Alabama     

Alabama lobbyist principals such as Apple are generally prohibited from providing a “thing of value” to any public official or employee in Alabama.  There are applicable exceptions for:


  1. Meals and other food and beverages with a limit of $50 per meal, with an annual limit of $250 (includes the cost of both the official/employee and their spouses meal); 

  2. Actual and necessary travel, lodging and meals provided by an organization as part of an educational function (a meeting, event or activity held  within the State of Alabama, or if the function is predominately attended by participants from other states, held within the continental U.S., and which is organized around a formal program or agenda of educational or informations speeches, debates, panel discussions or presentations concerning matters within the scope of the participants official duties); and 

  3. Actual and necessary travel, lodging and meals related to widely-attended event (“widely attended” means a gathering, dinner, reception, or other event of mutual interest to a number of parties at which it is reasonably excepted that more than 12 individuals will attend and that individuals with a diversity of views or interests will be present).  

Please note that any expenses provided under these exceptions that are in excess of $250 per person made in a 24-hour period are reportable on Apple’s lobby report, and that certain public officials and employees may be required to file a statement of economic interest disclosing any gift from Apple.



Alaska

School district officials and employees in Alaska do not fall under the state ethics rules.  However, please keep in mind that that there may be local laws and individual school district rules limiting gifts to district employees and officials.


  1. Alaska - City of Anchorage and Anchorage School DIstrict

  2. Anchorage School District’s Ethics Code states that “under most circumstances district employees and officials cannot accept gifts or gratuities from someone doing business with the district.  Gifts must be reported to a supervisor.  If the value or nature of the gift requires it, a Gift Disclosure form must be filed with the employee’s supervisor and with the Municipal Clerk’s office within 10 days of receipt of the gift.  There are a few exceptions but these new rules are stringent.  Occasional gifts worth less than $50 are allowed, but circumstances may still indicate gifts of low value are intended to influence an employee’s independent judgment.  Employees should thoroughly review AMC section 1.15.025(H) before accepting any gifts.  If in doubt, report the gift.”



Arizona

Arizona law prohibits school district officials and employees from using their official position to secure any valuable benefit that would not ordinarily accrue in the performance of their official duties. Additionally, any person or entity such as Apple that has an interest in matters before a school board is prohibited from providing a school district board member with any expenditure for admission to, or participation in, any sporting or cultural event or activity.



Arkansas

Arkansas law prohibits officials and employees of school districts from receiving any gift for the performance of the duties and responsibilities of his or her office or position.  Gift is defined as “any payment, entertainment, advance, services, or anything of value, unless consideration of equal or greater value has been given therefor.  There are exceptions for: informational material; anything with a value of $100 or less (reimbursement of anything over $100 allowed if within 10 days); food or beverages provided at a conference scheduled event that is part of the program of the conference; and food, lodging or travel in situations where a public servant is appearing in his or her official capacity, the appearance bears a relationship to the public servant’s office or position, and is one that would be subject to expense reimbursement by the public servant’s agency.  Please note that any public servant required to file a statement of financial interest must report any such gift in excess of $150.



California

Public officials in California may not accept gifts of more than $440 from any single source per calendar year, and must report any gifts of $50 or more from a single source in a calendar year.  Public officials include Superintendents, Board Members and any other employee designated in a school district’s conflict of interest code as someone who must file a statement of economic interest.  If an official travels to give a speech, any transportation, necessary lodging and “subsistence” provided directly in connection with the event are not subject to the gift limits, but are reportable.    


  1. California - Los Angeles Unified School District

  2. LAUSD’s Employee Code of Ethics states that contractors such as Apple or their representatives may not provide, and district officials and employees may not accept, gifts or gratuities in excess of $100 from a single source in a single year, or gifts that give the appearance of improperly influencing official decisions, regardless of the amount.  In addition, the LAUSD Contractor Code of Conduct provides that contractors such as Apple or their representatives are prohibited from offering or giving, directly or indirectly, any gift or gratuity to any LAUSD procurement official at any time.  The Code does not define "procurement official," but the LAUSD Ethics Office has confirmed that "procurement official" covers (1) any person who throughout the year exclusively handles procurement matters on the district's behalf (e.g., employees with the Procurement Services Group) and (2) any person who may from time to time become involved in a procurement matter that could impact the donor.  LAUSD has in the past permitted travel expenses as a “gift to agency,” but this requires working with the district’s legal counsel in advance of an event, and public disclosure of the expenditures.



