Conflict of Interest

Definition and Guidelines

  1. The Conflict of Interest Policy contained in the ISU Policy Library explains the University's position regarding purchasing goods or services from employees.
  2. For more information on Conflict of Interest as it relates to state employees, see Iowa Code Section 68B Conflicts of interest.
  3. Federal Standards: The Federal Government employs a slightly different standard of conflict of interest which may affect ISU employees purchasing goods and services with federal grant or contract funds. The Federal Government also states that even the appearance of impropriety is to be avoided. The following section from the Code of Federal Regulation 2 CFR Part 200 Uniform Administrative Requirements for Grants and Agreements deals with conflicts of interest.
  4. Codes of Conduct: The recipient shall maintain written standards of conduct governing the performance of its employees engaged in the award and administration of contracts. No employee, officer, or agent shall participate in the selection, award, or administration of a contract sponsored by a Federal award if a real or apparent conflict of interest would be involved. Such a conflict would arise when the employee, officer, or agent, any member of his or her immediate family, his or her partner, or an organization which employs or is about to employ any of the parties indicated herein, has a financial or other interest in or a tangible personal benefit from a firm selected for contract. The officers, employees, and agents of the recipient shall neither solicit nor accept gratuities, favors, or anything of monetary value from contractors, or parties to sub-contracts. However, recipients may set standards for situations in which the financial interest is not substantial or the gift is an unsolicited item of nominal value. The standards of conduct shall provide for disciplinary actions to be applied for violations of such standards by officers, employees, or agents of the recipient.
  5. ISU has established the Conflict of Interest Procurement Committee (COIPC) to review purchases from potential conflcits of interest. These conflcits arise when the company we are transacting business with is owned wholly or partially by an ISU employee, an employee of a regent institution or an employee of a state agency. 

 

For a complete listing of purchasing guidelines when using federal funding refer to the Office of Management and Budget Circular A-110.