Under Title 19, NYCRR, Part 933, Gift Regulations for Public Officers, employees are prohibited from soliciting or accepting gifts of more than nominal value when it may be reasonably inferred that the gift:

  • is intended to influence them, or
  • could reasonably be expected to influence them in the performance of their official duties, or
  • is intended as a reward for any official action, or
  • is from an interested source. A gift from an interested source is presumptively prohibited. An interested source is defined as a person or entity that has certain dealings or involvement with an individual’s agency; has contracts with, or seeks contracts with, you or your agency; is a registered lobbyist or client of a lobbyist that lobbies your agency; is the spouse or minor child of a registered lobbyist; is involved in ongoing litigation that is adverse to Purchase College; has received or applied for funds from Purchase College at any time during the previous year, up to and including the date of the proposed or actual receipt of the funds; attempts to influence Purchase College in an official action.

Purchase College employees must adopt an attitude and mode of operation that is above criticism and avoid any type of conduct that would give any suggestion of a conflict of interest. The value of a gift is the retail cost to purchase it; the value of a ticket entitling you to food, refreshments, entertainment, etc. is the face value of the ticket; if no value is indicated, the value is the actual cost to the giver. The offer of reciprocity, or even actual reciprocity, does not reduce the value of a gift given to you. You may not designate a friend, family member, or entity (for example, a charity) to receive a gift that you cannot receive.

The underlying principle is the same for multiple gifts, even of nominal value, from a single source given over a 12-month period. Employees “must strive to avoid creating any appearance that would suggest that they are being improperly influenced in discharging their public responsibilities by refusing multiple nominal gifts from the same donor.”