I. System Office Guidelines on the Acceptance of Gifts

(Note: OLPM sections on this page may be cited following the format of, for example, "USA.III.G.1". These policies may be amended at any time, do not constitute an employment contract, and are provided here only for ease of reference and without any warranty of accuracy. See OLPM Main Menu for details.)

The USNH policy on conflict of interest (USY V.D.7, Conflict of Interest) does not directly address the question of whether a USNH employee can accept a gift (including, e.g., travel expenses, meals, entertainment opportunities, etc.) from a current or potential USNH business partner.  Even so, as a matter of practice USNH employees, and in particular employees at the executive level or with relevant decision-making authority, generally are very careful to avoid accepting anything that might be considered a personal gift from a vendor.  In addition, it is always important to consider the perceptions of a skeptical media outlet, state legislator, or citizen.

One useful decision-making exercise is to develop the bullet points to be used by our media relations people to defend the decision in the court of public opinion.  It is also important that before implementing the decision you alert anyone who would have to support the decision in the event it is challenged – likely that will include both the department head and the Chancellor.  And, if there is a potential for controversy, it is a good idea to document the decision and supporting rationale before you implement the decision.  To state the obvious, we work in highly-visible positions of public trust and any perceived breach of our duties as stewards of the public good will harm our relationships with key constituents including the campuses, the Board of Trustees, student and their parents, and the legislature.

Some key factors to include in the analysis:

  • The value to USNH of participating in the opportunity;
  • The total cost of the opportunity;
  • The extent to which the opportunity is beneficial to USNH versus a personally interesting/valuable experience;
  • The extent to which the opportunity may raise, or be seen as raising, the cost of services to students or employees (e.g., the offer of an affinity credit card that provides payments to the institution based on usage);
  • The public perception of the opportunity:  the extravagance, the location(s), the expense, the activities (i.e., the “boondoggle-appearance” test);
  • The USNH employee’s role relative to the engagement of the vendor and/or the management of the vendor relationship (i.e., will the public perceive the opportunity as potentially influencing your judgment?); and
  • If the opportunity is valuable to USNH and reasonably priced, why shouldn’t USNH pay for your participation and eliminate and question or appearance of conflict or impropriety?
This page last updated Thursday, September 1, 2016. For information on the adoption and effective dates of policies please see explanation on the OLPM Main Menu.