Gift Registry Procedures

Purpose

The purpose of these Procedures is to establish a process for reporting Gifts received by Employees and documenting those gifts to ensure compliance with the Code of Ethical Conduct.

Definitions

For the purposes of these Procedures the following definitions apply:

“Donation” means a voluntary gift of cash and/or in-kind, given to the benefit of the University. Donations are not considered Gifts under this Policy, and will be accepted in accordance with the University’s Gift Acceptance Policy.

“Employees” means individuals, including students, who are employed by the University or holding an appointment with the University including paid, unpaid and/or honorific appointments.

“External Funding and Awards” means grants and funding such as research grants, fellowships, awards or honors that are awarded to an individual for academic merit and not administered by the University. These honors are not considered Gifts for the purposes of this Policy.

“Gift” means anything of value, including cash, cash equivalents, items, hospitality, entertainment or goods given to an Employee by an external party in connection with an Employee’s University responsibilities or position. For further clarity, External Funding and Awards, Expenses for Outside Activities, Donations and University Administered Funding, are not considered Gifts.

“University Administered Funding” means grants and funding such as research grants, fellowships, awards or honors that are awarded to an individual or a research project, and administered by the University in accordance with applicable research finance procedures. This type of funding is not considered a Gift for the purposes of this policy.

Scope and authority

These Procedures apply to Employees of the University.

The University Secretary and General Counsel, or successor thereof, is the Policy Owner and is responsible for overseeing the implementation, administration and interpretation of these Procedures.

Procedures

Responsibilities

1. Office of the General Counsel is responsible for:
   1. Developing an online form for submission of Gift details and maintaining a Registry of Gifts.
   2. Providing advice to supervisors on the acceptance of Gifts.
   3. Annual compliance reporting under these procedures.
2. Unit Supervisor is responsible for:
   1. Reviewing Gifts reported by their Employees.
   2. Determining whether Gifts are consistent with the Ethical Conduct Policy.
3. Employees are responsible for:
   1. Reporting Gifts received using the prescribed means.
   2. Understanding the rules regarding acceptable Gifts under the Ethical Conduct Policy and seeking advice when necessary.

Reporting of Gifts

1. All Gifts will be reported to an Employee’s immediate supervisor prior to accepting or as soon as possible afterward. The supervisor will determine if the Gift is consistent with section 15 of the Ethical Conduct Policy. The supervisor will consider whether:
   1. The Gift is a Donation that can be accepted in accordance with the Gift Acceptance Policy.
   2. The value of the Gift is nominal.
   3. The Employee is directly involved in transactions or other activities with the source that would give rise to a perceived Conflict of Interest.
   4. The Employee’s attendance at an event would be of benefit to the University due to increased public profile, training or development of the Employee, or strengthening of institutional partnerships.
   5. The Gift is consistent with the requirements of the Procurement Policy, related procedures and the Supply Chain Code of Ethics.
   6. Hospitality would be otherwise allowable as a business expense claim under the University’s Expense Policy and Procedure.
2. Gifts inconsistent with section 15 of the Ethical Conduct Policy should not be accepted, or, if accepted, should be returned. Where returning a Gift would be considered a breach of protocol or would give offense, disposal by donation to a non-profit organization or similar should be considered. These Gifts should be reported to the Office of the General Counsel within a month of receipt.
3. Hospitality inconsistent with section 16 of the Ethical Conduct Policy should not be accepted.
4. A supervisor may contact the Office of the General Counsel for advice when making determinations based on sections 15 or 16 of the Ethical Conduct Policy.

Registry of Gifts

1. The Office of the General Counsel will maintain a Registry of Gifts to track Gifts received by Employees that are more than nominal in nature.
2. The Office of the General Counsel will create an online form for submitting information on Gifts that are more than nominal received by Employees. The following information is required:
   1. Value (or estimated value) of Gift
   2. Type of Gift
   3. Source of Gift
   4. Date of Gift
   5. Recipient of Gift
   6. Unit of Recipient
   7. Supervisor
   8. Disposition of Gift
3. Gifts should be reported to the Office of the General Counsel within a month of receipt.
4. An annual report on Gifts received will be submitted by the Office of the General Counsel to the Audit and Finance Committee as part of compliance reporting.

Monitoring and review

These Procedures will be reviewed as necessary and at least every three years. The Policy Advisor, or successor thereof, is responsible to monitor and review these Procedures.

Relevant legislation

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Related policies, procedures & documents

Code of Ethical Conduct Policy
Code of Ethical Conduct Investigation Procedure
Procurement of Goods and Services Policy and Procedure

Supply Chain Code of Ethics