FAQs for Accepting Gifts
Below is a full list of frequently asked questions (FAQs) with respect to accepting gifts or offers of hospitality from external partners. If you have additional questions not covered here, please reach out to email@example.com for assistance.
Additional information regarding providing a gift to someone within Northwestern, or to another department at Northwestern, is provided in the Travel and Entertainment policy.
Note that these FAQs do not apply to charitable gifts to the institution, that is, those gifts managed by Alumni Relations and Development and processed by Gift and Record Services. For more information about policies and procedures related to charitable gifts, please see:
- Cash Handling Policies and Procedures for information on how charitable gifts to the institution are processed.
- Policy on Gifts to Northwestern from Faculty and Staff for information on making a charitable contribution to Northwestern as a Faculty or Staff member.
Is there ever a time that I must refuse any gift and/or hospitality?
If a vendor is seeking to become a business partner, is in the middle of a “bid” process with the university, or is renegotiating terms, you must refrain from accepting any gift or hospitality from that vendor.
How can I avoid conflicts of interest – perceived or real – in selecting a vendor or business partner for my Northwestern work?
Following standard Northwestern processes for selecting business partners is a good place to start.
- Review the list of Preferred Vendors that are already thoroughly vetted partners of Northwestern.
- If you need to establish a new relationship, reach out to Procurement and Payment Services to assist with the Invitation to Bid process and assessing the potential partner’s offerings.
- Avoid hiring or using the services of someone in your family and/or an organization in which you have a financial stake unless there are no reasonable alternatives (and be prepared to document that).
I have been offered a Gift and/or Hospitality that exceeds the standards set forth in the Policy. Approval to accept the Gift/Hospitality was denied. May I appeal this decision?
In accordance with the Policy on Conflict of Interest and Conflict of Commitment, a faculty or staff member may appeal decisions to the appropriate school dean’s office, supervisor, NUCOI, Staff Conflict of Interest Committee, school-based conflict of interest committee, or Conflict of Interest Oversight Committee if/as applicable. All appeals must be made in writing within 15 calendar days of the date of the individual’s receipt of the denied exception. Contact the Conflict of Interest office for assistance in filing an appeal.
Sporting, Concerts, and Other Events
I have been invited to attend a professional sports/concert/major event by a vendor/organization/individual – may I accept the invitation?
Professional sporting, music and other major events are common invitations to receive in Chicago. In general, these events have ticket prices that are significant and do not meet the de minimus standards of the gift policy.
If you are invited to a sporting/concert/major event by a vendor, potential vendor, organization or individual seeking to do business with the University, you must:
- First inform your direct supervisor and receive approval, indicating that your acceptance of an invitation shall not present a conflict of interest in your duties (subject to the discretion and determination by your supervisor).
- Verify that the representatives of the vendor, potential vendor, organization or individual shall also be in attendance for the event itself. No tickets shall be accepted for your personal use.
- Not accept more than one invitation per year from any vendor, potential vendor, organization or individual.
- Approval must be documented.
Receipt of any and all non-de minimus accepted invitations must be disclosed on your annual conflict of interest disclosure form, with an indication of the business purpose of such event.
Vendors, potential vendors, organizations and individuals may offer gifts at the holiday seasons. Am I permitted to accept them?
It is a best practice to advise all vendors, potential vendors, organizations and individuals doing business with the University that it is not necessary or advisable to give any gift to an individual or to departments during holiday seasons. In general, if the gift can be returned, it should be returned. If a gift is provided to you or to your department that cannot be readily returned, the following guidance applies:
- Cash or gift cards should be politely refused or returned; if it cannot be readily returned, it should be used to purchase something of benefit to the entire department;
- Gifts of shareable food should have any tags or identifying information from the vendor removed and be shared with the entire department;
- If a gift of promotional material is provided and is of nominal value, it should be shared with as many members of the department as possible;
- If gift(s) of food, alcohol or other material value are received and cannot be returned or shared, identifying information should be removed, and the item may be raffled off to a department member or donated to a local organization.
Samples (products, textbooks, other)
A company has sent me a sample of their product for me to evaluate and determine whether it is of use to my Northwestern work. Is this considered a gift? May I accept it?
A publisher has sent me a desk copy of a book or textbook that I am considering using in my class. Is this considered a gift? May I accept this?
I have been invited to breakfast/lunch/dinner by a vendor, potential vendor, organization or individual seeking to do business with the University or already doing business with the University. What is appropriate for me to accept?
Business meals with existing or potential business partners of the University are permissible to accept if i) there is a bona fide business purpose to the meeting; ii) it is the only possible time to conduct business; and iii) is held to a modest standard consistent with the University’s own entertainment reimbursement standards.
Meals should not be accepted with regularity from any vendor, potential vendor, organization or individual.
Any hospitality of a material value or extraordinary nature should be disclosed to your immediate supervisor and in the annual conflict of interest disclosure process.
A vendor is providing a training session on equipment / systems we have already purchased and has offered to bring in lunch for that session. Is this permitted?
Yes, as long as the lunch is held to modest standards consistent with the University’s own reimbursement standards. Because the negotiation is complete (i.e. the purchase has already been made) there is limited opportunity for that meal to be perceived as a quid pro quo.
A vendor or potential vendor has offered to cover the cost of my attendance at a meeting where they will be demonstrating their products. They have offered to pay for flights, hotel, meeting registration, meals, and admittance to an optional, evening networking event. May I accept this?
