Ethics Guide
Kickbacks and Gratuities
A kickback is a gift with a string attached. There is an expectation of favorable treatment in return for the gift. It can include: meals, money, souvenirs, gift certificates, invitations to attend or participate in any entertainment, sporting, hunting, or other event, or any other item of any value.
A gratuity is a kickback without the string attached. It includes anything that has monetary value including all those listed above.
Some things to be mindful of:
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Don't accept kickbacks from anyone offering or providing goods or services to the Foundation. |
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Don't offer kickbacks to anyone who works for a customer to whom HJF provides (or proposes to provide) goods or services. |
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Don't accept gratuities (gifts) from anyone offering or providing goods or services to the Foundation EXCEPT if the gratutity is a meal, souvenir, momento, or promotional item of nominal value. (Less than $25 per occasion AND does not exceed $75 per year from the same company.) |
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Don't offer any gratuities (gifts) to Government Employees EXCEPT if there has been prior approval of the Business Conduct Officer. |
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Don't offer gratuities to customers or higher-tiered contractors EXCEPT with prior approval of the Business Conduct Officer |