To report a gift/entertainment, complete a “Gift Receipt Notification” in Compliance Elf and include the following information: Name of gift giver, position of recipient/donor, and cost or value of gift.
Employees may obtain such pre-approval by completing and submitting a “Gift and Entertainment Pre-Clearance/Approval Request Form”.
All Access Persons must submit a “Gift and Entertainment Form” (Exhibit II-F to this Code) within 15 days of receipt of any gift or for tickets provided for any event attended.
On May 30, 2006, plaintiff executed a “Gift Deed” (ECF 25-4 at 3-4), which vested the Property in the names of Jaime Palacios and Monica Palacios as “Tenants by the Entirety.” Id. at 3.
All Access Persons must submit a “Gift and Entertainment Form” within 15 days of receipt of any gift, including for tickets provided for any event attended, valued at an amount in excess of $25.