Colorado

Colorado state gift law restrictions (including Amendment 41) do not apply to school district officials and employees.  However, please keep in mind that that there may be local laws and individual school district rules limiting gifts to district employees and officials.



Connecticut

Connecticut state gift law does not apply to school district employees and officials, with the exception of the vocational/technical high schools belonging to the state of Connecticut Technical High School System (see summary below).  However, many towns and municipalities have their own codes of ethics which would apply to school districts.  Finally, the Connecticut Code of Professional Responsibility for Teachers states that “[t]he professional teacher, in full recognition of his or her obligation to the profession of teaching, shall: decline any gratuity, gift or favor that would impair or influence professional decisions or actions.”


  1. Connecticut - Vocational/Technical High Schools

  2. Employees of vocational/technical high schools may not accept gifts from regulated donors such as Apple.  There are exceptions for: token items (any item of value that is under $10, but annual aggregate of such items from a single source must be under $50); food and beverage up to $50 in a calendar year, provided the regulated donor or the donor’s representative is in attendance when the food and beverage is consumed; and necessary expenses related to an event only if the official or employee is actively participating in an event by giving a speech or presentation, or having some other active involvement.  Necessary expenses include travel (not 1st class), lodging for night before, of and immediately following the event, meals, and related conference expenses. 



Delaware

School District employees with administrative duties (e.g. a Superintendent) or who are required to file a financial disclosure statement and school board members are prohibited from accepting gifts under circumstances where acceptance would impair independent judgment, give preferential treatment to any person, result in the making of a governmental decision outside official channels, or give the appearance of impropriety.  There are no other specific gift limits or exceptions, however, please keep in mind that that there may be local laws and individual school district rules limiting gifts to district employees and officials. 



District of Columbia

The District of Columbia prohibits school district officials and employees from accepting any gift from persons or entities who do or seek to do business with the District, or who have an interest that may be favorably affected by the performance or non-performance of the covered official or employee’s official duties.  There are exceptions for: infrequent occasions where food and refreshments of nominal value are provided in the ordinary course of a lunch or dinner meeting or while on an inspection tour where an employee may properly be in attendance, and unsolicited promotional items of nominal value (e.g. company logo pens or note pads).



Florida

Apple may not provide, and Florida local school district employees who are required to file personal financial statements (including but not limited to Superintendents and members of school boards) may not accept, gifts worth more than $100 per gift.   There is an exception for actual and reasonable transportation, lodging and food and beverage related to an honorarium event (official invitation to speak and cost notification required).  Please note that gifts between $25 and $100 will be reported by Apple on a quarterly gift disclosure report if required.



Georgia

It is unlawful for Apple to give and for any person acting for or on behalf of a school district to accept a “thing of value” that could reasonably be believed to influence the performance of an official action. (Applies to all public officials and employees regardless of the status of the donor.)  There are exceptions for: food or beverage consumed at a single meal or event; actual and reasonable expenses for food, beverages, travel, lodging and registration for a meeting which are provided to permit participation or speaking at the meeting; any gift with a value less than $100; promotional items generally distributed to the general public or to public officers; and food, beverage and expenses afforded public officers, members of their immediate families, or others that are associated with normal and customary business or social functions or activities.



Hawaii

School district employees and officials who work for schools under the Hawaii Department of education’s jurisdiction are subject to the general gift rule for public employees of the State of Hawaii, which provides that they shall not "solicit, accept or receive any gift whether in the form of money, service, loan, travel, entertainment, hospitality, thing, or promise, or in any other form, under circumstances in which it can reasonably be inferred that the gift is intended to influence the legislator or employee in his or her official capacity or is intended as a reward for any official action.”  


