Waunakee Community School District Business Office Procedures/Internal Controls 8.3

FEDERAL GRANTS CONFLICT OF INTEREST

PURPOSE To ensure compliance with the regulations under the Federal Uniform Grant Guidance (UGG) (2 CFR Part 200), which requires written procedures outlining steps necessary to ensure allowable grant costs and methods.

MANAGED BY  Budgetary Administrative Assistant  Grant Administrator  Accounting Specialist  Business Manager  Superintendent

APPLICABLE DISTRICT POLICIES  Staff Conduct = Policy No. 522  Staff Conflicts of Interest = Policy No. 524.1  Board Member Conflict of Interest = 165.1

§ 200.318 GENERAL PROCUREMENT STANDARDS. (c)(1) The non‐Federal entity must maintain written standards of conduct covering conflicts of interest and governing the performance of its employees engaged in the selection, award and administration of contracts.

(2) If the non‐Federal entity has a parent, affiliate, or subsidiary organization that is not a state, local government, or Indian tribe, the non‐Federal entity must also maintain written standards of conduct covering organizational conflicts of interest.

DEFINITIONS

EMPLOYEE CONFLICT OF INTEREST No employee, administrator, or agent may participate in the selection, award, or administration of a contract supported by a Federal award if he or she has a real or apparent conflict of interest. Such a conflict of interest would arise when the employee, officer, or agent, any member of his or her immediate family, his or her partner, or an organization which employs or is about to employ any of the parties indicated herein, has a financial or other interest in or a tangible personal benefit from a firm considered for a contract. The employees, administrators, and agents of the Waunakee Community School District (“District”) may neither solicit nor accept gratuities, favors, or anything of monetary value from contractors or parties to subcontracts.

8.3 Conflict of Interest‐Federal Grants Page 1 All business related gratuities are specifically prohibited except nominally valued, widely distributed items (calendars, pencils, etc.)

ORGANIZATIONAL CONFLICT OF INTEREST Organizational conflicts of interest means that because of relationships with a parent company, affiliate, or subsidiary organization, the District is unable or appears to be unable to be impartial in conducting a procurement action involving the related organization (non‐profit organizations). Purchasing services from organizations such CESA 2, the Dane County New Teacher Project, the Dane County School Consortium, or other public corporations, shall not be considered organizational conflicts of interest.

DISCLOSING CONFLICT OF INTEREST

All staff with decision making authority for Federal awards will be required to complete a Conflict of Interest (Federal Grants) online form on an annual basis at the beginning of each school year. This form includes a Disclosure of Conflict(s) of Interest and a Personal Certification of the employee’s responsibilities relating to disclosure of any conflict of interest within 30 days of acquiring any new conflict of interest. This form will be reviewed by the Accounting Specialist. A report of Conflict of Interest form submissions will be provided to the Business Manager by September 1 of each fiscal year.

In the event a conflict of interest arises after the annual Conflict of Interest (Federal Grants) form has been completed, the employee must disclose the conflict of interest in writing to the Accounting Specialist as soon as they know the facts of the conflict. This written disclosure will include name of the person, form or organization with whom the conflict exists, the nature of the conflict of interest and the date that the conflict status began.

Upon receipt of the notification, Accounting Specialist will:  confirm the facts of the conflict of interest  verify that the employee is removed from participation in selecting, evaluating, ordering, or purchasing from the identified vendor  notify the Business Manager of the removal  disclose the potential conflict of interest in writing to DPI in accordance with applicable Federal awarding agency policy

FORM(S)

 Conflict of Interest (Federal Grants) Disclosure Form (Online)

Est. 4/1/16 Rev. 8/30/17

8.3 Conflict of Interest‐Federal Grants Page 2