Paying or waiving the registration fee is acceptable. If meals are included in the registration, that is also acceptable, but travel should be paid for by Northwestern. Similarly, the optional, evening networking event should be paid for by Northwestern if it is for Northwestern purposes.
I will be speaking at an academic conference / conference hosted by a nonprofit, professional organization of which I am a member and/or was on a committee helping to develop the program. As a speaker / committee member, the organization hosting has offered to cover the cost of my travel and waive my registration fee. May I accept this?
Yes. In this case, you have provided a service and time to the organization, and the offer to cover costs associated with that service is acceptable.
I will be speaking at conference, sharing my experiences using a vendor’s product at Northwestern. The vendor has offered to cover my travel expenses, registration fee and meals. May I accept this?
Waiving the registration fee may be acceptable, but travel should be paid for by Northwestern since it is a Northwestern activity. Having the vendor pay for the entire experience creates the perception that they are seeking favor with you / the university and that your presentation, as a member of Northwestern University, may not be an objective representation of the utility of their product.
I have been invited to a conference organized by one organization, but know that vendors and/or business partners of the university are sponsoring the event. Am I allowed to attend such events and/or allowed to accept a waived registration fee from the event’s organizer?
Yes. In cases like this, because the offer of hospitality / the waived registration fee comes from a third party, and not a single vendor, this interaction is considered to be arm’s length.
It is often the case, however, that vendors in attendance at these conferences may pursue opportunities to speak with you while at the conference, and offer additional hospitality directly while at the conference (e.g., a one-on-one dinner with the vendor, or other favors). In those cases, it is prudent to decline the offer, adhering to the guiding principles of this policy: that faculty and staff must avoid accepting a gift or other offer when that offer could be perceived as seeking favor.
I have been invited to speak at a conference, event, or as part of a colloquium. As part of this event, I have been offered a cash honorarium. May I accept this? May I accept reimbursement of travel to/from this event?
Yes. Honoraria are excluded from the definition of “Gift” and are generally provided as an acknowledgement of the value that the speaker brings to the other event participants. Thus, honoraria are more closely aligned with an acknowledgement of services rendered, than a gift.
Acceptance of travel that is arranged or reimbursed for attendance at this event is permitted under the same “services rendered” premise, provided the general principle of this policy is adhered to: that faculty and staff must avoid engaging in transactions or relationships that might influence or appear to influence their decision-making in their role at Northwestern.
In the rare circumstance that an honorarium or travel is being offered by an organization seeking to become a vendor of Northwestern, then the offer should be declined, as the honorarium/travel could be perceived as seeking favor in decision-making.
If the honorarium and/or travel arrangements meet the threshold for disclosure as defined in the Policy of Conflict of Interest and Conflict of Commitment and/or the Policy on Conflict of Interest in Research, they must be disclosed in eDisclosure, as applicable.
Am I allowed to accept a “swag bag” or other tokens while attending a conference or event?
Yes, if the offering is available to everyone attending the conference / event.
I am attending an academic conference where it is common for publishers to make copies of textbooks available upon request for faculty to consider using in their classes. The Policy states that I may not solicit items from External Parties. May I request textbooks in cases like this?
The conference I am attending offers a series of raffles / prizes drawn at random throughout the conference. If I win, am I allowed to accept?
It depends more on the identify of the host / sponsor of the raffle and whether the prize could be viewed as creating any kind of quid pro quo than it does on the value or type of prize.
- If the host / sponsor is an entity that is seeking business with Northwestern, the prize should be refused.
- If the host / sponsor is a professional development organization, the prize likely may be accepted. Prizes like year-long subscriptions to a trade magazine or professional organization are acceptable; cruises or vacations should be refused.
Internal Gifts (within Northwestern)
One of my colleagues has a life event that our team would like to celebrate. Can we give this colleague a gift?
Another department or individual internal to Northwestern that our department provides services to has sent someone in our department a gift. Is it appropriate to accept this gift?
At the holidays, I like to give my staff a small token of my appreciation for their work throughout the year. Is this ok?
Use of Private Aircraft
A vendor, potential vendor, organization or individual has offered the use of private aircraft in order to travel to a destination where current or proposed University business is to be conducted. May I accept the invitation?
The use of private aircraft should be used rarely and only by designated representatives of the University. The designation is provided by the Office of the President. If it is necessary to consider the use of private aircraft, the following steps must be taken:
- Your direct supervisor should be informed and a determination shall be made by the supervisor whether a bona fide business purpose exists for the use of private aircraft;
- It should be documented by the supervisor/department/unit that there is no viable commercial means of transportation to the proposed location;
- The Office of Risk Management should be notified of any potential use of private aircraft in order to ascertain the sufficiency of insurance coverage by the flight operator;
- If the provider of the aircraft is a donor, the Office of Advancement and Alumni Relations should be notified;
- The value of a trip on private aircraft is material to the traveler and may result in the determination of additional taxable compensation to the traveler in excess of the value of a commercially available mode of transportation. A documented, bona fide business purpose must be provided at a minimum to defend against the taxability of the value of the trip;
- If approved, no more than three (3) University officials shall travel on private aircraft at the same time;
- Any non-University employees, family members or guests of a University official who participate on a flight will result in taxable compensation to the University employee;
- All private flight information shall be disclosed to your immediate supervisor as well as on the annual conflict of interest disclosure;
- The University does not permit any employee who is also a licensed pilot to fly any aircraft on official University business.