Policy on Vendor Donations for Company Events

Date Issued: 07/09/2026    

Purpose

This policy establishes guidelines governing the solicitation and acceptance of voluntary vendor donations to help fund events held by the Milwaukee County Transit System (Milwaukee Transport Services, Inc. or “MTS”), such as the annual Bus Roadeo competition. This policy is designed to ensure transparency, prevent actual or perceived conflicts of interest in procurement processes, and maintain public trust in our organization.

 

Scope

This policy applies to all MTS employees, officers, and board members involved in either (a) the solicitation of vendor donations for MTS events, or (b) the evaluation, award, or administration of MTS contracts and procurements.

Policy Statement

MTS may solicit voluntary monetary or in-kind donations from vendors to support MTS-sponsored events. Such donations are strictly non-transactional and shall have no bearing on current or future procurements. MTS does not solicit donations for operational expenses. MTS reserves the right to reject or return any donation.

Pre-Solicitation Requirements

Before any vendor donation solicitation is issued, the following steps must be taken:

  • The solicitation approach and materials must be reviewed and approved in writing by MTS's legal counsel.
  • Staff must verify compliance with all applicable state and local ethics laws, gift statutes, and public agency regulations before soliciting donations.
  • This policy must be adopted and on file prior to any solicitation being issued.

Solicitation Standards

All vendor solicitations for event donations must adhere to the following standards:

  • Solicitations must be sent to all vendors with a valid email on file. MTS shall publish solicitations for donations on ridemcts.com for the access of any vendors that do not currently have a valid email on file. Solicitations of this type shall be published separately and distinctly from procurement opportunities.
  • All donations must be clearly communicated as voluntary. No vendor shall be pressured, coerced, or incentivized to donate. MTS reserves the right to reject or return any donation.
  • The letter of solicitation must explicitly state that donating or declining to donate will have no effect on current or future procurement decisions. (See Appendix A for required language.)
  • Individual vendor donations, whether cash, in-kind donations, or any combination thereof, shall not exceed a value of $5,000.00 per event. In-kind donations must be accompanied by documentation of the donated goods/services fair market value.
  • A standardized, pre-approved solicitation template must be used for all outreach. No individualized solicitations are permitted.

Transparency and Disclosure

Transparency is a foundational safeguard against conflicts of interest. MTS shall:

  • Maintain a complete record of all vendors solicited, all donations received (monetary amount or in-kind value), and the event for which donations were collected.
  • Publicly disclose a list of all donors on ridemcts.com prior to or concurrent with the funded event.
  • Report all donations received to the MTS Board as a standing agenda item.
  • Maintain donation records separately from all procurement files. Donation records shall not be stored within, referenced in, or attached to any vendor's procurement or contract file.

Procurement Firewall

MTS shall maintain a strict separation between event fundraising activities and procurement processes:

  • MTS CEO or Deputy CEO shall be the sole individuals with authority to solicit donations of this type. The individuals responsible for soliciting donations shall not serve as evaluators, scoring panel members, or decision-makers on any procurement.
  • Procurement staff will never solicit donations.

Recordkeeping

MTS shall retain the following records for a minimum of 7 years or as required by applicable law, whichever is longer:

  • A complete list of vendors solicited and the date of solicitation.
  • Copies of all solicitation letters and response communications.
  • Documentation of all donations received, including donor name, amount/value, and date.
  • Records of public disclosure of donations.
  • Written legal/ethics approval for each solicitation cycle.

Violations and Consequences

Any MTS employee found to have violated this policy, including by soliciting donations outside the approved process, influencing a procurement on behalf of a donor vendor, or failing to recuse when required, may be subject to disciplinary action up to and including termination, in accordance with MTS's personnel policies and applicable law.

Review and Monitoring

This policy shall be reviewed annually as part of the regular policy review cycle. Revisions may be made as necessary to ensure continued effectiveness and alignment with organizational objectives.

 

Urgent Policy Updates

When immediate updates are required due to changes in law, industry standards, or internal operational needs, this policy may be reviewed and amended outside of the annual review schedule.

 

Approval

This policy supersedes all prior versions and has been formally approved by the Milwaukee County Transit System (MCTS) Chief Administrative Officer and the President & Chief Executive Officer.