While corporate divisions may be separate, they are all part of a single entity, and they all report to the same top corporate officials. No matter how disparate their day to day operations, they each operate under an integrated corporate strategy designed to best serve the corporate owners and customers, as well as the public. One division of a corporation may well have knowledge of the contracts of the other divisions. This information can usually be obtained by nothing more than reading the corporation's annual report. In addition, corporate compensation will be dependent, at least in part, upon the operations and profits of all divisions.
Many divisions can have overlapping management or promotional lines.
Given this integration, the public could reasonably perceive that a corporate division with which IBR has contracts will receive more favorable treatment or continued good will if a different division of the same corporation provides IBR with financial support for its programs. Thus, IBR may not seek financial support from an entity, or any division of an entity, where one of its divisions is a vendor. This bar also applies to any entity which is seeking a contract from IBR, as the timing of a donation could lead to the appearance of favoritism in the selection process. As to the solicitation of companies which are not its vendors, IBR should adopt a policy that any gift or support that it may receive will be given no consideration whatsoever at such time as it may select a vendor in the future. Based on the Commission's prior opinions, IBR could not accept a gift of support from any company, or from any of its various divisions, with which it is in litigation.