Declaring a Conflict of Interest in the Procurement of Goods and Services

Legislative History: Approved by the Vice-President Finance and Administration: 2007/04/30; Date Effective: 2007/06/25.

Approval Authority: Vice-President Finance and Administration

Signature: Gary Brewer


Description: Outlines the responsibility of University employees who have the authority to procure goods and services to make appropriate disclosure should a conflict of interest arise and also sets out the disclosure process to be followed. Issued pursuant to the University Policy and Procedure on Procurement of Goods and Services.


Guideline

The University shall not acquire goods, materials or services from an employee, from anyone who is not arm’s length to any employee, or from a corporation, firm or other business in which an employee, or someone at non-arm’s length to an employee, is a shareholder in a company that is not publicly traded, without full disclosure of the conflict of interest, and the written waiver or other resolution of the conflict by the Vice-President, Finance and Administration.

Accordingly, an employee may not, without disclosure and resolution of a conflict or a perception of conflict:

  1. enter into a business or other contract/transaction on behalf of the University with a company or firm in which the employee, or related persons, has a financial interest; and/or
  2. influence the purchase of equipment, materials or services for the University from a company or firm in which the employee, or related persons, has financial interest.

Application

This Guideline applies to University procurement activities, whether from operating, research, capital, ancillary or special purpose funds.

Disclosure Procedure

  1. Whether the conflict actually exists or can appear to others as though a conflict exists, the  employee has an obligation to declare this conflict, the waiver of which can only be approved by the Vice-President Finance and Administration or designate.
  2. To declare a conflict of interest, an employee shall submit a formal written declaration outlining the details of the conflict to the Director, Procurement Services, in advance of making any financial commitment to an external supplier.
  3. The Director will consider the nature of the situation and will submit a recommendation to the Vice-President, Finance and Administration who shall make a determination on how the matter shall be resolved.
  4. The request will be retained for the official record until such time as the conflict no longer exists (e.g. change in employment status or change in relationship status).
  5. Undeclared conflicts of interest may result in disciplinary action up to and including termination.

Related Policies, Procedures and Guidelines

Conflicts of Interest for University Employees, Policy on
Conflicts of Interest for Members of the Board of Governors, Policy on