The state’s gift guidelines provide that the following are acceptable (these guidelines may not apply for employees whose official duties include procurement):


  1. “Gifts of Aloha” - modest gifts of nominal value traditionally given as part of Hawaiian culture as a gesture of aloha or goodwill such as a flower lei or a box of cookies to share with the office - and other gifts of nominal value such as small promotional business items (e.g. pens with company logo). 

  2. Meals and “Food and Drink” types of events valued at under $25.  (This limit applies to the whole event.)


The gift guidelines state that meals and receptions valued at $25 or more and travel cannot be accepted absent a legitimate “state benefit,” i.e. a reasonable relationship between the trip and the employee’s official duties.  Any travel-related expenses must be pre-approved by Government Affairs.


There is also a separate gift disclosure law which requires public officials and employees to file a gifts disclosure statement with the state ethics commission on June 30th of each year, if they receive gifts valued singly or in the aggregate in excess of $200 from a source that has interests that may be affected by discretionary action or lack of discretionary action by a state official or employee.  (This means that should Apple be permitted to pay for anything with a value in the aggregate of $200 or more, the official or employee may have to disclose the value.)




Idaho

Idaho school district officials and employees who have discretionary authority to perform official action in connection with contracts, purchases, payments, claims or other pecuniary transactions of the government are prohibited from accepting any benefit from any person or entity known to be interested in or likely to become interested in any such contract, purchase, payment, claim or transaction.  There is an exception for trivial benefits not to exceed a value of $50 that involve no substantial risk of undermining official impartiality.


Expenses associated with a trip for the purpose of viewing demonstrations of a product already purchased by the district, or for gathering technical information relevant to a district’s interest in a product, may be permissible under Idaho law.  However, if Apple is currently bidding or will likely be bidding on a contract with a local jurisdiction, covering the costs of a briefing or other event would be impermissible, because the public officials and employees attending the event would likely have authority over an official action, decision, or recommendation involving Apple.



Illinois

Illinois law requires local governments and school districts to adopt their own "no less restrictive" gift provisions than those set out in the state law, which prohibits state employees from intentionally soliciting or accepting any gift from any prohibited source.  Because Apple does business with the state and has registered lobbyists in Illinois, we are a prohibited source.  An exception allows Apple to provide food or refreshments not exceeding $75 per person per day, provided the food or refreshments are consumed on premises from which they were purchased or catered.  In addition to the food and beverage exception, Apple may provide gifts under $100 (cumulative and per calendar year), and in certain circumstances, travel expenses when pre-approved by an agency’s ethics officer.


  1. Illinois - Chicago Public Schools

  2. Illinois law requires local governments and school districts to adopt their own "no less restrictive" gift provisions than those set out in the state law, which prohibits state employees from intentionally soliciting or accepting any gift from any prohibited source. (Because Apple does business with the state and has registered lobbyists in Illinois, we are a prohibited source at the state level; local and school district Gift Bans usually use a similar definition.) Chicago Public Schools officials and employees are generally prohibited from soliciting or accepting any gift with a value of $50 or more during a calendar year, or two or more gifts with a cumulative value of $100 or more during a calendar year, from anyone doing or potentially doing business with the Board.



Indiana

School district employees and officials in Indiana do not fall under the state ethics rules.  However, please keep in mind that that there may be local laws and individual school district rules limiting gifts to district employees and officials. 



Iowa

Iowa law prohibits all public employees, including teachers, from accepting gifts over $3 from any one donor during one calendar day.



Kansas

School district employees in Kansas, including superintendents, do not fall under the state ethics rules.  However, please keep in mind that that there may be local laws and individual school district rules limiting gifts (including meals and travel) to district employees and officials. 



Kentucky

The Kentucky Executive Branch Code of Ethics does not apply to school district officials and employees.  However, please keep in mind that that there may be local laws and individual school district rules limiting gifts to district employees and officials. 



