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Gifts and Gratuities

We never accept anything of value that may create a conflict of interest or suggest something improper.  Seek guidance from EA-Ethics if you are not sure about what is acceptable when it comes to giving or receiving gifts.

None of us should offer, give, solicit, or accept a bribe or kickback. Likewise, we may not solicit any gift or gratuity (i.e., anything of value) from a person or organization related to Triad or the Laboratory. Employees may, however, accept unsolicited nominal-valued gifts and ordinary business courtesies from those with whom Triad does business. Employees should take special care and review LANL’s applicable policies and procedures when giving or offering anything of value to federal or state government employees as special rules apply.

Questions regarding gifts or gratuities should be directed to EA-Ethics or Office of the General Counsel.

Summary of Policy

P722, Gifts and Gratuities, provides guidance on the acceptance of gifts and gratuities and establishes safeguard against the acceptance or offering of kickbacks.  The Laboratory is committed to conducting business transactions that are free from even the perception that favorable treatment was sought or received as the result of a gift, gratuity, entertainment, business courtesy, or similar transaction.

Do the Right Thing

  • Know the difference between what is acceptable and what is not by reviewing P722, Gifts and Gratuities, and/or contacting EA-Ethics for guidance.
  • Raise a concern if you suspect that a colleague, third party, or other Laboratory representative may be engaged in any attempt to improperly influence a procurement decision of a vendor or customer. You may report your concerns to your manager, EA-Ethics, or the Employee Concerns 24-Hour Hotline.
  • Cooperate with investigations into possible kickback violations or the improper acceptance of gifts and gratuities.
  • Do not accept a gift or gratuity that might be given to influence you or as a condition for something in return, such as a bribe, kickback, or pay off.
  • Do not accept cash, including gift cards, from a current or future Laboratory vendor.

 

Common Questions

No, this is not allowed.  Each Triad employee in attendance must pay for their own meal. Meals are only allowed when they are required for completion of a business meeting or are incidental to the meeting. In this case, the meal is not required for completion of the meeting and is not incidental to the meeting.

Laboratory policy on gifts and gratuities allows employees to accept certain items, including:

  • When required for completion of a business meeting or related event, employees may accept a nominal-valued meal on infrequent occasions. The meal should be incidental to the meeting or event. Meals affecting more than five employees require pre-approval from EA-Ethics.
  • Unsolicited advertising novelties or promotional material of a nominal value, such as pens, coffee mugs, hats, or calendars; or informational material such as books, reports, pamphlets or periodicals.
  • Modest entertainment, such as soft drinks, coffee, and doughnuts, in connection with attendance at widely-attended gatherings sponsored by commercial firms, professional societies, or persons with whom the Laboratory does business.
  • Transportation in customary form on official business.
  • Perishable food items such as tins of popcorn, boxes of candy, or cookies should be graciously discouraged, but need not be returned if they are of nominal value and can be shared by a Group, Division, or Directorate.
  • Employees do not have to seek approval for awards or prizes that are clearly offered because of an employee’s outside activities, are not related to Laboratory activities/duties, and cannot be perceived by others as related to Laboratory activities/duties.

Additional Resources:

  • P722, Gifts and Gratuities
  • EA-Ethics Conflict of Interest
  • Decision Tool for Gifts
  • EA–Ethics 7-7506 or coi@lanl.gov
  • Employee Concerns Program 24-hour Hotline: (844) 537-9524, https://lanl.ethicspoint.com
  • General Counsel 667-3376