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We have a board member who is a prominent orthodontist. He has been giving the bank employees a discount on services for themselves and their immediate children. He recently gave a substantial discount to an employee that is having some widely-known financial difficulties. The usual discount is greater than the $100 limit we have set for “accepting something of value” under certain conditions. We have been treating this as an exception to this rule because the discount is available to all employees. I hate for this employee to not get the large discount, but it seems it would not qualify for the exception since it is not consistent with the discount other employees are getting. Before I tell the director/employee they can’t do this, I want to make sure there isn’t something in the Bank Bribery Act/regulation that I am missing.
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