Louisiana

Louisiana’s Code of Governmental Ethics prohibits public servants from accepting any thing of economic value from anyone who has or is seeking a contractual, business or financial relationship with the public servant’s agency.  Such a person is also prohibited from giving any thing of value to the employee.There are exceptions for: promotional logo items having no substantial resale value, such as pens and t-shirts; food and beverage of $57 or less at a single event (before tax and gratuity); and reasonable transportation which is incidental to the food and drink.  (The $57 F/B limit does not apply to gatherings held in conjunction with a meeting related to a national or regional organization or meeting of a statewide organization of government officials or employees provided that at least 10 persons associated with the organization are invited to the gathering.) In addition, Louisiana law tightly constrains the ability of a company with government contracts to make travel and accommodations  



Maine

Maine has no state law restrictions on lobbyist employers such as Apple giving gifts to school employees or officials, including superintendents.  However, please keep in mind that there may be local laws and individual school district rules limiting gifts to district employees and officials. 



Maryland

Maryland school district officials and employees are subject to the ethics regulations enacted by their school board, or the ethics laws of their county if the school board has not enacted such regulations.  Please consult your ethics official to determine the ethics and gift rules for your district.



Massachusetts

Massachusetts conflict of interest law prohibits anyone from offering a school district employee with whom they have official dealings “anything of substantial value” in relation to his or her public employment.  Anything worth $50 or more in the aggregate per calendar year is considered to be of substantial value for purposes of the conflict of interest law.  There is an exception that generally allows Apple to reimburse a public employee for out-of pocket expenses, including transportation, lodging, meals and conference fees, for a legitimate speaking engagement whose purpose is to provide education to conference participants.  Please note that because Apple is a registered lobbyist employer in Massachusetts, we must itemize gift expenditures that exceed $35 per day for certain public employees on our semi-annual disclosure report.


Additionally, it is not a violation of Massachusetts law for Apple to offer or give, or a public employee to receive, free or discounted travel and lodging expenses, including meals, of substantial value that serve legitimate public purposes provided that:


  1. A public employee, prior to any travel, shall file a full disclosure in writing of the travel and expenses to be covered;

  2. An appointed public employee, prior to any travel, shall file a full disclosure of the travel and expenses to be covered with his or her appointing authority. The appointing authority shall make an advance determination, which shall be filed in the same manner as a disclosure, that the travel serves a legitimate public purpose and that the benefit to the government of the employee's participation in the travel or event outweighs any non-work related benefit to the employee or the private sponsor taking into account the extent to which such free or discounted travel may convey an appearance of special benefit for any employee.

  3. An elected state or county employee, prior to any travel, shall file a full disclosure of the travel and expenses to be covered with the State Ethics  Commission.

  4. An elected municipal employee, prior to any travel, shall file a full disclosure of the travel and expenses to be covered with the city or town clerk in the respective municipality. Such disclosure shall state that the travel serves a legitimate public purpose and that the benefit to the government of the elected public employee's participation in the travel or event outweighs any non-work related benefit to the employee or the private sponsor taking into account the extent to which such free or discounted travel may convey an appearance of special benefit for the elected public employee.



Michigan

The Michigan State Ethics Act does not apply to school district officials and employees.  The 57 Michigan Intermediate School Districts (http://wash.k12.mi.us/adminandcommdept/StateISDList.php) are required by the Michigan School Code to adopt and implement a conflict of interest policy designed to avoid conflicts of interest by intermediate school district officials and employees.  The law prohibits these districts school board members or district administrators from accepting any gift in excess of $44, in a one-month period, from a person who does business or seeks to do business of any kind with the intermediate school district.  The provision only applies to board members and administrators, and does not apply to most intermediate school district employees. The statute does not incorporate any exceptions, but the policy of an individual districts may.   For all districts, please keep in mind that that there may be local laws and district policies limiting gifts to district employees and officials. 


