Loyola University Chicago

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Loyola University Chicago

Purchasing

General Policies on Ethics, Conflicts of Interest and Gifts

TABLE OF CONTENTS

2.1 - Ethical Guidelines
2.2 - Conflict of Interest and Buying Ethics
2.3 - Anti-Kickback Clause


2.1 Ethical Guidelines

All faculty, staff and students must avoid conflicts of interest between their obligations to the University and their personal affairs. No faculty or staff member or a relative of either group, should have an economic interest in, or relationship with, any firm, person or corporation doing business with the University if there is a chance, or a perception, it could influence the employee’s actions on behalf of the University.

Loyola's buyers' code of ethics, gift guidelines for employees and anti-kickback clause, and conflict of interest policy are applicable to various University members, such as the University's Authorized Buyers.

Loyola University Chicago Buyers' Code of Ethics

University Authorized Buyers, first and foremost, understand and follow the financial policies of the University. They strive to obtain the maximum value for each dollar of expenditure. They decline personal gifts or gratuities which might affect their decision-making processes. They grant competitive suppliers equal consideration insofar as state or federal statute and institutional policy permit. They conduct business with potential and current suppliers in an atmosphere of good faith, devoid of
intentional misrepresentation. They DO NOT share vendor pricing information with anyone without written permission from the vendor. They make every reasonable effort to negotiate an equitable and mutually agreeable settlement of any controversy with a supplier; and/or are willing to submit any major controversies to arbitration or other third party review, insofar as the established policies of the institution permit.

They cooperate with governmental and private agencies for the purposes of promoting and developing sound business methods. They foster fair, ethical and legal trade practices, work on behalf of the interests of the University solely, and avoid situations that may result in personal benefit or gain to the buyer.

Confidentiality

All University employees in the University’s purchasing environment must be sensitive to issues of confidentiality. It is improper and prohibited to discuss and/or share pricing information, trade secrets or proprietary information with or among suppliers. If there is any question regarding what information may be discussed, contact the Loyola Purchasing Manager.

2.2 Conflict of Interest and Buyer Ethics

The University's principal missions are education and research. In pursuit of these missions, or as a natural outgrowth of such activities, faculty, researchers and staff may become involved in outside activities. While participation in activities away from Loyola benefit the University and are generally encouraged, in some circumstances such activities give rise to conflicts of interest or buying ethics.

The University actively encourages an open academic environment where teaching, conducting research, and disseminating knowledge are the principal goals. To further these missions, the University has relied and shall continue to rely on the good judgment, professional commitment and 13 moral ethics of the University members to protect themselves and the University from conflicts of interest and buying ethics. For further information on University conflict of interest policies as related to externally funded awards, please refer to the following for the Lakeside and HSD campuses:

Conflicts of Interest in Externally Funded Projects
Conflicts of Interest in Research Policy

Gift Guidelines

The University’s policy on Conflict of Interest also includes guidelines for the acceptance of Gifts and Favors.

2.3 Anti-Kickback Clause

The purpose of this section is to inform all University employees of their responsibility to act in an ethical manner that brings the best overall value to the University and not to solicit and/or accept personal gain from any procurement transaction.

Definition: "Kickback" as used in this clause means any money, fee, commission, credit, gift, gratuity, thing of value, or compensation of any kind which is provided, directly or indirectly, to any University, University employee (principal investigator, buyer, executive, etc.), subcontractor, or subcontractor employee for the purpose of improperly obtaining or rewarding favorable treatment in connection with an award.

Clause: (FAR 52.203-7) The Anti-Kickback Act of 1986 (41 U.S.C. 51-58) (the Act) prohibits, when using US government funding, any person from:

Providing or attempting to provide or offering to provide any kickback; soliciting, accepting or attempting to accept any kickback; or, including, directly or indirectly, the amount of any kickback in the contract price.

The Act imposes criminal and civil penalties on any person who, when using federal funding, knowingly and willfully engages in the prohibited conduct addressed above (reference FAR 3.502-2 (b) and (c)).

Applicability: This clause is designed to work hand-in-hand with the Loyola University Chicago Buyers' Code of Ethics to ensure that Loyola is represented in a professional manner that brings the best value to the University for all acquisitions of products and services.

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Loyola

1032 W. Sheridan Rd., Chicago, IL 60660 ยท 773-274-3000

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