It’s the Most Wonderful Time of the Year for Some Guidelines on Giving and Receiving Gifts
Can you believe its already that time of the year again? When the weather starts getting colder, the ugly sweaters start showing up in force, Home Alone is playing on every channel, and associates are out shopping for awesome gifts for their bosses.
Wait a minute, that last one doesn’t seem right.
You’ve taken the super fun ethics training put out by the General Counsel’s office, but what did the ethics rules say about giving gifts to supervisors? Wasn’t there something about a $20 limit? Or was it $10? And how about contractors? Can you accept a gift from a contractor that you work with on a daily basis? Or what if that contractor invites you to her house for a holiday party? Can you accept? All your questions and more will be answered as we take a stroll down this year’s Holiday’s Guidance for Exchange Associates.
Let’s first talk about gifts between associates. Bob knows that Jill, his supervisor, loves cats. So one day, while shopping, he finds the cutest plushie cat. A glance at the price tag shows the cat to be $30. Wow, expensive, but hey, Jill’s been a great boss and Bob knows she’ll love it. So he buys the cat, wraps it up, and gives Jill the cat. Can she accept the gift of the plushie cat? It is Christmas after all, and wasn’t there some exception that allows supervisors to accept gifts during the holidays?
The rule Bob is thinking of is the exception that allows supervisors to accept non-cash gifts up to $10 on traditional gift-giving holidays. Here, Jill would not be allowed to accept the gift, since the plushie cat exceeds $10. Keep in mind, even pooling contributions for a holiday gift for a supervisor cannot exceed $10. This also means that any white-elephant gift exchanges involving supervisors need to be capped at $10. Furthermore, there are no restrictions on the amount supervisors may spend on gifts for subordinates (common sense and good taste should apply). Finally, personnel generally may attend holiday parties hosted personally by their superiors or subordinates.
As for contractors, the general gift rules apply, which means you may not accept gifts given due to your official position or from a prohibited source, unless an exception applies. One of these exceptions is the “$20/$50” rule, which allows associates to accept gifts not exceeding $20, as long as the total amount of gifts that the individual accepts from that source does not exceed $50 for the year. But what if a contractor invites you to their holiday party? Unfortunately, there is no “holiday party exception” to the ethics rules for accepting free attendance at events hosted by contractors and other non-federal organizations.
Some final miscellaneous rules to keep in mind:
- Exchange funds may not be used to purchase and send greeting cards
- Door prizes or drawings where individuals purchase a chance to win something constitute gambling and are thus prohibited on federal property
- Participating at holiday social events is personal, not official, and therefore use of a government vehicle is not authorized
- Contractors may have their own ethics rules and policies, so consider these rules before offering contractor-associates gifts they may not be able to accept.
Happy Holidays and see you again next year!
Great article Daniel!