  1. Michigan - Detroit Public Schools

  2. Detroit Public Schools’ Conflicts of Interest Policy provides that board members and employees shall not solicit or accept a gift or loan of money, favors, goods, services, discounts, and or benefits, including food, lodging and transportation, in excess of $100.00 (one hundred dollars) from a single source.  Board members and employees are required to complete a conflict of interest form disclosing any actual or potential conflicts of interest that may have occurred in the past year.  Each vendor doing business with the District are also required to disclose actual or potential conflicts of interest prior to entering into a business relationship with the district, and annually thereafter.



Minnesota

Minnesota gift and lobby law restrictions do not apply to school district officials and employees.  However, please remember that there may be local laws and individual school district rules limiting gifts to district employees.



Mississippi

Mississippi law does not limit gifts to public officials and employees.  (A “gift” is anything of value, including a rebate or discount in price of anything of value, unless it is available in the ordinary course of business to the general public.)  However, please remember that there may be local laws and individual school district rules limiting gifts to district employees.



Missouri

Missouri’s bribery law prohibits public school district officials and employees from acting or refraining from acting in any official capacity because of anything of value received in relationship to the performance of that act.  There are no other state gift limitations, however, please keep in mind that there may be local laws and individual school district rules limiting gifts to district employees.



Montana

Montana law limits gifts from an interested source such as Apple to less than $50 per occasion for elected local officials such as county superintendents.  There are exceptions for: educational activity that does not appear to place the recipient under obligation, that serves the public good and is not lavish, and food and beverages consumed when appearing in an official capacity.  Appointed school officials and employees are not subject to the state gift rule.  However, please keep in mind that that there may be local laws and individual school district rules limiting gifts to district employees and officials.



Nebraska

Nebraska school district officials and employees are prohibited from accepting anything of value including gifts based on an agreement that their vote, official action, or judgement would be influenced.  Food and beverage provided for immediate consumption and the occasional provision of transportation within the state of Nebraska is excluded from the definition of “gift.”  In addition, please remember that there may be local laws or individual school district rules limiting gifts to district employees and officials.



Nevada

Nevada school district officials and employees are prohibited from accepting gifts that would tend to improperly influence a reasonable person in his or her position to depart from the faithful and impartial discharge of his or her public duties.  Public officials and employees may not accept an honorarium, however they may be reimbursed for actual and necessary costs incurred for the making of an appearance or speech in an official capacity.  Superintendents and school board members must annually report gifts from single sources that cumulate to more than $200 in a calendar year.  Please keep in mind that there may be local laws and individual school district rules limiting gifts to district employees and officials - we are aware of at least one district (Clark County) that significantly limits gifts from vendors.



New Hampshire

New Hampshire gift and lobby law restrictions do not apply to school district officials and employees.  However, please remember that there may be local laws and individual school district rules limiting gifts to district employees.



New Jersey

New Jersey school officials are prohibited from accepting anything of value if offered with the intent to influence him or her in the discharge of official duties, and are prohibited by the School Ethics Act from accepting anything that is limited to clients or customers of a vendor.  A "school official" is a board member, administrative, or a managerial employee or officer of the New Jersey School Boards Association.  An “administrator” is an employee, other than a board member, of a local school district who:  1) holds a position which requires a certificate that authorizes the holder to serve as a school administrator; 2) holds a position which does not require that the person hold any type of certificate but is responsible for making recommendations regarding hiring or the purchase or acquisition of any property or services by the local school district; or 3) holds a certificate that authorizes the holder to serve as a supervisor.  The Act does not apply to a teacher unless he or she is responsible for making recommendations regarding purchases of property or services by the school district.  However, please remember that there may also be local laws and individual school district rules limiting gifts to all district employees.



New Mexico

New Mexico state gift law provisions do not apply to school district officials and employees.  However, please keep in mind that there may be local laws and individual school district rules limiting gifts to district employees and officials.



New York

The New York state gift and lobby laws for state officials and employees does not apply to school district officials and employees, but the state’s General Municipal Law includes a special conflict of interest rule that prohibits municipal officers and employees (includes county, city and school district employees) from accepting anything having a value of $75 or more, “under circumstances in which it could reasonably be inferred that the gift was intended to influence him or could reasonably be expected to influence him, in the performance of his official duties or was intended as a reward for any official action on his part. The General Municipal law also provides that local governing bodies, including schools districts, shall adopt a code of ethics setting forth for the guidance of its officers and employees the standards of conduct reasonably expected of them.  These codes of ethics may be more restrictive than the state law, or may provide explicit exceptions (e.g. for expenses related to speaking engagements).   



