Many thanks for your question Erica. During review of our Conflict of Interest 
policy, we recently decided to develop a stand-alone policy on accepting gifts 
or hospitality. I similarly will be interested to see what others have done.


Karen Halverson Cross
Associate Director of Policy Management
Compliance, Audit & Advisory Services
Northwestern University

[] On Behalf Of Erica Heffner
Sent: August 8, 2017 7:24 AM
To: Association of College and University Policy Administrators 
Subject: [acupa-l] Gifts and Gratuities policies

Hello all,

I have a question regarding how your policies address potential gifts, 
gratuities or favors that could cause a conflict of interest, for example 
employees responsible for procurement contracts or similar situations.  Do you 
include such provisions as part of your conflict of interest policy, in your 
code of conduct, or do you have a stand-alone policy/procedure?  As part of a 
rewrite to our code of conduct, some of this content has been orphaned and 
we’re trying to find the best approach to communicate these restrictions.

Any examples would also be appreciated!



Erica Heffner, MEd, CCEP
Asst. Director Compliance Services
University of Vermont<>
p. (802)-656-1398

Ethics and Compliance Reporting and Help 
  or Toll Free (877) 310-0413

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