Frequently Asked Questions- Ethics (General)
What is considered a “gift” under the State Code of Ethics?
The State Code of Ethics defines a “gift” in three parts:
- “Anything of value” (for example, money, tickets to a sporting event, meals, services, gratuities, discounts, etc.);
- Which is directly and personally received;
- Unless payment of equal or greater value is given in return (i.e. fair market value)
In other words, if you accept a gift personally that was given to you where you do not provide payment for that gift equal (or more) to its value – it would be a gift.
Is there anyone I am not permitted to accept a gift from as a UConn employee?
Under the State Code of Ethics, there are certain groups of people that are considered “restricted donors”. These are people or entities that we are not typically permitted to accept gifts from. There are three specific groups that are restricted donors:
- Any vendor/contractor currently doing business with UConn, or who is seeking to do business with UConn;
- Any registered lobbyist with the State of Connecticut; and
- Any pre-qualified contractor with the Department of Administrative Services (DAS).
A vendor that frequently does business with the University just sent a large fruit basket to our office as a holiday gift. May we accept it or do we need to send it back?
A fruit or gift basket (valued at more than $10), while not acceptable if given to one person alone, may be accepted on behalf of an entire office if the per person cost will be reduced to less than $10. This makes the gift comply with the gift exception for items of $10 or less per person.
A vendor recently provided me with a gift that exceeds the permissible limits (an expensive tablet). Can I donate the gift to charity?
Yes, you can donate it to charity as long as you do not accept any personal tax credit for donating the gift. If you choose to do that, it is suggested that you document the charitable donation and retain it in your records. If the gift is not practical to donate, you may return it to the vendor. If the tablet could be used for University business, you could also keep the tablet for office business and it would be kept as property of UConn.
A vendor invited me to a customer appreciation event – is this something that I would be permitted to attend?
Attendance at a vendor’s event may be permissible, as long as you are mindful that gifts of food and beverage must total less than $50 in a calendar year and a representative from the vendor must be present at the event. Additionally, any other items given as gifts from a vendor must be less than $10 in value with an annual total less than $50. Therefore, if you have previously received a gift of food, beverage, or other items from this particular vendor within the year you will need to be mindful of whether or not the total amount of gifts would exceed the annual permissible limits.
Our department would like to recognize the Department Head for their service to the department. May the department get a gift for the Department Head?
Serving as a Department Head is certainly important to the University. While it would be permissible to purchase a gift for the Department Head, it would be important to note that the value of the gift cannot exceed $100.00 regardless of whether it is a group gift or individual gift. Additionally, the gift would need to be funded personally and not with University funds to ensure compliance with UConn’s Policy on Use of University Funds for Gifts, Social Functions, Sponsorships & Donations.
My supervisor just adopted a child. I would like to give him a special gift to celebrate this milestone occasion and support his family. Would it be permissible to give a gift even though he is my supervisor?
Yes. Gifts between supervisors and supervisees is generally permissible as long as the gift does not exceed $100. This is a per-gift limit. There is, however, an exception to the gift rules called the “Major Life Exception” that increases the value limit of a gift from $100 to $1000 per gift. The adoption and/or birth of a child meets the definition of a Major Life Event; therefore, it would be permissible to give a gift to your supervisor so long as the value of the gift does not exceed $1000.
What is considered a “Major Life Event” under the Gift Rules?
Per the State Code of Ethics, the following would be considered a major life event, and therefore the applicable exception to the gift rules would apply:
- Adoption and/or birth of a child
- Wedding/Marriage Ceremony
- Retirement from State Service
- Ceremony commemorating induction on into Religious Adulthood
Any other life event that falls outside of these five specific examples would not be considered a “major life event” under the gift rules and therefore, would not meet the exception.
My office is planning on coordinating a large gift to celebrate the major life event of our colleague. Specifically, they are getting married at the end of the month. I know the gift rules provide that the major life exception would apply and therefore a gift for this occasion cannot exceed $1000. A few of us are invited to the wedding shower as well as the actual wedding ceremony. Does the gift limit apply to each of these events or are they considered one event in total?
Excellent question. Per an Advisory Opinion from the Office of State Ethics, it would be considered one event in total. Therefore, the amount of gifts provided in celebration of the wedding, cannot exceed the $1000.00 limit. For example, if a gift valued at $200.00 is given at the wedding shower, any further gifts provided in celebration of the wedding cannot exceed $800.00. Remember, this is a per-gift limit regardless of whether it is a group gift or individual gift.
As a supervisor, I would like to take my staff out and treat them to dinner to celebrate the holidays. Would this be permissible to spend $250.00 on a dinner for my staff?
Yes – it would be important to ensure that the amount of the dinner per staff member not exceed $100. It would also be important to ensure you are also following UConn’s Policy on Use of University Funds for Gifts, Social Functions, Sponsorships & Donations.
I have been asked to make a speech at a conference concerning a project that I have been working on in my department. The conference is in California and the organizer of the conference has offered to pay the cost of my airfare, hotel, meals and conference fees, and pay me a stipend of $500. Can I accept this?
If you are actively participating in the conference (e.g., making a speech, presenting a paper, etc.), and your participation facilitates UConn business you may accept reimbursement for “necessary expenses” associated with your participation. This means that you may accept reimbursement for airfare (in coach class, not first class), lodging for the nights before, of and after the speech or presentation (standard room, not a suite), meals, and conference related fees (such as registration or for materials). You may not, however, personally accept an honorarium or stipend for your participation.
You must report reimbursement of “necessary expenses” to the Office of State Ethics within 30 days of receiving such reimbursement. To do so, complete the necessary expenses / gifts to the state disclosure form at https://www.oseapps.ct.gov/NewLobbyist/NecessaryExpenses/NEHome.aspx.
While I am at the conference, I was offered a water bottle and a pen at the registration table as were all other attendees of the conference. Can I accept the water bottle and pen or would that violate the gift rules?
If the estimated value of the water bottle and pen do not exceed $10.00, it would be permissible. These would be considered “token items” under the State Code of Ethics provided the annual total of such items from a single source is $50 or less.
While I’m at the conference, is it permissible for me to accept a round of golf or tickets to a show from the sponsor?
No. The cost of a round of golf, shows, spa treatments and the like are not considered “necessary expenses” and may not be accepted (unless, of course, they cost less than $10). Necessary Expenses do not include recreation or entertainment costs.
I believe that someone I work with is doing something that violates the State Code of Ethics. What do I do?
There are various options to report any suspected violations. You can always contact the Office of University Compliance directly to further discuss your concerns. You can also utilize the University’s Reportline, which provides the ability to report your concerns anonymously. The Reportline can be utilized through phone or submitting a web form online or using a mobile device. For more information about utilizing the Reportline, please click here.
You also have the option to report the concern directly with the Office of State Ethics. For more information on their reporting options, please see the Citizen’s Guide to Filing a Complaint. You can also submit the following Complaint Form with the Office of State Ethics.