Conflict of Interest Policy
The nature of public purchasing subjects all parties involved in it to close public scrutiny. This scrutiny extends to their ethics as well as to their performance. Since almost every action taken by purchasing personnel is anchored in public trust, the rules governing the conduct of public personnel are often as much concerned with appearance as with substance.
We strive to ensure compliance with high ethical standards and avoid possible conflicts between public purchasing duties and private affairs by complying with the LCC Conflict of Interest Policy.
Employees of the College are expected to conduct business according to the highest legal and ethical standards. This policy demands not only observing the law, but also designing practices and procedures to maintain a high degree of integrity.
I. Disclosure of Relationship to Vendor
An employee who participates in the selection or approval of products or sources of supply, or who has supervisory responsibility for such employees, may not have a financial interest in the company which furnishes the supplies or services being purchased. This would avoid an unfair competitive advantage and protect the interests of LCC. For this reason, employees directly involved in the purchasing process are to refrain from any outside activity or relationship which lessens their impartiality, judgment or effectiveness. This policy does not prohibit the ownership of stock in large publicly owned companies whose stock is listed and sold on a recognized stock exchange.
Disclosure of Relationship to Vendor is required:
- In instances of financial interests
(e.g., employee's spouse or other immediate
relative is an owner or shareholder or an
employee of a firm;
- In any situation where there is a potential for an
employee to benefit financially from a business
transaction conducted by the College.
Employees will complete Conflict of Interest Form. Personnel assigned to evaluation committees will sign Evaluation Committee Disclosure Statement for Conflict of Interest.
II. Gifts and Gratuities from Vendors
All College employees are to avoid accepting any kind of gratuities, tips or gifts for himself/herself or for any member of his or her family. This includes merchandise, cash, services, entertainment and other courtesies. It is essential to both the College and its suppliers that all decisions and actions regarding purchasing are based upon proper business considerations and are not influenced in any way by personal obligations. Most offers of this kind are made in the spirit of good business relations without the intent to obligate the recipient in any way. However, it is extremely difficult to differentiate between minor gratuities or courtesies and those which will cause some feeling of obligation or create any unfavorable impression in the minds of other vendors. Because of this difficulty employees must refrain from accepting any gratuity regardless of its magnitude or the manner in which it is presented.
- Calendars, desk novelties or similar advertising
items of less than $25.00 in value (this dollar
limit will be reviewed and revised in accordance
with IRS limit on business gift deductions);
- Reasonably priced meals accepted in settings
where College business is conducted;
- Text books, recorded media, software or similar
work-related items for which the school is not
- Any other exceptions to this policy should be
reviewed by the President, Provost, Senior Vice President for
Finance, Administration and Advancement or Chief Financial Officer
to determine if special circumstances exist to warrant the
acceptance of a gift from a vendor or to determine whether a gift
should be declined or returned.
Employees must exercise caution that neither regular gifts of nominal value, nor reasonably priced meals from a particular vendor, do not gradually accumulate into an embarrassing obligation (or violation of this policy). Under no circumstances shall an employee accept a gratuity where prohibited by law, policy or regulation or where the appearance of impropriety may occur.
Download the Conflict of Interest Disclosure Form.
Washington Court Place, Room 214
Phone: (517) 483-1785
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