Conduct

This policy governs the standard of performance of Wake Forest 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 supported by federal or other sponsored funds 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 that employs or is about to employ any of the parties indicated herein has a financial or other interest in the firm selected for an award. 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 subagreements (except when such gift is an unsolicited item of nominal value).

Definitions:
"Financial interest" is defined as including salary, royalties, or other remuneration from the firm selected or ownership in the firm if the value of such interests exceeds:

          · an amount of $5,000 per year in the case of salary, royalties, or other remuneration;

          · an interest of $5,000 or 5% ownership interest for any one employee and the employee's spouse and dependent children.

"Federal funds" are those funds received either directly from the federal government or indirectly as a subrecipient under another entity's federal agreement.

Violations of such standards by officers, employees, or agents of the university shall result in disciplinary actions as determined by the cognizant university official and university policy.

SEE ALSO HR91, Conflict of Interest

AUTHORIZATION:
This policy is implemented to comply with federal regulations contained in Office of Management and Budget Circular A-110 "Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations."