Conflict of Interest Gift Policy
Compliance And Ethics Department Reminder
Published on: November 21, 2024
The holiday season is a time of celebration.
However, even during the holiday season, the Choctaw Nation of Oklahoma’s Conflict of Interest Policy still applies.
To make sure you don’t mistakenly violate the Conflict-of-Interest Policy, here is an overview of the gift policy.
Associates can accept gifts as long as the gifts do not compromise the Choctaw Nation’s priorities, mission, or business objectives and as long as they meet the following requirements:
A gift is an item of value, including invitations to events and meals.
A single gift under $150 does not require reporting. Choctaw Nation does not require associates to disclose gifts under $150. But be aware that if additional gifts from the same person/company are received, that may bring you $150 or more disclosure amount which would increase the value of the gifts and disclosure would be required.
$150 or more associate must report the gift. Choctaw Nation requires the gift(s) to be disclosed.
$500 or more an associate cannot accept the gift. UNLESS, it is a cultural gift. Associates may accept cultural gifts of any value on behalf of the Choctaw Nation. If an individual receives a cultural gift, they will need to also inform the Cultural Department. The Cultural Department may determine that the gift needs to be provided to the Cultural Department to be used and displayed throughout the Choctaw Nation.
Gift cards that are specific to a single store or business are allowable and fall under the same disclosure requirements as other gifts. Examples of these types of gift cards would be gift cards to Amazon, Chili’s, Walmart, or Target.
Pre-paid loaded cards, such as Visa or Mastercard gift cards, are considered a cash equivalent and cannot be accepted at any time.
ASSOCIATES CAN REVIEW OR TAKE CONFLICT OF INTEREST TRAINING ON HOSHONTI