GIFT AND ENTERTAINMENT POLICY

1. Purpose

USA Cycling is committed to sustaining an ethical workplace free of conflicts of interest and perceived conflicts of interest. Therefore, USA Cycling has adopted this Gifts and Entertainment Policy to provide instruction to USA Cycling Affiliated Individuals (as defined in Section 2) regarding how to handle offers of gifts or other forms of entertainment from individuals or companies that do business with or are interested in doing business with, USA Cycling. Additionally, it provides instruction on the NGB extending gifts to third parties.

This policy should not be considered an encouragement to make, solicit or receive any gift or entertainment. USA Cycling Affiliated Individuals may not, under any circumstances, actively solicit any gift or entertainment. Further, USA Cycling will not permit or authorize participation in any business gifts or entertainment considered lavish, inappropriate, or illegal. The only allowed gifts or entertainment are those outlined in this policy, and those gifts or entertainment must be properly disclosed.

2. Applicability of Policy

This Gifts and Entertainment Policy applies to all USA Cycling employees, board members, officers, committee members, task force members, hearing panel members, contractors, volunteers, and their spouses and immediate family members (“Affiliated Individuals”).

3. Gifts Received

Affiliated Individuals may accept and are not required to disclose gifts and entertainment, or invitations to attend events or travel valued at less than $250. Any gifts or entertainment valued at $250 and over must be disclosed promptly to USA Cycling’s General Counsel. Where the gift or invitation is made to the CEO or General Counsel, the required disclosure must be made to the Ethics Committee.

The General Counsel, or the Ethics Committee, in consultation with the Affiliated Individual, require that any gift(s) be surrendered and donated to USA Cycling or another agreed-upon charity if the General Counsel or the Ethics Committee believes that such gift(s) is not proper or creates an appearance of impropriety.

4. Gifts Given

There may be times when an Affiliated Individual, on behalf of USA Cycling, wishes to extend to a current or potential USA Cycling business associate (i.e., an individual, company, or government official) a gift or an invitation to attend an event (e.g., reception, meal, or sporting event) to further or develop a business relationship. In such instances, the value of the gift may not exceed $250.00 per recipient per year without prior approval from the USA Cycling General Counsel and the Chief Executive Officer. Invitations to events must be reasonable and appropriate. Topics of a business nature must be discussed at the event, and the inviting Affiliated Individual must be present.

All gifts or invitations offered by an Affiliated Individual must be covered by the appropriate USA Cycling budget and approved in advance by the appropriate USA Cycling supervisor.

5. Non-Gifts

The following items and scenarios do not constitute a reportable gift or entertainment under this policy:

1. Items valued under $250;

2. Sponsor discounts and provided products;

3. Any item or event which is available to the general public and the Affiliated Individual pays fair market value for;

4. Promotional items provided to all attendees at an event;

5. A gift or invitation extended by a relative or provided by an individual based on personal friendship; individuals subject to this policy must be mindful of gifts and invitations based on friendship as opposed to gifts and invitations provided based on one’s role with USA Cycling;

6. An item that may be publicly displayed or shared among USA Cycling employees, such as flowers or cookies; or

7. Food and beverage provided as meal or refreshment at a business meeting or reception attended by an Affiliated Individual as part of their official responsibilities, provided such food and beverage is reasonable for the event.

6. Policy Violations

Violations of this policy may be reported to USA Cycling by the processes outlined in the USA Cycling Whistleblower Policy. Violations will be referred to General Counsel or Ethics Committee and subject to appropriate disciplinary action, up to and including termination of employment.

7. USA Cycling Point of Contact

If an Affiliated Individual is unsure of any of the requirements outlined in this policy or has questions regarding a specific situation related to gifts and entertainment, they should contact:

Shane Garman
Chief Administrative Officer & General Counsel
legal@usacycling.org

Policy History