Employee-Vendor Relationships

Background

It is University practice to separate an employee's University and private interests and to safeguard the University and its employees against charges of favoritism in the purchase of goods and services.  No purchase of goods or services shall be made from any officer of employee of the University or from the immediate family¹ of any officer or employee unless there has been a specific determination such goods or services are not available either from other commercial sources.  This practice safeguards the University and its employees from charges of favoritism in the acquisition of goods and services.

Scope

This practice applies to all facilities operated by the University.  This does not apply to securing services that are judged to be within the scope of the employment relationship.  Such cases will be considered under the appropriate academic or staff personnel regulations.

What is an employee-vendor relationship?

An employee-vendor relationship is a relationship between a University employee and a proposed vendor that might create a conflict of interest.  An employee-vendor relationship exists when:

• An employee proposes to rent, sell, or provide goods or services to the University
• An employee owns or controls an interest in the vendor who proposes to rent, sell or provide goods or services to the University
• A former employee proposes to rent, sell, or provide goods or services to the University
• A member of an employee's immediate family or the spouse of an employee currently provides, or is being proposed to provide, goods or services to the University
• A member of an employee's immediate family or spouse of an employee owns or controls an interest in the vendor who currently provides or is being proposed to supply, goods or services to the University

Required Reports

Prior to an officer, employee, or any officer's or employee's near relatives entering into a consideration to provide goods or services to the University, this intent shall be submitted in a detailed written disclosure to the responsible administrative officer.² The disclosure shall include:

• The name and relationship of the individual entering into the relationship or activity
• The nature of the pending activity or relationship
• The relationship between the outside entity and the University
• Any benefits to be gained by the employee or family member; and
• A description of how the employee will ensure separation of interests between the commitment to the outside entity and to the University

¹ Immediate family includes an individual's parents, siblings, spouse or domestic partner, children, and grand-children.  This definition also extends to individuals married to any of the aforementioned groups. (i.e. brother-in-law, daughter in-law, etc.)

² Responsible administrative officer is defined as the Provost and University Vice President, the Chief Financial Officer or the Chief Risk and Compliance Officer.   Responsible administrative officers may approve exception to this policy upon determination that there are unusual or extenuating circumstances.  This authority may be re-delegated to a specific designee, but may not be further re-delegated.

Anti-Kickback Guidelines

Statement

Purchasing Conduct and Ethics

Accepting Gifts, Gratuities, Incentives and Rebates

Employee-Vendor Relationships