ACCEPTANCE OF GIFTS FROM EXTERNAL ENTITIES POLICY (A1515) 08-21-2019.PDF

MARICOPA COUNTY INTERNAL POLICY
Policy Title:
Policy Number: A1515
ACCEPTANCE OF GIFTS FROM
EXTERNAL ENTITIES Current Adoption Date: 08-21-2019
Current Implementation Date: 08-21-2019
Approved by: Board Agenda Number: C-49-13-026-6-01
BOARD OF SUPERVISORS
Original Adoption Date: 11-14-2012
I. PURPOSE
To outline expectations for employees interacting in their official capacity with organizations or
individuals in order to maintain impartiality, public trust, and compliance with the law.
II. AUTHORITY
This Policy is authorized by the Board of Supervisors pursuant to A.R.S. § 11-251.
III. APPLICATION
This Policy applies to all employees of Maricopa County appointed departments as well as the
Flood Control District of Maricopa County and the Maricopa County Library District (Special
Districts). The Board of Supervisors is authorized to jointly adopt policies applying to the Special
Districts under the Intergovernmental Agreement, C-06-18-393-6-00, approved on April 11, 2018.
This Policy also applies to employees of County elected offices unless the elected official has
implemented a similar policy specific to his or her office.
IV. DEFINITIONS
A. Appointing Authority: An elected official, the single administrative or executive head of a
department or the designated representative authorized to act in this capacity.
B. Chief Officer: Deputy County Manager, Assistant County Manager, Director of Procurement
Services, County Internal Auditor, Clerk of the Board, County Manager or the Chief Deputy of
an elected office.
C. Conflict of Interest: Participating in a decision about a matter or exercising control over another
person participating in a decision about a matter (e.g., any contract or arrangement of
employment, leasing, sale or provision of goods and services) which may personally benefit or
be seen to benefit that person because of actions or decisions made in an official capacity.
Situations that may give rise to a Conflict of Interest include but are not limited to: nepotism, an
external business relationship, or a close personal relationship.
D. Donation: The receipt of something of value voluntarily transferred by a person or entity to a
County department or special district without compensation as outlined in A2508 Receiving
Donations Policy.
E. Employee: A person paid a wage, salary, or stipend in accordance with official County payroll
entries. For purposes of this Policy, this includes all classified, unclassified, temporary, and
contract employees as well as volunteers.
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Policy Title:
Policy Number: A1515
ACCEPTANCE OF GIFTS FROM EXTERNAL
ENTITIES Current Adoption Date: 08-21-2019
F. External Entity: Any corporation partnership, individual, sole proprietorship, joint stock
company, joint venture, union, committee, organization, group of individuals or any other private
legal entity (including any of its employees) that is directly affected by a service an Employee
provides and/or would benefit by selling commodities or services, or influencing the County’s
behavior or decisions. It includes individuals or entities that 1) are regulated by the County, 2)
do business or seeks to do business directly with the County, 3) attempt to lobby or influence
any action by the County, 4) are involved in adverse litigation to the County, 5) have received
or applied for funds from the County, or 6) have applied for employment with the County. This
does not include organizations to which the County subscribes or is a member.
G. Gift: Anything of value from an external entity.
H. Volunteer: A person who, of their free will, provides services to the County without receiving a
wage, salary, stipend, or other County benefit.
V. POLICY
Employees shall not accept things of value or benefit that would create a real or perceived Conflict
of Interest.
A. Employees May Accept the Following:
1. Discounts and similar benefits sponsored through and/or contracted by the County such as
those provided by the County’s employee discount program.
2. Personal or private business loans from financial institutions doing business with the County
where the loans are based on customary terms generally available to the public.
3. Unsolicited advertising or promotional material such as pens, pencils, calendars, and other
items of nominal value from an External Entity or other organization.
4. Unsolicited perishables from an External Entity, individual or group that are made available
to all Employees within the work unit and are placed in the Employee lounge or general
office area.
5. Awards for meritorious public service or honorary degrees given without remuneration. The
Employee shall obtain approval from the Appointing Authority prior to acceptance, when
possible, of any awards or honorary degrees awarded by contracted entities.
6. Food, shuttle services, or other items underwritten by a sponsor of a conference or training
event generally available to the public or other attendees and only if the Employee’s
attendance is seen to further the County’s mission.
7. Subject to Section V.B.5., admission to an event, conference, activity or honorarium,
speaking fees, travel expenses, or food which benefits the County subject to the following
principle: employees shall not accept any valuable item or benefit that would cast
reasonable doubt or suspicion upon themselves or the County.
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Policy Title:
Policy Number: A1515
ACCEPTANCE OF GIFTS FROM EXTERNAL
ENTITIES Current Adoption Date: 08-21-2019
a. Employee attendance at an event, honorarium, speaking fee, travel expense, or food
that benefits the County must be approved prior to the event by the Employee’s Chief
Officer.
b. Justification for the benefit must be in writing, signed by the Chief Officer and a copy of
the form shall be kept in the Employee’s personnel file and on file in the department for
audit purposes.
c. Elected officials are encouraged to submit a disclosure of these events to the Clerk of
the Board.
8. Anything given by a friend or family member of the Employee when it is clear that the
motivation for giving is because of the friendship or family relationship and not the recipient's
official County position. Factors to consider include whether the relationship existed before
the recipient became an Employee and whether gifts have been previously exchanged.
9. Contributions or benefits permitted by law and the PhRMA Code of Interactions with
healthcare professionals.
B. Unless Permitted by Policy, Employees Shall Not Accept any of the Following from
External Entities Regardless of the Value:
1. Food
2. Gifts or gratuities
3. Tickets or complimentary admittance to an event (e.g., admission to conferences, trade
shows, concerts, and sporting or promotional events)
4. Donation in any form until the requirements of A2508 Receiving Donations have been
fulfilled
5. Honorariums, speaking fees, travel expenses, food, or other forms of remunerations for
attending events that could be perceived as benefiting an External Entity and do not benefit
the County
C. Other Conduct Regarding External Entities:
1. Employees shall not provide endorsements for or against External Entities. However, with
department authorization, Employees may respond in reference to communications
regarding an External Entity.
2. Employees shall not show favoritism for or against an External Entity regarding access to
staff or information.
3. In accordance with the A.R.S.§ 38-501 through 505 and the Maricopa County Employee
Merit System Rule 11 – Code of Ethics, Employees shall declare all Conflicts of Interest or
potential Conflicts of Interest before participating in any activity that may call into question
their ability to make an unbiased decision. Employees who are uncertain if a Conflict of
Interest exists should make the declaration.
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Policy Title:
Policy Number: A1515
ACCEPTANCE OF GIFTS FROM EXTERNAL
ENTITIES Current Adoption Date: 08-21-2019
4. Employees shall treat External Entities with respect and in a way that reflects positively on
the County.
VI. REPORTING REQUIREMENT
Employees are required to report conduct that may violate this Policy. Employees who have
questions about interactions that may be covered by this Policy are expected to consult with their
supervisor prior to taking any action. Reporting may be in any form accessible to an Employee and
may include:
A. Notification to an Employee’s immediate supervisor who will report the concerns through the
appropriate organizational management hierarchy.
B. Submitting a written account of specific concerns to the Employee’s Chief Officer for review.
Revision History
Revision
Version Date Description of Revision
1 11/14/2012 Initial version (C-49-13-026-6-00)
Retitles policy and updated definitions, format, and language for consistency
2 08/21/2019
throughout policy (C-49-13-026-6-01)
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