UNIVERSITY OF PITTSBURGH POLICY 05-02-02

CATEGORY:               FINANCIAL AFFAIRS
SECTION:                   Purchasing
SUBJECT:                  Conflict of Interest and Procurement Relationships
EFFECTIVE DATE:    March 12, 2003 Revised
PAGE(S):                    1

I.    SCOPE

      This policy establishes the responsibilities of all persons with purchasing authority in

      dealing with suppliers who provide goods and services to the University.

II.   POLICY

      All individuals with purchasing authority on behalf of the University must avoid any behavior

      that involves a real conflict of interest and any appearance, however remote, of using
      affiliation with the University as a means of furthering personal interests.

      No member of a purchasing unit should accept entertainment, gifts, or favors provided by

      persons with whom the University has business dealings under circumstances that suggest

      that the donor intends to influence the judgment or conduct of the purchasing staff.

      -     Courtesy gifts such as flowers, as well as unsolicited advertising or promotional

            materials (pencils, calendars, etc.) of nominal intrinsic value may be accepted.

      No member of a purchasing unit should serve as an officer, director, or in any other

      management capacity for a company or organization doing or seeking to do business with

      the University.

      No member of a purchasing unit should serve in any capacity in any other organization

      where his or her judgment regarding University affairs may be influenced by concern for

      the success of the outside enterprise.

      No member of a purchasing unit should request or accept from any individual or

      organization doing or seeking to do business with the University, a favor or special

      consideration for himself or any member of his family that will result in any direct or
      indirect financial gain.

      No member of a purchasing unit should engage directly or indirectly in a personal financial

      transaction that primarily relies upon information obtained through his University
      employment and is not otherwise common knowledge.

      In cases where it is not clear whether such conflict could exist, the situation should be

      referred to the Director of Purchasing.

      As a condition of employment, all individuals authorized to commit University funds or

      purchase goods and services are required to sign a Conflict of Interest Certification.