Gifts, Favours and Donations

Policy

Category: Human Resources
Subject: Gifts, Favours and Donations
Division: Administrative Services
Policy Number: CA.52.01.119
Effective Date: January 30, 2017

POLICY STATEMENT

Wellington-Dufferin-Guelph Public Health (WDGPH) does not accept gifts, favours and/or donations that require the Agency to provide consideration to the person or group providing the gifts, favours or donations. WDGPH does not provide gifts, favours and/or donations to person(s) or group(s) in order to obtain consideration for the Agency in any areas or activities when doing business or providing services.

Consideration may include, but is not limited to, the areas of employment, financial and/or personal gain, procurement, medical supplies and services, Agency, personal or client information. The Agency also does not accept gifts, favours and/or donations that involve unlawful discrimination or conflict with any provisions of law. 

What is a conflict?

It is not always easy to identify what is a conflict and what is not a conflict. One of the easiest tests to determine if a conflict exists is to simply ask oneself if publically disclosing a gift, favour or donation would result in personal humiliation and/or harm the reputation of WDGPH with the public. If the answer to either question is yes, it is likely that a conflict of interest exists.

Employees of WDGPH are in conflict if they accept any monetary payment or compensation, a gift that is not of nominal value (total value of all items less than $50.00), entertainment, hospitality or other favour, or donation from any person or group doing business with WDGPH. In addition, an employee may be in conflict if their relatives or an individual with whom the employee has a close person relationship accepts what is deemed to be a gift, favour or donation that puts the employee in conflict with their responsibilities to WDGPH.

Accepting a gift that is not of nominal value, favour and/or donation from any person or group may be a conflict if a reasonable person might conclude that the gift and/or donation could influence an individual at WDGPH when performing their duties at the Agency with:

  • a person or group that has dealings with WDGPH;
  • a person or group to whom the employee provides services in the course of their duties to WDGPH; or
  • a person or group that seeks to do business with WDGPH.

An employee who is offered a gift in these circumstances shall, in writing, notify their immediate supervisor. Refer to form CA.30.01.107 Disclosure of Gifts, Favours and Donations Conflicts.

What may not be a conflict?

In specific cases, an employee of WDGPH may receive an item of nominal value (total value of all items less than $50.00) given as an expression of courtesy or hospitality if doing so is reasonable in the circumstances and there is no requirement (either formally or implied) from the other party to do so. Examples of this may be promotional marketing trinkets such as nominal value marketing items (i.e. stuffed animals, hats, pens, etc.) as well as product samples for procurement evaluation approved or coordinated by procurement, or nominal non-alcoholic food items (i.e. coffee, etc.).   

What should you do if you are unclear?

An employee who is unclear about accepting or giving any gift, favour or donation should contact their immediate manager, director, or Human Resources for guidance.

Compliance

Failure to comply with the terms of this policy or failure to disclose a conflict of interest may result in disciplinary action in accordance with policy CA.52.01.142 Progressive Discipline.

SCOPE

The policy applies to all employees of WDGPH.

DEFINITIONS

Management – includes the Medical Officer of Health, directors, managers and other managerial employees who are part of the management team employed by WDGPH

Employee – applies to all full-time, regular part-time, casual, and contract employees who are employed by WDGPH. Students, volunteers, agents and consultants are not considered employees of WDGPH.

Relatives or personal relationship – means any relationship to persons including immediate family whether related by blood, adoption, marriage, or common-law relationship, and any relationship of an intimate and/or financial nature during the preceding five years, any supervisor relationship, or any other past or present relationship that may give rise to a reasonable apprehension of bias.

REFERENCES AND RELATED FORMS, POLICIES AND PROCEDURES

Corresponding Procedure: CA.52.02.119 Gifts, Favours and Donations
CA.52.01.142  Progressive Discipline
CA.30.01.107 Disclosure of Gifts, Favours and Donations Conflicts

CONTACT FOR INQUIRIES

Manager, Human Resources

APPROVED BY

Director, Administrative Services 


Procedure

Category: Human Resources
Subject: Gifts, Favours and Donations
Division: Administrative Services
Procedure Number: CA.52.02.119
Effective Date: January 30, 2017

PROCEDURE

All Wellington-Dufferin-Guelph Public Health (WDGPH) employees, as identified in policy CA.52.01.119 Gifts, Favours and Donations, have an obligation to disclose to their immediate supervisor any gifts, favours and donations that may be a potential, perceived or actual conflict of interest. This includes gifts, favours and donations valued at $50.00 or more. Gifts, favours and donations valued at less them $50.00 may need to be reported if there is a conflict that may have significant impact on the Agency.

Reporting the offer or receipt of gifts, favours and donations that may be a conflict:
  1. The employee must consult with their immediate supervisor as soon as possible regarding any offer or receipt of gifts, favours and/or donations that may result in a potential, perceived or actual conflict of interest.
  2. The employee must disclose in writing the details of the conflict by completing a CA.30.01.107 Disclosure of Gifts, Favours and Donations Conflicts form.
  3. The individual must provide all information regarding the conflict and a proposed action plan to deal with the conflict.
  4. The immediate supervisor will review the completed CA.30.01.107 Disclosure of Gifts, Favours, and Donations Conflicts form and meet with the individual to further discuss the conflict and action plan if required.
  5. The immediate supervisor may change or add to the action plan if necessary to ensure the plan safeguards the interests of WDGPH.
  6. Once the action plan has been approved by the immediate supervisor, they will forward the form to the division director. 
  7. The division director will review and if required change or add to the action plan to ensure the plan safeguards the interests of WDGPH.
  8. The division director will advise the Medical Officer of Health (MOH) only if there is a serious conflict that may have a significant impact on WDGPH.
  9. Where a conflict arises at the division director level, the director will complete form CA.30.01.107 Disclosure of Gifts, Favours and Donations Conflicts and forward to the MOH for review and approval of the action plan.
  10. The MOH will meet with the division director to discuss the conflict, change and/or add to the action plan if required any safeguards in the interest of WDGPH if required.
  11. When a conflict arises with the MOH, the MOH will complete the form CA.30.01.107 Disclosure of Gifts, Favours and Donations Conflicts and submit it to the Human Resources Committee of the Board of Health for review and approval of the action taken.

If the supervisor to whom the disclosure is made also has a conflict, the disclosure should be made, in writing, to the person at the next highest level of authority.

Where appropriate, the supervisor or individual may consult with higher level management and/or Human Resources.  

RESPONSIBILITIES

Management at all levels of WDGPH must:
  • Understand and promote the policy CA.52.01.119 Gifts, Favours and Donations; and
  • Ensure compliance by all persons or groups and take the appropriate disciplinary action if required.
Employees must:
  • Understand and follow the policy CA.52.01.119 Gifts, Favours and Donations; and
  • Identify and discuss any areas of concern pertaining to gifts and/or donations with their supervisor as soon as they become aware of an issue.

REFERENCES AND RELATED FORMS, POLICIES AND PROCEDURES

Corresponding Policy: CA.52.01.119 Gifts, Favours and Donations

CONTACT FOR INQUIRIES

Manager, Human Resources

APPROVED BY

Director, Administrative Services