I'm afraid the answer is "no". I happen to have a copy of the Dividend Incentives brochure (actually it says VIP Miles but that's the old name, I think).

The application requires you to define whether it's a Customer Incentive/Reward or Employee Incentive/Reward. I don't know how closely they monitor this.

BTW, there's also a 7.5% federal sales tax and a $75 handling fee.

andrew