Gifts and Hospitality Policy - Policies and Policy Governance

1. Policy

Issued: May 11, 2022
Last Revised: May 19, 2025
Last Reviewed: November 20, 2025

Applies to: Faculty (including part-time, adjunct and visiting faculty), postdoctoral scholars, staff and students (including graduate/undergraduate student workers and graduate assistants) employed by University of Southern California (“USC“ or the “University“) and including those working for Keck Medicine of USC (“USC Employees”), as well as students enrolled at the university. This policy continues to apply to individuals who are on sabbatical or other leaves, or who are visiting other institutions.

2. Policy Purpose

At USC, we recognize that Gifts and Hospitality (“G&H”) are often exchanged to build goodwill and strengthen working relationships and partnerships between USC and those with whom we engage. However, when G&H-giving exceeds Modest Value, it can appear improper and, in some cases, may be unlawful. This policy is designed to support compliance with the law and align with our Unifying Values.

As USC Employees, we are responsible for evaluating all G&H given and received in accordance with this policy. USC employees must ensure that giving or receiving G&H does not improperly influence or appear to improperly influence an individual’s decision-making abilities.

3. Scope and Application

This policy represents USC’s commitment to proactively address and manage giving and receiving of G&H between:

USC Employees and Third Parties
USC Employees and students

This policy does not address institutional gift giving or G&H between USC Employees. While G&H between employees is not covered by this policy, employees should avoid accepting or offering G&H that could create a conflict of interest, or the perception thereof.

For the purposes of this policy, G&H exchanged between a USC employee and student worker/graduate assistant in the context of the workplace is considered between USC employees while G&H exchanged between a USC employee and student in an academic setting is considered between a USC employee and a student.

Individual departments, schools or units may have more restrictive standards or guidance concerning the giving and receiving of G&H. USC Employees should consult their supervisor, department chair or Dean to determine if additional policies or procedures apply based on their roles or responsibilities at USC. In the event of a discrepancy or conflict between this policy and an employee’s school, department, or unit standards or guidance, the more restrictive provisions will govern, unless prohibited by law.

The giving or receiving of certain types of G&H may trigger additional or distinct regulatory or legal obligations that are specific to a USC Employee’s activity or roles. The following USC policies are intended to address these types of obligations:

The Conflict of Interest and Commitment Policy further describes USC’s position on financial or personal benefits that may create the appearance of a Conflict of Interest.
USC’s Political Activity Policy contains additional requirements for giving G&H to Government Officials. Any G&H to a Government Official must be pre-approved pursuant to that policy.
The Relationships with Industry and Conflict of Interest in Research policies contain additional requirements for accepting and providing G&H for healthcare professionals and researchers.

Keck Medicine of USC’s operating policies contain additional guidance for giving and receiving G&H at USC hospitals and clinics.

The following G&H are not covered under this policy:

Payments for lodging, meals and transportation received for the purpose of participating in uncompensated service to a professional organization of which the individual is a member.
Honorarium received by USC Employees based on their role at USC and in conjunction with their external professional activities so long as the receipt of such honorarium does not create a potential Conflict of Interest.

Charitable donations to USC are not gifts under this policy. For additional information about donations to USC, please see the following USC policies:

The Gift Acceptance and Campaign Counting Policy contains additional requirements for receiving G&H from donors.
The Fundraising Coordination Policy describes USC-related fundraising requirements, including independent efforts related to fundraising opportunities and restrictions on G&H from current or former patients and students.

