1.8 Institute Policies on Gifts and Gratuities (10/05)

In the course of doing business, it is quite natural to develop close relationships with suppliers. This may lead to expressions of friendship or appreciation in the form of personal gifts or gratuities from vendors, subcontractors, and contractors (referred to in this section as "suppliers").

It is the Institute's objective to award business to suppliers based on considerations such as quality, service, competitive pricing, and technical abilities. Acceptance of personal gifts or gratuities from suppliers that could be construed as a means of inducing business with the Institute is totally inconsistent with this objective.

Institute policy prohibits Institute employees from accepting personal gifts or gratuities of any kind from suppliers. This includes the use of property or facilities, gift certificates, entertainment, or other favors of value extended to employees or their families.

Federal regulations, which govern procurement under contracts and grants, impose a like prohibition mandated by Public Law 99-634 (41 U.S.C. 51-58), known as the "Anti- Kickback Enforcement Act of 1986." "Kickback" is defined as any money, fee, commission, credit, gift, gratuity, thing of value, or compensation of any kind that is provided by a supplier, directly or indirectly, to any employee for the purpose of improperly obtaining or rewarding favorable treatment in connection with procurement under a federal contract or grant. Any violations of the Act may result in both criminal and civil penalties.