  1. New York City

  2. Both New York state and local laws govern gifts from city lobbyist employers such as Apple to city officials and employees.  Generally, New York City Department of Education (DOE) employees and officials are not subject to the restrictive state lobbying laws, but are still prohibited under the NYC lobbying laws from accepting gifts from lobbyist employers such as Apple, unless an exception applies.  There are exceptions for: 


  3. Modest meals or refreshments in the course of and for the purpose of conducting City business when offered during a meeting in which the public servant is attending for official reasons. (This exception is intended to apply to meals offered in a setting where there is no public price structure and individual payment is impractical.)

  4. De minimis promotional items that have no substantial resale value, such as company logo pens, mugs, hats and t-shirts.


  5. Anything provided under these exceptions may be reportable on Apple’s New York City lobbying report.



North Carolina

North Carolina's strict contractor ban prohibits state contractors such as Apple from making a gift or giving favors to any government officer or employee in charge of awarding, administering or preparing plans, specifications or estimates for public contracts.  This rule governs all “governmental agencies” including local jurisdictions and school districts.  There is an exception for souvenirs of nominal value and reasonable actual expenditures for food, beverages, registration and travel in connection with attendance at an educational meeting related to official duties or where the attendee will be speaking.  For this exception, the educational meeting must be attended by at least 10 or more participants; have a formal agenda, notice of the meeting must have been given at least 10 days in advance, and any food or beverages must be provided to all attendees.  In addition, please keep in mind that even when the state contractor ban does not apply, there may be local laws and individual school district rules limiting gifts to district employees and officials.



North Dakota

North Dakota does not have state gift laws other than a general bribery law.  There are however special state contractor gift rules, which prohibit any vendor or contractor from giving or offering to give any employee or official of a purchasing agency involved in any aspect of the procurement process gifts or anything of value that might influence or appear to influence procurement decisions.  There is an exception to this rule for items of nominal value as a gesture of goodwill or for public relations purposes.  In addition, please keep in mind that there may be local laws and individual school district rules limiting gifts to district employees and officials.



Ohio

Ohio law prohibits Apple from providing anything of value (including gifts, meals, lodging, travel expenses and discounts) to an Ohio public official or employee at any level of government, including public universities and school districts.  However, these restrictions do not apply to an employee who is strictly an educator and whose position does not involve any administrative or supervisory functions.  There is also a narrow exception for modest meals of a routine character, such as a meal at the Apple Executive Briefing Center.  This exception does not allow for a non-routine meal, e.g. a dinner at a restaurant.  Small gifts of nominal value such as a book or promotional item are also allowed.  However, acceptance of multiple items of nominal value from the same source, if the value added together is substantial, could be considered an improper influence.



Oklahoma

The  Oklahoma Ethics Commission does not have jurisdiction over municipal or school board employees.  However, please keep in mind that there may be local laws and individual school district rules limiting gifts to district employees and officials.



Oregon

Oregon law prohibits all public officials and employees from receiving, and “interested parties” such as Apple from providing, any gift or gifts with an aggregate value in excess of $50 in a calendar year from any single source.  There are exceptions for: 


  1. Unsolicited tokens of minimal value (less than $25); 

  2. The cost of food and beverage and admission to a reception, meal or meeting where the public official or public employee is attending in his/her official capacity on behalf of his/her state or local government body. 

  3. Reasonable food, travel or lodging expenses provided to a public official or public employee when representing state or local government on a “fact-finding mission”, where receipt of such expenses is pre-approved.  Written approval from district administration that they consider the briefing, meeting or other event to be a fact-finding mission and the expenses to be permissible is required.  A “fact-finding mission” is defined as any activity related to a cultural or educational purpose.

