The following summary by Crowell Moring on a case in which two employees of contractor accepted meals and entertainment from subcontractors/Suppliers, demonstrates why one resulted in violation of the Anti-Kickback Act and one did not.
It demonstrates the importance of ensuring your employees understand conflict of interest and compliance to company Ethics and Business Conduct policies, and the risk violations pose to the company.
Employees acceptance of Gratuities subject company to heightened liability under Anti-kickback Act