In determining whether a gift is of “substantial value,” the Ethics Board
looks at the totality of the circumstances.* Here, the value of the gifts is small in
comparison to the time you devoted to the two organizations, the sentimental
value of the gifts is greater than their monetary value, and the gifts are, in
essence, commemorative in nature. In these circumstances, we conclude that
the gifts are not of “substantial value” as that term is used in the Ethics Code,
and you may keep them.