4. Definitions

Term	Definition
Conflict of Interest	A Conflict of Interest arises when: Professional, financial, or personal activities or relationships compromise, or have the appearance of compromising, a USC Employee’s professional loyalty and responsibility to USCProfessional, financial, or personal activities or relationships compromise, or have the appearance of compromising, a USC employee’s ability to perform USC duties and responsibilities in a full and complete manner, orA USC Employee’s professional, financial or personal activities compete (or have the appearance of competing) with the university See the Conflict of Interest and Commitment Policy for full definitions of a Financial Activity, Conflict of Commitment, and Close Relation.
Gift & Hospitality	A Gift is anything of value provided to an individual, including but not limited to, baskets of fruit, flowers, promotional items, subscriptions to publications or clubs, jewelry, use of vacation homes, tickets to sporting events or concerts, and preferential rates or discounts on goods and services. Charitable donations to USC are not gifts under this policy. Hospitality includes, but is not limited to, lodging and travel expenses, room, meals, waivers of conference or event fees, and customary expenses in connection with participating in engagements or attending conferences or events.
Government Official	Elected or appointed officials (typically including most of their staff members) or government employees empowered to make governmental decisions. Candidates for political office may be subject to the same policy requirements and limitations. Government Officials may also be Political Candidates.
Honorarium	For the purposes of this policy, an honorarium is a voluntary payment for services (for which fees are not legally or traditionally required). This method of payment is usually made to a guest speaker or lecturer as a “thank you” and gesture of good will and appreciation. Under this policy, an Honorarium is not considered a gift or hospitality. If receipt of honorarium creates a potential conflict of interest, it must be reported as described in the Conflicts of Interest and Commitment Policy.
Modest Value	Items considered modest value include food and refreshments or customary G&H of no more than $200 per person per occasion.
Third Party	A Third Party is any individual or entity that is not a USC employee, including but not limited to: – A supplier or vendor of goods or purchased services – Past students – Past or present patients, their families, or their foundations – A customer, person, or entity with whom USC has a business or other relationship, or with whom negotiations may be in progress – A sales representative acting on behalf of a Third Party – Joint venture partners – Professional organizations – Non-employed physicians with privileges at a USC hospital

5. Policy Details

Guidance for G&H between USC Employees and Third Parties

USC Employees should not offer or give G&H to a Third Party, nor should they accept G&H from a Third Party unless it conforms to the principles set forth in this policy.

The following guidance applies to any G&H given to or received from a Third Party:

G&H may not place the recipient under any obligation that may create an actual or apparent Conflict of Interest.
G&H must not be lavish or frequent. The value of the G&H must be reasonable and of Modest Value as outlined in the Acceptable Gifts and Hospitality section of this policy.
G&H must be made openly, transparently and accurately documented per USC’s procedures outlined in section 6 of this policy.
If a USC Employee needs guidance about G&H, they must consult their supervisor, Department Chair, Dean, or the Office of Ethics and Compliance.
When exchanging G&H outside of the United States, USC Employees must be mindful of US and local anti-bribery and corruption laws. The requirements of this policy apply regardless of where a USC Employee is conducting business.

Acceptable Gifts or Hospitality between USC Employees and Third Parties

USC Employees are generally permitted to accept meals, travel, and other customary expenses in connection with participation in speaking engagements and other professional events. However, if the estimated value of such expenses exceeds Modest Value, the G&H must be approved by the USC Employee’s supervisor, Department Chair or Dean and must be disclosed to the Office of Ethics and Compliance through diSClose, USC’s online disclosure system. Examples of acceptable G&H that may generally be exchanged between USC Employees and a Third Party and do not require disclosure or approval include the following items of Modest Value:

A working meal or meal voucher
Logoed USC items
A host/hostess gift
A plaque or award

If a USC Employee wishes to accept G&H that is more than $200 per person per occasion or $1,000 in aggregate from the same Third Party within one year, it must be pre-approved by the USC Employee’s supervisor, Department Chair or Dean and disclosed to the Office of Ethics and Compliance. Similarly, G&H given to a Third Party that is more than $200 must be pre-approved by the USC Employee’s supervisor, Department Chair or Dean and disclosed to the Office of Ethics and Compliance through diSClose.

Prohibited Gifts or Hospitality between USC Employees and Third Parties

The giving or receiving of G&H between a Third Party and USC Employee is unacceptable and prohibited if it:

Is illegal
Does not fit within USC policies
Is an attempt to or intended to influence or reward in connection with USC business, regardless of the value of the G&H
Is inconsistent with USC’s values
Is in the form of cash or cash equivalents
Creates an actual Conflict of Interest or the appearance of a Conflict of Interest
Violates the University’s Policy on Prohibited Discrimination, Harassment, and Retaliation

USC Employees must never exchange G&H with a Government Official without adhering to the procedures in the Political Activity Policy. Offering or giving G&H to a Government Official can result in regulatory and/or legal consequences for the USC Employee and for the university.

