Conflict of Interest Definition and Guidelines

The Conflict of Interest Policy contained in the ISU Policy Library explains the University's position regarding purchasing goods or services from employees. 

For more information on Conflict of Interest as it relates to state employees, see Iowa Code Section 68B Conflicts of interest. 

• Federal Standards: The Federal Government employs a higher standard related to conflicts of interest which may affect ISU employees purchasing goods and services with federal grant or contract funds. The Federal Government also states that even the appearance of impropriety is to be avoided. The following section from the Code of Federal Regulation 2 CFR Part 200 Uniform Administrative Requirements for Grants and Agreements deals with conflicts of interest. 
• Codes of Conduct: The non-Federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. No employee, officer, 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 officers, employees, and agents of the non-Federal entity may neither solicit nor accept gratuities, favors, or anything of monetary value from contractors or parties to subcontracts. However, non-Federal entities may set standards for situations in which the financial interest is not substantial or the gift is an unsolicited item of nominal value. The standards of conduct must provide for disciplinary actions to be applied for violations of such standards by officers, employees, or agents of the non-Federal entity. 
  
  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. Organizational conflicts of interest means that because of relationships with a parent company, affiliate, or subsidiary organization, the non-Federal entity is unable or appears to be unable to be impartial in conducting a procurement action involving a related organization.

ISU has established the Conflict of Interest Procurement Committee (COIPC) to review purchases from potential conflicts of interest. These conflicts arise when the company we are transacting business with is owned wholly or partially by an ISU employee, an employee of a regent institution or an employee of a state agency. 
 

For a complete listing of purchasing guidelines when using federal funding refer to the PART 200—UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS