Acceptance or Conveyance of Gratuities, Gifts and Favors


AUI employees shall not give or accept gifts, gratuities or special favors of any substantive value to or from any party with whom AUI conducts or is considering establishing a business relationship. When gifts, gratuities or special favors of nominal value are conveyed or received by employees, such exchanges shall be governed by the following guidelines:

  1. Ordinary business courtesies, such as payment for a modest lunch or dinner in connection with a business meeting are permitted provided that employees make reasonable efforts to keep such courtesies on a reciprocal basis, to the extent practicable, in order to demonstrate that no special favor is sought or granted.
  2. Retention of advertising novelties is permitted, provided the item has no appreciable value and is widely distributed to others having the same sort of business relationship with the donor.
  3. Offers by present or potential suppliers or contractors to provide expense-paid trips, whether for business or pleasure, must be declined. Authorized expenses for business trips to a supplier or subcontractor facility or other destination are to be paid by AUI in accordance with established business travel policy.
  4. When an employee has a close personal or familial relationship with a person representing a supplier or subcontractor, the employee must identify the situation to his/her supervisor and disqualify himself/herself from participating in the decision-making process involving that supplier or subcontractor.

AUI employees must comply with all regulations concerning the offering of gifts, favors, gratuities and entertainment to government employees. Accordingly, AUI employees who have business relationships with government personnel are expected to be familiar with pertinent regulations. While it is recognized that such regulations may allow government employees some discretion in accepting such items of nominal value, it is imperative that AUI employees do not place government personnel in situations that could be mistakenly interpreted as contravening these regulations.