City bosses should beware this holiday season — accepting presents from underlings can land you on the naughty list, the Conflicts of Interest Board said Thursday in a memo reminding all municipal employees of the rules.
“It will violate the conflicts of interest law for a superior to accept a gift from a subordinate, except on special occasions,” the COIB advisory states.
The advisory makes a distinction between “special occasions” like a wedding or birth and “annual events” like Christmas or a birthday – with only “gifts of smaller value” allowed on the more frequent dates.
As a helpful guideline, the COIB advisory reminds city workers that federal regulations only allow Christmas presents to bosses “if the gift has a value of $10 or less.”
With that limit a city worker could buy their boss a six-pack of Budweiser cans but not a pack of Marlboro cigarettes.
A supervisor could accept a gift for a “wedding or the birth or adoption of a child” so long as the gift is an appropriate type and value — and it’s clear the present was given because of the occasion and not the boss’ position.
For occasions that are more frequent, like Christmas or a birthday, superiors may accept smaller gifts, in essence gifts where the ‘thought of giving’ has greater value than the gift itself,” the advisory states.
Seemingly taking a page from Miss Manners, the advisory notes that when bosses invite subordinates to their wedding they “might include a ‘no gifts, please’ request.”
The consequences are serious, the advisory notes: A boss who accepts a gift from a subordinate could get slapped with a $25,000 fine plus “disgorgement” of the gift.
The rules are much looser for gifts between co-workers and gifts given by bosses to their subordinates.
COIB has used the above rules for years when city workers called in to ask whether a gift was allowable, but the Thursday advisory was the first time the rules have been summarized and gathered together in one public document.