1211 - University of North Carolina at Chapel Hill Policy on Avoiding Vendor Conflicts of Interest

Introduction

Purpose

Conflict of interest relates to situations in which financial or other personal considerations may compromise, have the potential for compromising, or have the appearance of compromising an employee's objectivity in meeting University duties or responsibilities related to the purchase of equipment and other supplies. This policy protects the University from these types of situations.

Scope of Applicability

All University faculty and staff.

Policy

Policy Statement

To avoid conflicts of interest issues, the University does not purchase from University employees, or from companies in which a University employee may have a greater than fifty (50) percent financial interest, either directly or indirectly.

Exceptions

A request for an exception to this policy may be submitted to Purchasing Services. The request must be accompanied by clear evidence documenting the procurement vendor selection was not impacted by the potential conflict of interest. In the event the evidence is not compelling, Purchasing Services will submit to the N.C. State Division of Purchase and Contract for a binding decision.

Additional Information

Special Situations

None.

Frequently Asked Questions

Q: What is a conflict of interest?

A: For University purposes, a person has a conflict of interest when it is likely that the outcome of a University decision will have an impact on his or her financial interests.

Q: If a conflict of interest is found, are there any options available for managing the conflict?

A: Depending on the facts and circumstances of the situation, any or all of the following might be employed:

  • Public disclosure of the financial interest.
  • Modification of the research plan.
  • Disqualification from participation in all or a portion of the proposed project.
  • Divestiture of the financial interest.
  • Severance of the relationship that creates the actual or potential conflict.

Q: What if a company with which you consult makes a contribution to your research; is it a conflict?

A: Potentially. The appropriate course of action is to report it.

Q: If an employee of the University owns a business would they be allowed to conduct business with the University?

A: No.

Q: I am an employee of the University and my spouse has her own business; can she conduct business with the University?

A: Yes, if it is clear that the University purchasing decision can not be influenced by you and you have no influence over the outcome. All potential activity by the spouse should be disclosed to Purchasing Services prior to any activity to determine if a potential conflict exists.

Related Requirements

External Regulations and Consequences

General Statute § 14-234 - Public officers or employees benefiting from public contracts; exceptions

University Policies, Standards, and Procedures

None.

Contact Information

Policy Contact
Subject Contact Telephone Fax E-Mail
Potential Conflict of Interest Purchasing Services - Goods 919-962-3774 919-962-0636 purchasing_team@unc.edu

History

Revised:

  • July 13, 2010
  • November 14, 2003
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Details

Article ID: 131408
Created
Thu 4/8/21 9:08 PM
Modified
Thu 5/16/24 11:10 AM
Effective Date
If the date on which this document became/becomes enforceable differs from the Origination or Last Revision, this attribute reflects the date on which it is/was enforcable.
02/28/2020 8:55 AM
Issuing Officer
Name of the document Issuing Officer. This is the individual whose organizational authority covers the policy scope and who is primarily responsible for the policy.
Issuing Officer Title
Title of the person who is primarily responsible for issuing this policy.
Director of Purchasing Services
Last Review
Date on which the most recent document review was completed.
02/28/2020 8:55 AM
Last Revised
Date on which the most recent changes to this document were approved.
02/28/2020 8:55 AM
Next Review
Date on which the next document review is due.
02/27/2021 12:00 AM
Origination
Date on which the original version of this document was first made official.
03/01/1998 11:00 PM
Responsible Unit
School, Department, or other organizational unit issuing this document.
Finance and Budget