  4. Informational materials.



Pennsylvania

Pennsylvania school district officials (including superintendents, board members and potentially principals) and employees with duties including recommending equipment purchases are prohibited from accepting gifts “with strings attached.”  However, there is no per se prohibition on providing travel, lodging or meals related to official responsibilities of the official or employee.   Public officials and employees with administrative duties must file a statement of financial interest disclosing sources of gifts valued in the aggregate at $250 or more, and sources of payments for transportation, lodging or hospitality exceeding $650 or more.  In addition, please keep in mind that there may be local laws and individual school district rules limiting gifts to district employees and officials. 



Rhode Island

Rhode Island law limits an interested “person” such as Apple from giving anything to any public employee with a value of $25 or greater per occasion and $75 in the aggregate per calendar year.



South Carolina

South Carolina law prohibits a person from directly or indirectly giving, offering or promising anything of value to a public official or employee with intent to influence the official or employee's official responsibilities.  There are exceptions for: a promotional item not exceeding $10 in value; a meal provided in conjunction with a speaking engagement where all participants are entitled to the same meal and the meal is incidental to the speaking engagement; and actual and reasonable expenses incurred for and directly relating to a speaking engagement.  Any such payment or reimbursement must be reported on a statement of economic interest if the official or employee is required to file one (includes superintendents, school board members and chief finance and purchasing officials/employees), otherwise to the head of the agency with which employed, and if the expenses are incurred out of state, the public official or public employee incurring the expenses must receive prior written approval for the payment or reimbursement from the appropriate person.  In addition, please keep in mind that there may be local laws and individual school district rules limiting gifts to district employees and officials. 



South Dakota

South Dakota has no state law restrictions on giving gifts to school employees or officials, including superintendents.  However, please keep in mind that there may be local laws and individual school district rules limiting gifts to district employees and officials.



Tennessee

School district officials and employee in Tennessee do not fall under the state ethics rules.  However, please keep in mind that there may be local laws and individual school district rules limiting gifts to district employees and officials.



Texas

Texas public officials and employees, including those of school districts, are generally prohibited from taking any benefit from anybody.  There are exceptions (when no lobbyist is present and there is no lobbying intent) for: an item with a value of less than $50 (does not apply to cash, checks or negotiable instruments, including discounts) and benefits in the form of food, lodging, transportation, or entertainment if the donor is present and the benefit is accepted as a “guest” and reported in accordance with any applicable reporting requirement. Please note that a public servant required to file financial disclosure statements may have to report costs incurred by Apple for his or her attendance at an event.  In addition, the Texas Ethics Commission has stated that individual discounts are included in the definition of benefit, and they are therefore never permitted.



Utah

The Utah Procurement Code prohibits any person who in their official capacity participates in the procurement process from accepting, and interested parties such as Apple from even offering, any gift.  The Procurement Code in general does apply to school districts, and while it is unclear whether the specific gift prohibition sections apply as well, we have been informed by at least one Utah school district that they do.  In addition, we have found that individual school districts often have purchasing policies that mirror the state code and place restrictions on any gift to a school official or employee who participates in the purchasing process.  Please note that persons determined to be in violation of the Utah Procurement Code sections referenced above are guilty of a felony.   For those employees and officials who do not participate in the procurement process, the Utah Ethics Act simply prohibits public officers and employees from accepting gifts, directly or indirectly, that would tend to improperly influence official duties, or if the gift is from an interested party, the gift must be properly reported.  The Ethics Act provides exceptions for: occasional gifts of $50 or less; admission price for events; meals; recreation; outings or functions; and travel.  However, please keep in mind that there may be local laws and individual school district rules limiting gifts to all district employees and officials.  



Vermont

Vermont has no state law restrictions on lobbyist employers such as Apple giving gifts to school employees or officials, including superintendents.  However, please remember that there may be local laws and individual school district rules limiting gifts to district employees and officials.