Additionally, Employees who manage or oversee relationships with a Third Party such as vendors, suppliers, or partners, must never contact or approach those Third Parties with a request for Gifts and Hospitality, of any value, for personal use.

This Policy does not apply to situations where a personal, non-business relationship exists, and the G&H is not given for a business purpose. In such cases USC employees are encouraged to discuss the exchange with their supervisor and the Office of Ethics and Compliance if giving the G&H could give rise to the appearance of Conflict of Interest.

Limitations on Gifts and Hospitality between USC Employees and Students

USC Employees who offer or accept excessive G&H to or from a student may compromise or have the appearance of compromising that employee’s professional integrity and responsibility to USC. Offering or accepting G&H to or from a student may also present actual or perceived conflicts of interest, perceptions of favoritism, improperly influenced decision-making, and potential adverse consequences for students and academic programs. However, USC also recognizes that limited G&H may be provided by USC employees to students to express and foster professional collegiality in an academic environment. USC faculty and staff may offer G&H to students valued at no more than $50 per student, per occasion and no more than $100 total to the same student per academic year.

The limitation applies to gifts provided directly from USC employees to individual students and does not apply to faculty and staff donating G&H to groups of students through participation in university affiliated community service and events where the donation of G&H may occur as part of charitable, volunteer or educational activities.

USC employees are prohibited from accepting G&H from a student when there is an existing or known upcoming academic or evaluative role between the USC employee and student. Where no such role exists, employees may accept nominal G&H from a student up to $20 per occasion and $50 total from the same student per academic year.

Exceptions to these limitations require a disclosure in diSClose and approval from the Office of the Provost and the Office the Ethics and Compliance.

6. Procedures

USC Employees should refer to the Travel and Expenses Procedures when personal funds or USC travel cards are used for payment of G&H.
USC Employees should refer to the Corporate Card Procedures when a USC Procurement card is used for payment of G&H.
Any G&H exchanged between a USC Employee and a Third Party that exceeds $200 per person per occasion or $1,000 per person per year in aggregate from the same Third Party must be approved by the USC Employee’s supervisor, department chair or Dean and disclosed to the Office of Ethics and Compliance through diSClose.
USC Employees should immediately report any knowledge or awareness of an inappropriate exchange of G&H between USC Employees and Third Parties as well as USC Employees and students to their supervisor and the Office of Ethics and Compliance. Employees may also report at USC Report & Response.

7. Forms

diSClose

8. Responsibilities

POSITION or OFFICE	RESPONSIBILITIES
Office of Ethics and Compliance	Review and approve exceptions to the policy. Monitoring G&H activity relative to the policy requirements and provide periodic communication and training designed to support the policy and the related procedures.
USC Employees	Understand and comply with this policy. In any situation where it is not clear if the actions a USC Employee is contemplating are permitted, seek guidance from their supervisor, Department Chair or Dean and the Office of Ethics and Compliance. Disclose G&H that is more than $200 per person per occasion or $1,000 in aggregate from the same Third Party within one year to the Office of Ethics and Compliance and obtain approval from their supervisor, Department Chair or Dean before accepting the G&H. Disclose G&H offered by a student that is more than $20 per occasion or more than $50 total from the same student per academic year in diSClose and obtain approval from the Office of the Provost and the Office the Ethics and Compliance before accepting the G&H.
Supervisors, department chairs, and Deans	Set expectations for the giving of G&H to and receipt of G&H from Third Parties including what is permissible based on the individual department, school, and unit, and how to comply with expenditure and procurement procedures. Review and approve G&H above Modest Value and ensure that reportable G&H given or received are disclosed in accordance with this policy.

9. Related Information

10. Contacts

Please direct any questions regarding this policy to:

OFFICE	PHONE	EMAIL
Office of Ethics and Compliance	213-740-8258	compliance@usc.com