About WUSTL

Compliance & Policies

Procurement Conflict of Interest Policy

Employees conducting business on behalf of the University have a responsibility to do so in a manner that is objective and ethical. The goal of all such business dealings must be to benefit the University. The following policies apply:

  1. University employees will conduct University business ethically and objectively, in compliance with all applicable laws, regulations and University policies, including the University's Code of Conduct.
  2. Employees must not accept gifts, entertainment, meals or travel that might directly or indirectly influence the employees' business judgements or decisions, or that might give the appearance of impropriety.
  3. The University intends to avoid any unnecessary costs that are the result of gifts from suppliers given to employees.
  4. The University provides equal opportunity to firms wishing to pursue business relationships.
  5. The purchase of goods or services from a business in which an employee or his family has a financial interest, or may directly benefit from such purchase, is a potential conflict of interest. Such situations should be disclosed to the University's executive director for Resource Management for review prior to the purchase.
  6. Any promotional benefits that result from a business transaction will be provided to the University (or one of its departments) and not to an individual employee.
  7. Employees may not accept any sum from any supplier attempting to "reward" the employees for the decision to do business with the supplier. Any acceptance of such sums, or kickbacks, will result in termination of the employees' employment (and possible legal action); and in the termination of the business relationship with the supplier.
  8. Gifts - In conducting University business, employees may encounter offers of gifts from suppliers. The following guidelines apply:

    • Offers of gifts should generally be refused.
    • While there may be occasion to accept such gifts (for example company promotional trinkets, e.g., pens or note pads), these or other gifts should never be accepted in return for a business favor.
    • Gifts of cash or monetary gifts of any kind or amount may never be accepted by employees.
    • The cumulative value of gifts received from all suppliers in total should not exceed $75 in any 12-month period.
    • Employees should review with their supervisors any offers of gifts.
  9. Business Entertainment - In conducting University business, employees may from time to time be invited by a supplier to attend a sporting event, cultural activity or other entertainment event. It may be appropriate for employees to accept such offers according to the following guidelines:

    • The supplier is in attendance.
    • Business will be conducted at the event.
    • The value of the entertainment is reasonable and not excessive.
    • Employees' business judgements and decisions will not be influenced by the entertainment or by the expense involved in the entertainment.
    • The entertainment offer is from a supplier with whom the University has an existing relationship or contract.
    • The entertainment offer is not made during a time period where proposals or bids are being sought to establish a new contract.
    • Entertainment offers should not be accepted with routine frequency.
    • Employees should review with their supervisors any offers of business entertainment.
  10. Business Meals - In conducting University business, employees may from time to time find it appropriate to do so in conjunction with meal times. While employees should not routinely plan business meetings around meal times in order to be the recipient of a "free" meal, it may not be inappropriate for employees to accept such a meal from suppliers. The following guidelines should be observed:

    • Business will be conducted at the meal.
    • Employees' business judgements and decisions will not be influenced by the meal or by the expense involved in the meal.
    • Employees who are so authorized should occasionally, at the University's expense, pay for the meals, including the suppliers' meals.
    • Employees should review with their supervisors any offers of business meals.
  11. Business Travel - In conducting University business that requires out-of-town travel, employees may receive offers from suppliers to pay for transportation, lodging and meals. It may be appropriate for employees to accept such offers according to the following guidelines:

    • The supplier will be at the travel destination.
    • Business is the sole reason for the travel.
    • The supplier will pay only for the employees' transportation, lodging and meals, NOT for employees' family members or other traveling companions.
    • Employees should review with their supervisors any offers to pay for expenses associated with business travel.
  12. Employees who are uncertain about whether or not to accept any offerfrom a supplier are advised to not accept the offer if there are any doubts at all. Supervisors should be made aware of all offers made to employees. In turn, supervisors should contact the University's executive director for Resource Management to discuss any questionable offers and any known violations of this policy.

November, 2003

Leading Together: the Campaign for Washington University