Employee Handbook: Accepting gifts from clients

[Conner Lantz]

#81093

Is there any level of gift that is acceptable for a professional such as a financial advisor to receive from a client/member?
For example, a client/member expressing their appreciation of great service from an employee and offering a near cash gift card in a token amount for dinner out or even just a coffee card?
I’ve seen in some other companies that there is a generally accepted understanding that “gifts” of $100 or less in value are acceptable.
Our currently policy is strictly no gifts whatsoever, as receiving gifts from clients/members is seen to influence the standard of service or weaken the fiduciary relationship.
However, employees have suggested that accepting gifts in certain circumstances allows clients/members to express gratitude and strengthens the advisor- client relationship.

[Conner Lantz]

#81094

I agree with your employees. In addition, declining gifts may be taken as an insult, especially when dealing with foreign clients from countries where modest gifting is part of the business culture. I’d suggest instead that you allow them subject to specific limitations following the HRI Model Gifts Policy, https://hrinsider.ca/tool-model-gifts-acceptance-policy/
As for the so called “de minimus” threshold, there is no legally required dollar. Our Model Policy uses $100, which is consistent with standards followed in many corporations. There should also be aggregate limits and bans on accepting certain types of gifts, like cash or financial instruments. Again, check out the Model Policy. Also consider whether to require employees to report the gifts they receive, even the de minimis ones. Hope that helps. Glenn

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