Liability for Credits?

[Guest MD Hart]

My company has been approached by a vendor to implement a program offering products and services to our employees.

One aspect of the program that I'm concerned about is this: the vendor provides each employee with a credit towards the purchase of these products and services. The total credit amount is undecided - it could be somewhere between $25 and $100 and the credit amounts per product vary. Typically, the program is set up so it appears as though the employer is "providing" the credits. This is done for goodwill purposes, building participation based on the employer/employee relationship. My task is to research the credit piece of this with the goal of determining if there is any risk of our company incurring liability of any kind. Does anyone have any experience with anything like this that you can share with me or would anyone be willing to comment? I intend to obtain a legal interpretation but I would prefer hearing from the HR community as well.

Thanks.