Virginia

Virginia law generally prohibits public officials and employees, including those of local school boards and school districts, from receiving any gift that would tend to influence an official action.  Exceptions to this general rule include: gifts under $25, informational material, and actual travel, lodging, or subsistence incurred in connection with an appearance or speech.  However, Virginia also has special procurement rules that would apply to any employee whose work puts them in direct contact with the state Department of General Services - these rules prohibit a prohibit government contractor such as Apple from providing, and such a public employee from accepting, any gift.  The only exception to the procurement rules is for a gift of nominal value (de minimis gifts under $10).  Please note that some school districts have policies that mirror the state procurement rules but apply to any employees who are involved in procurement generally.  



Washington

The Washington State Ethics Code does not apply to school district officials and employees; any ethics issues regarding school district employees would go before the school board.  However, please note that Seattle and other larger cities may have their own ethics code, which would apply to school district officials and employees.  In addition, please remember that individual school districts  may have rules limiting gifts to district employees and officials.



West Virginia

West Virginia law prohibits all public officials and employees, including all school district employees, from accepting gifts from interested persons such as Apple.  There are exceptions for: meals and beverages; unsolicited gifts of nominal value ($25 or less); reasonable expenses for food, travel and lodging associated with a meeting at which the official or employee participates in a panel or speaking engagement at the meeting; and reduced rate or free admission to privately sponsored conferences or seminars if the attendance would benefit the state agency and would enhance job related skills and the performance of official duties.   However, please remember that there may be local laws and individual school district rules limiting gifts to district employees and officials.



Wisconsin

Local public officials in Wisconsin, including elected officers of political subdivisions, individuals appointed to a position in a political subdivision and individuals appointed to a position by the governing body, executive or administrative head of a political subdivision) may not accept (1) items of substantial value for private benefit if offered because of the recipient’s public position; (2) anything of value that could reasonably be expected to influence the official’s vote, official actions or judgment; (3) anything of value that could reasonably be considered a reward for any official action or inaction; or (4) discounted transportation or traveling accommodations for which the supplier would usually charge.  There are exceptions for: (1) items unrelated to the recipients’ public position; (2) expenses provide by or for the benefit of the local governmental unit, and(3) items of insubstantial value.


These restrictions do not apply to other school district employees, but please remember that there may be local laws and individual school district policies limiting gifts to all district employees and officials.




Wyoming

Wyoming law prohibits elected local officials from using their office or position for private benefit, such as receiving a gift which resulted from the holding of an office or position.  However, Wyoming exempts from the definition of "gift" the following:  food and beverage; any gift, special discount or hospitality with a value of $250 or less; and travel, registration and lodging for a conference or meeting while attending in an official capacity.  Please keep in mind that there may be local laws and individual school district rules limiting gifts to district employees and officials.




This information is provided only as a guide; please check with your ethics official to determine whether you are permitted to accept expenditures associated with this event.  Should you have any questions regarding ethics or gift laws relevant to this education event, please feel free to contact Genevieve Lewis in Apple Government Affairs at (408) 974-6550.

The state-by-state list below summarizes applicable ethics and gift laws as we currently understand them.  This information is provided only as a guide; please consult your ethics official to ensure that no state or local laws or school district rules prevent you from attending or from accepting expenditures associated with this event.  In addition, please note that attendance by a public official or employee may constitute acceptance of  a reportable gift.


Should you have any questions regarding ethics or gift laws relevant to this education event, please feel free to contact Genevieve Lewis Wyman in Apple Government Affairs at (408) 974-6550.

Please note that the FCC has issued gift rules applicable to service providers and entities participating or planning to participate in the E-rate program, including any employee of a school or district who is in any way involved in the E-rate program. These rules apply when a school or district has purchased or may purchase from a service provider using E-rate funds, and prohibit giving or receiving anything of value unless it falls under one of the two de minimus gift exceptions for: 1) modest refreshments not offered as part of a meal (e.g. coffee and donuts provided at a meeting); and 2)items worth $20 or less (e.g. pens, t-shirts and other items worth less than $20, including meals), so long as those items do not excee $50 in a calendar year.  The FCC is taking a very broad view of who is covered by these rules.