MCC Daily Tribune
'Tis the Wonderful Season for Gifts!
The holiday season is here—a time for feasting, gathering with loved ones, and, of course, giving and receiving gifts. However, gift exchanges can sometimes create conflicts of interest for employees. While exchanging gifts can promote goodwill and strengthen relationships with our community and third-party partners, we must stay alert.
“A conflict of interest will be deemed to exist whenever an individual is in the position to approve or influence College policies or actions which involve or could ultimately harm or benefit financially: (a) the individual; (b) any member of his or her immediate family (spouse, parents, children, brothers or sisters, and spouses of these individuals); or (c) any organization in which he or she or an immediate family member is a director, trustee, officer, member, partner or shareholder or has a substantial financial interest.”
To navigate the holiday gift-giving season without conflicts, consider these guidelines:
- Focus on Perception, Not Intent - It’s crucial to consider how a gift may be perceived by others rather than just its intended purpose. Gifts should be of nominal value (not exceeding $75); avoid soliciting or accepting anything beyond this amount if it could be seen as influencing your actions. Some gifts, like quality gift baskets, can easily fall into a gray area, ranging between $20 and $200.
- Don’t accept cash gifts – Accepting cash or cash equivalents, including gift cards, event tickets/entertainment, services, loans, travel, or hospitality that exceeds the nominal value ($75) from individuals or vendors with pending contracts or those looking to do business with the college is strictly prohibited, especially if you have decision-making authority regarding such agreements. For more information, please refer to New York State's General Municipal Law, §805-a (PDF).
- Consider Philanthropy – Reach out to the MCC Foundation to explore the possibility of redirecting gifts (with the giver's permission) to support MCC's philanthropic initiatives.
Acceptable Gifts:
- Token promotional or logo items from suppliers of a nominal value such as calendars, hats, t-shirts, mugs, etc. Refer to the Joint Commission website for more information.
- Holiday gift baskets and flowers for the department, homemade gifts, or perishable food items (i.e. tea, coffee, donuts, chips, fruit, soda, bottled water, etc.) of nominal value (not to exceed $75).
- Meals received when you serve as a participant or speaker in a job-related professional or educational program and meals are available to all participants.
Unacceptable Gifts:
- Gifts of cash, cash equivalents, gift certificates, and gift cards which exceeds the nominal value.
- Gifts such as event tickets, services, loans, travel, or hospitality that may influence or give the appearance of influencing business judgments for personal gain or unfair business advantage.
- Accepting gifts of any amount of money from any student or parent of a student, even if it is appropriate or culturally acceptable to do so in the student’s native country.
Disclose any possible or apparent conflicts of interest to the Human Resources Management office as soon as they arise so that appropriate steps may be taken to prevent a potential conflict of interest from becoming an actual conflict of interest.
If you have any questions about this notice, please contact Brenda Ronan, Compliance Officer/Internal Auditor.
Brenda Ronan
Internal Audit
12/04/2024