TCDSB Policy Register   

ACCEPTANCE OF HOSPITALITY OR GIFTS H.M.33   

Policy:

It is the policy of the Toronto Catholic District School Board that elected officials and employees may only accept and retain gifts of low intrinsic value or business hospitality of less than $100.00 per person.  If in the circumstances that hospitality or a gift of considerable value is received, notification according to regulation 5 is required.

The Board acknowledges that the offering of gifts or hospitality of limited value from suppliers, partners or other business contacts is a common business practice which may be appropriate under certain circumstances.

Elected officials and employees may accept a gift provided it does not create a sense of obligation, expectation or indebtedness or a real, or the appearance of, a conflict of interest that may be seen to be likely to affect the objectivity of those officials and employees in the performance of their duties.

Philanthropic gifts made by individuals, corporations, foundations or legal entities to assist the Board in the pursuit of its mission may be accepted at the discretion of the Director of Education or Board of Trustees.

Definitions:

A gift or benefit is considered to be anything of value received as the result of a business relationship for which the recipient does not pay fair market value.  Gifts or benefit refers to items both tangible and intangible such as hard goods, entertainment, trips, financial instruments and services other than hospitality offered directly or indirectly to an elected official or employee of the Board.

Gifts of Considerable Value are defined as any gift, benefit or hospitality whose value exceeds $100.00.

Hospitality is the offering of meals, refreshments, entertainment, and transportation. 

Regulations:

1.                  The acceptance of gifts, hospitality and other benefits is permissible provided that:

(i)                  they are infrequent and of minimal value (low-cost promotional objects, simple meals, souvenirs with no cash value) and are within the normal standards of business practice; and

(ii)                they do not obligate or compromise the integrity of the recipient or the Board.

2.                  Gifts and benefits to an immediate family member or close associate of an elected official or employee, which can be reasonably attributed to the employee's official duties or association with the Board are prohibited.

3.                  An elected official or employee may accept moderate hospitality during the normal course of business that would not significantly exceed what the Board would likely approve on an individual’s expense account form.

4.                  Acceptance of a gift or hospitality must be legal and consistent with generally accepted ethical standards relevant to the person’s position.

5.                  Notification Requirement:

Employees must notify by e-mail their immediate supervisor of any gifts or hospitality received with a nominal value of more than $100; in the case of trustees, the Director of Education or designate; the Chair of the Board should receive notification of gifts or hospitality received by the Director of Education.

6.                  Gifts of Considerable Value:

Where it would be inappropriate to refuse a gift of obvious value, the gift may be accepted on behalf of the TCDSB and donated to the Angel Foundation for Learning unless directed otherwise by the Director of Education /Board of Trustees.

7.                  Charity Events:

Where the hospitality/gift offered to an elected official or employee is for attending a charity event with an ongoing relationship to the Board, the employee may accept. The elected official or employee may only accept from any one supplier once per year. The number of events attended must be reasonable and appropriate to practice within the sector.

8.                  Non Charity Events

No elected official or employee shall accept hospitality/gifts to non charity events such as sporting or cultural events from any individual or organization doing business with the Board without obtaining prior approval from their immediate supervisor or in the case of trustees, the Director of Education or designate.  The number of events attended must be reasonable and appropriate to practice within the sector.

9.                  Solicitation of Gifts or Sponsorship

(i)               Board officials or employees shall not solicit hospitality, gifts, benefits or sponsorships for their personal benefit from any individual, company or organization that have an existing or potential business relationship with the Board.

(ii)                For special Board functions, the Director of Education may approve the solicitation of gifts, prizes or donations from companies or organizations with whom the Board is not currently involved in a competitive acquisition process and provided that the  donation or gift is legal and  does not  place the Board under any obligation or in a conflict of interest.

10.              Exceptions to this policy and resolution of any dispute arising shall be at the discretion of the Director for staff and the Board in the case of trustees in private session.