All employees must act with integrity and good judgment and recognize that accepting personal gifts from suppliers may cause legitimate concerns about favoritism. Stevens prohibits the use of incentives and rebates for personal benefit. If you are a buyer for your department, it is important that you understand incentives and rebates and what to do if they are offered.
It is Stevens' policy to negotiate either quantity or trade discounts in lieu of accepting incentives or entering into rebate agreements with suppliers for all methods of purchase. Department buyers and others are not to accept either incentives or offers for rebates from a supplier. If a supplier proposes incentives or rebate agreements, refer the supplier to the Director of Purchasing.
Guidelines for all Employees
The federal Anti-Kickback Act of 1986 states that no officer or employee should solicit or accept any personal favor, gift, gratuity, or offer of entertainment directly or indirectly from supplier who is doing or seeking to do business with the university.
- Gifts and Gratuities - If you are a buyer or requestor for your department, report to your supervisor the offer or acceptance of any gift. If necessary, your supervisor will confer with the Office of University Risk and Compliance and/or University General Counsel to determine whether the offer or acceptance poses any problems or is contrary to University policies.
- Incentives - Incentives are deliberate enticements offered by a supplier to encourage a purchase. Incentives are tangible non-monetary benefits to the recipient and include any value-added goods and services offered at no charge to either the buyer or Stevens. Examples include (but are not limited to):
- Extra goods or services
- Tickets to an event
- Free merchandise
- Incentives are generally not accepted because it is inappropriate to accept either property or a service that is difficult to identify as tangible and administer it to the benefit of SIT.
- Rebates -Rebates are offers from the supplier either to return part of the cost of the order to the buyer or to provide additional consideration or compensation to encourage the purchase of goods and/or services. Examples include (but are not limited to):
- Cash or credit based on total purchases
- Value-added goods or services offered at a substantially reduced price
- Checks to either the buyer or the university
- If a manufacturer rebate is offered, either in the form of credits against future purchases or for goods or services at a substantially reduced cost on a purchase you make, practice requires that the rebate check is made payable to the Board of Trustees of Stevens Institute of Technology.
SIT "Code of Ethics (10.2.1)"
SIT "Conflict of Interest Policy (10.3.1)"
SIT "Financial Irregularities Policy (10.2.3)"
SIT "Conscientious Employee 'Whistleblower' Policy (10.2.2)"
SIT "Code of Business Ethics Program"
SIT "Purchasing Conduct and Ethics"
SIT "Anti-Kickback Statement of Guidelines and Procedures"
SIT "Employee-Vendor Relationships"
SIT "Accepting Gifts-Gratuities-Incentives and Rebates"
For more information or assistance, contact the Director of Purchasing