Go Ahead and Offer the Senator a Cup of Coffee

As detailed in the attached bullet analysis, the Senate Select Committee on Ethics, in response to the Honest Leadership and Open Government Act of 2007 (“HLOGA”), published new guidance concerning the gift exceptions for items of little intrinsic value and food offered other than as part of a meal. Although the Senate clarifications arguably clear up very little, they are a good reminder that it is time to update company codes of conduct and compliance manuals in light of the many new requirements established by HLOGA.