"""Tis the gift to be simple,"" goes an old Shaker hymn.

But where holiday gifts among co-workers are concerned, that's not how it goes at the Advisory Board Co., a District-based research and publishing firm.

In fact, it is downright complicated. In the company's department of corporate member services, a three-tier system has been constructed: The top manager swaps gifts with the six employees he directly supervises, with each spending no more than $10 to $15 per person. Middle managers also exchange gifts with their subordinates, and, lastly, the remaining 45 people in the department trade presents among themselves. But there are more rules. Employees don't just choose someone and buy them a gift; they participate in a week-long ""secret Santa"" program. Each day they pick a name from a bag and buy a gift, of no more than $3 to $5, for that person. On the last day, they are asked to spend as much as $10. Why do companies go to such lengths for something that seems so simple? ""We've never had an uncomfortable situation,"" said Jonathan Baker, director of corporate member services and a 10-year veteran at the 750-employee company. ""But that's what you're afraid of."" The uncomfortable situation Baker wants to avoid is an employee giving a co-worker an inappropriate or unseemly present. With a heightened awareness of sexual harassment and a keener concern about what is proper, many employers have instituted gift-giving policies rather than risk having an overzealous employee present a co-worker with something on the order of lingerie. A gift that goes beyond the workplace bounds can create an irreparable chasm between the workers involved, as well as disharmony throughout the staff, workplace experts say. It also can land the offending employee -- or employer -- in court. ""I would hope people don't let their fingers do the walking through the Victoria's Secret catalogue,"" said Deborah Kelly, a partner specializing in employment law at the District-based firm Dickstein, Shapiro, Morin and Oshinsky. ""But one inappropriate gift probably won't bring in the Title VII police."" If the gift is coupled with suggestive comments or other indiscretions, though, it can provide a concrete example of harassment, Kelly said. At the very least, a boss who gives a female subordinate a negligee, or even jewelry, can expect a claim alleging a hostile work environment, she added. ""In 1997, be safe and give flowers, an office product or a gift certificate,"" Kelly advised. Other appropriate gifts include baked goods, food baskets, books or a donation to a charity. In addition to lingerie and jewelry, alcohol, cigarettes and anything else that even borders on questionable is a no-no, experts say. These concerns over eliminating unsuitable situations have led employers to today's gift-giving policies, workplace experts say. ""In most companies, it's a reaction to something that happened in the past,"" said Jim Maher, president of Crystal Group, a workplace consulting firm in Chesapeake, Va. ""They've had a bad experience with it and they want to control it, or get rid of it all together."" To one degree or another, employees are going to exchange gifts whether or not there's a policy, Maher said, so companies might as well institute a uniform guideline. Though some employees grumble at having to play Santa to a co-worker, set policies are the best way to maintain morale and productivity while also avoiding hurt feelings for those who go home empty-handed, he said. Most companies also allow workers to opt out if they don't want to participate. Without a policy, ""there can be a negative impact on productivity if one person doesn't get anything,"" Maher said. For employees who also are friends outside of work, experts suggest taking gift-giving out of the office in order to abide by company policies, avoid making people feel uncomfortable and to sidestep the appearance of favoritism. There is another, more practical reason that many offices are setting gift-giving policies: money. Without guidelines, workers don't know how much they should spend on their colleagues. ""A lot of folks here earn less than $30,000,"" the Advisory Board's Baker said. ""One of the main reasons we have our policy is to save people money. They can choose not to participate at all if they want."" Such policies also allow employees to avoid sticky questions, such as for whom they should buy gifts. Without these guidelines, workers on a 10-member team, for example, are left asking themselves if they should buy gifts for everyone, or just those two or three people with whom they work most closely. ""You have to be careful in a situation where you give a gift to one person,"" Maher said. ""If you're part of a team, you have to do something for the whole team; otherwise it can cause animosity."" At the Association Management Group in McLean, all 70 employees participate in a ""secret Santa"" program. Each worker picks a name out of a hat and, gifts are exchanged at the company's holiday lunch. No one has to spend more than $10. ""We're doing it differently this year,"" said Kathleen Ebel, director of communications. ""Everyone is exchanging gifts."" Last year the association tried a grab bag, its first venture into setting gift-giving rules. The grab bag didn't work because ""when people aren't accountable you get the cheapest things."" And without a policy, she said, people ""probably wouldn't give each other anything."" This year, Ebel said, everyone is bound by the same rules and there have been no problems. Oh, and if Ebel is your secret Santa, you're getting a Velcro dartboard and a gum-ball machine.

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