Rowan University Office of Compliance and Corporate Integrity
There are University and State policies governing the acceptance of gifts to State employees.(LINK)
Unsolicited gifts or items of trivial or nominal value, such as complimentary articles offered to the public in general, and gifts received as a result of mass advertising mailings to the general business public may be retained by the recipient or the recipient's department for general use if such use does not create an impression of a conflict of interest or a violation of the public trust.
An impression of a conflict may be created, for example, if an employee of a regulatory agency uses a pocket calendar conspicuously marked with the name of a company that it regulates or if an office in a State agency displays a wall calendar from a vendor, creating the impression of an endorsement. If circumstances exist which create a reasonable doubt as to the intention with which the gift or benefit was offered, the other paragraphs of these Guidelines govern.
All officers and employees should be instructed that any gift or other thing of value offered to or by an officer or employee that is related in any way to his/her public duties must be reported and remitted immediately to the Chief Compliance & Privacy Officer. Similarly, any favor, service, employment or offer of employment from such person or corporation must be reported immediately.
The Office of Compliance & Corporate Integrity's (OCCI) Procedure for returning/donating gifts is as follows:
- Employees are instructed to send non-perishable gifts via interoffice mail to the RowanSOM Office of Compliance and Corporate Integrity, 40 East Laurel Road, UEC Bldg. Suite #1031, Stratford, NJ 08084. In addition to the gift the employee should include the recipient's name, interoffice mailing address, title, and department, the date the gift was received from donor, and the donor's name and address.
- Employees are instructed to donate perishable gifts to a charitable organization in the vicinity of your campus that you do not hold an interest in, i.e., you and/or your immediate family are not a member, or on the board of the organization. Please contact the Assistant Compliance Officer at 856-566-6120 to obtain a list of charitable organizations. In addition the employee should send an email to: email@example.com which includes the recipient's name, interoffice mailing address, title, and department, the date the gift was received from donor, and the donor's name and address.
- Upon receipt of the above, a letter is sent out to the donor, with a copy to the recipient, from the Assistant Compliance Officer, informing the donor that State employees are prohibited from accepting gifts during their employment at RowanSOM. Whenever practicable, non-perishable items are returned to the donor by means of FedEx for tracking purposes.
- The Office of Compliance & Corporate Integrity maintains a database of all gifts returned/donated, as well as copies of the letters that were sent to donors.
Frequestly Asked Questions
1). May I keep nominal fee items and what types are they?
Answer: Yes. Pens and mugs that are provided at the events are considered nominal.
2). Can we provide prescription vendor's discount cards to patients?
Answer: No, you cannot provide vendor's discount cards to the patients. It would give appearance that we are supporting that vendor.