BBNC Code of Ethics Code of Ethics_Light_final_joomag 2 | Page 29

ANTI-KICKBACK ACT
Business Courtesies to
Government Personnel
Government personnel are subject
to a different standard. Under both
federal and state law, government
personnel are generally prohibited
from accepting entertainment, meals,
gifts, gratuities, and other things of
value from businesses and persons
with whom they do business or over
whom they have regulatory authority.
Employees of the executive branch
are permitted to accept unsolicited
business gifts (except cash or
investment interests) of up to $20
in market value per occasion (the
entire visit).
The sum of these gifts cannot
exceed $50 from one company per
calendar year.
Offering or giving gifts in excess of
these amounts may be a criminal
offense, regardless of intent and
regardless of whether paid with
BBNC or personal funds.
The Anti-Kickback Act prohibits
subcontractors and potential
subcontractors under government
contracts from giving kickbacks
to prime contractors or their
employees or to higher-tiered
subcontractors or their employees.
The Act also prohibits the
acceptance of such kickbacks.
“Kickbacks” can be in the form of
money, fees, commissions, credits,
gifts, gratuities, or anything of value,
which is either directly or indirectly
provided in return for obtaining
favorable treatment. Favorable
treatment does NOT have to be
something that you would think of
as dishonest, but under different
circumstances, might be considered
an innocent act. It could include
such activities as:
Awarding a subcontract or
purchase order;
Reducing contract requirements;
Putting a supplier on the
bidder’s list;
When the favorable treatment
is “bought,” then it becomes
unlawful. The Act prohibits any
employee from:
Providing, attempting to
provide, or offering to provide
any kickback;
Soliciting, accepting, or
attempting to accept a kickback;
Including, either directly or
indirectly, the amount of any
kickback in the contract price
charged to our customers.
Your Responsibilities
Immediately report any requests
to make, authorize, or agree to
any offer or payment which is
contrary to this Code.
Immediately report any
information that makes you
suspect that an employee or
vendor is engaging in, or has
engaged in, conduct prohibited
by this Code.
Paying an invoice earlier than the
company would normally pay it.
BBNC Code of Ethics | Ethics Hotline: [phone] | Effective May 17, 2019 | www.bbnc.net
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