendors, contractors or their agents, local businesses, or others with whom there is a potential or ongoing business or professional relationship. Employees may accept ordinary business courtesies, such as payment for a modest meal or event, or gifts which are promotional items without significant value (i.e. greater than $100, consistent with IRS policy) and which are distributed routinely.

    4.2     Gratuities or gifts of money to the employee from current or potential vendors, contractors or their agents, local businesses, or others with whom there is a potential or ongoing business or professional relationship are never permissible.  An employee who is offered such a gift must refuse it.  An employee given such a gift must return it immediately to the donor.  In either event, the employee should immediately report the offer or gift to his or her supervisor.

    4.3     In the decision as to whether or not to accept any gift (which is not covered in section 4.2 of this policy), employees should use good judgment and avoid in all cases any actual conflict. For example, College officials are often offered good will gifts when on a mission abroad, visiting other domestic institutions, or when officials from other institutions visit the College. Because a refusal of a gift could offend the hosting officials, such gifts may be accepted. If the gifts are of significant value they become the property of the College and should be discussed with the employee’s supervisor.

    4.4   TC employees shall disclose to their respective Vice Presidents any gifts or other benefits valued  at more than $100 received from anyone with whom the College has a potential or ongoing business or professional relationship.
 
    4.5   Employees who have questions regarding this policy or who are uncertain as whether a conflict of interest exists should confer with their supervisor or the General Counsel.  Faculty who are uncertain as to whether a conflict of interest exists should confer with their department head.  Department heads should confer with the Provost on any question of potential conflict of interest.

Tagged: HRPolicy