Sandia LabNews

Navigating gift exchanges during the holidays


Ethics at Sandia

The holiday season has begun, and Sandians have started thinking about the perfect gifts for co-workers, friends and families. Before browsing online or braving the mall to purchase a gift for an upcoming office party, keep a few things in mind. 

Giving and receiving personal gifts in the workplace is a great way to express thoughtfulness and thanks. Sandians should remember the rules listed below if they choose to exchange gifts with co-workers. These rules apply to gift exchanges among employees, but different rules apply when giving a gift to a colleague who works outside Sandia. Other employees are limited by their employer’s rules. For example, federal government employees are limited to accepting gifts that are $20 or less, not to exceed $50 in one year from Sandia. Giving gifts to foreign officials, foreign firm employees or their families can be complicated, so consult legal and the prime contract in these situations.

Finally, during the holiday season, giving or receiving business courtesies may become more prevalent. The guiding principle in these situations is to ensure business courtesies are not made with the intention of influencing the recipient. Sandia highly restricts its procurement personnel in this regard, as business transactions and relationships should be free from even the appearance of favorable treatment. It’s always best to consult IAEB003, Exchange of Business Courtesies, Gifts, Hospitality, and Honoraria Policy, or contact Ethics and Equal Employment Opportunity Advisory and Investigative Services at 505-845-9900 or ethicsteam@sandia.gov with specific questions on what you can give or receive.

The holidays are a great opportunity to reflect on and celebrate our organizational accomplishments and our work friendships. Remember these gift giving rules when enjoying end-of-year festivities.

Ethics accomplishments

In fiscal year 2021, the Ethics and Equal Employment Opportunity office received 756 calls on its anonymous helpline. The majority of those calls were resolved informally by Ethics officers providing guidance to callers or conducting a brief inquiry into complaints to determine if a policy or code violation occurred. During fiscal year 2021, the Ethics and Equal Employment Opportunity team opened 71 investigations into 82 allegations. Investigations sometimes include more than one allegation, and decisions are reached on each allegation investigated. See the graphic for the outcome of the 82 allegations investigated. Corrective actions were the result of all substantiated allegations.

Graphic by Stephanie Blackwell

Gift-giving reminders

Gift-giving should never be coercive. If you are organizing a gift exchange, please be sure participation is voluntary. No one should feel pressured to participate if they don’t want to.

Gifts should never be solicited. While it’s nice to get something you really want, please don’t ever pressure someone to purchase a gift for you.

Use your own money. Personal gifts need to be paid for with personal funds or resources.

Gifts need to be of nominal value.

Limit any use of Sandia IT resources to plan holiday parties and gift exchanges. If your team is getting together for some online festivities, do so using personal technology platforms.

Consider any conflict of interest. A conflict of interest exists when giving a gift or receiving a gift compromises an employee’s judgment or creates actual or perceived favoritism. While not prohibited, gifts between managers and employees could create a conflict of interest. Please use caution in these circumstances. Managers, however, may recognize their organizational or team achievements through NTESS Fee. Consult FIN012, NTESS Fee Policy, and your ALD’s office for their specific approval process.

Contact the Ethics and Equal Employment Opportunity Advisory and Investigative Services.

If in doubt, reach out to Ethics with questions.

505-845-9900 • ethicsteam@sandia.gov