Gifts/Gratuities and Expenses Paid by Vendors

Policy Number: 8.2.13
Effective Date: January 31, 2025
Revision History: February 28, 2023; Reviewed May 26, 2016
Policy Contact: Chief Human Resource Officer

I. Purpose and Policy Statement

GGC adheres to Board of Regents Policy Manual 8.2.18.4 Gratuities. When beneficial, GGC develops College-specific policies and procedures on gratuities and expenses paid by vendors to supplement the content in the BOR Policy Manual and the BOR HRAP.

II. Scope

This policy applies to all GGC employees.

III. Definitions

Gift: As provided in BOR Policy 8.2.18.4, a gift is lodging, transportation, personal services, a gratuity, subscription, membership, trip, loan, extension of credit, forgiveness of debt, advance or deposit of money, or anything of value. Note: a Gift does not include the actual and reasonable expenses for food, beverages, travel, lodging and registration provided to permit participation in a meeting, demonstration, or training related to official or professional duties if participation has been approved in writing by the President or their designee.

IV. GGC Approval of Expenses to be Paid by Third Parties

As noted above, a Gift does not include the actual and reasonable expenses for food, beverages, travel, lodging and registration provided by a vendor or third party to permit an employee’s participation in a meeting, demonstration, or training related to official or professional duties if approved in writing by the President or their designee.
Prior to granting this approval, GGC will ensure that payment of the employee expenses by a vendor or third party does not create the appearance of a conflict of interest, violate procurement rules, or serve to undermine the public’s confidence in the integrity of GGC. The process for employees to obtain approval in advance from the President or their designee for employee expenses that may be paid for by a GGC vendor, USG vendor, or other third party is set forth below.
1. GGC employees must obtain approval for expenses eligible to be paid by third parties in advance by completing and submitting the Approval Form - 3^rd Party/Vendor-Gratuities through their supervisor to the GGC Chief Audit Officer.

GGC Chief Audit Officer
gspence@ggc.edu
(678) 407-5993

The President has delegated approval authority under this policy to the GGC Chief Audit Officer.

Factors GGC will Consider in the Approval Process: In evaluating whether GGC will allow a third party to pay for employee expenses, the following factors will be considered:
1. Whether the training is related to the employee’s official or professional duties;
2. Whether the vendor is currently or is about to be involved in a procurement process with the USG or GGC;
3. Whether accepting the expense payment would violate procurement rules;
4. Whether the employee regularly interacts with, supervises, or could be involved in the selection process for the vendor;
5. Whether the meeting, demonstration, or training is designed as a marketing opportunity for the vendor, and the employee’s participation could be interpreted as an endorsement of the vendor;
6. Whether the employee will be participating in any of the presentations or have a role in the meeting or training other than attending;
7. Whether the circumstances are such that the appearance of a conflict of interest would be created; and,
8. Whether accepting the expense payment would undermine the public’s confidence in the integrity of the institution.

V. Guidance on Gifts

As a general rule, employees should not directly or indirectly accept Gifts from persons or organizations with whom the employee interacts with as part of their GGC responsibilities.
Some examples of Gifts from vendors, lobbyists, or other third parties that would violate this policy and/or state law include:
1. Cash, gift cards or similar items with a cash equivalent in any amount.
2. Tickets to entertainment events or experiences.
3. Use of a vendor’s car, vacation home, or other similar item.
Some items may be accepted by an employee. Examples of items that are excluded as Gifts include:
1. Promotional items such as those that might be available at a conference or meeting and would otherwise be generally available to the public.
2. A meal that does not exceed $100 in value, as established in BOR Policy 8.2.18.4.
3. Actual and reasonable expenses for food, beverages, travel, lodging, and registration provided to permit the employee’s participation in a meeting, demonstration, or training related to official or professional duties if participation has been approved in writing by the President or their designee (as described in more detail above).
Additionally, all employees should be aware that both USG policy and state law prohibit an employee from requesting or receiving a thing of value where the purpose of the gift is to influence the employee in the performance of their official duties.
For full details on all the gift exceptions, please review BOR Policy Manual 8.2.18.4 Gratuities

VI. Related Regulations, Statutes, Policies, and Procedures

BOR Policy Manual 8.2.18.4 Gratuities
BOR HRAP on Gratuities and Expenses Paid by Vendors
Forms: This form (available from HR) must be completed by GGC employees when seeking approval of items of value from a 3^rd party/vendor: GGC Approval Form - 3^rd Party/Vendor-Gratuities