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Martha Jefferson employees are prohibited from soliciting gifts, payments, free services, meals or any other items form independent contractors, vendors, suppliers or other items from independent contractors, vendors, suppliers or other individuals doing business with, or seeking to do business with, Martha Jefferson.

Likewise, employees are prohibited from accepting monetary tips and gratuities, except for non-cash gratuities and gifts of nominal value. (For purposes of this policy, nominal value shall mean less than $100 either at one time or over a period of one year), Gifts are identified as discounts, favors, tips and gratuities or other items of value.

Employees may accept non-cash gifts of nominal value (described above) from individual contractors, vendors, suppliers and other businesses or individuals doing business with Martha Jefferson so long as the gifts are of such little value that they could not reasonably be seen as an attempt to influence the employee. For example, employees may accept inexpensive pens, note pads, coffee mugs, key chains or other similar items with nominal value.

Employees may accept business meals, refreshments or other similar items provided at the expense of a business or a vendor so long as the occasions are infrequent and reasonable.

Employees are prohibited from making any payments to any company or person for personal gain or inducing business for Martha Jefferson.

The federal Anti-Kickback Statute prohibits payments or other consideration given to physicians for the referral of service.



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