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File code: ADM.CONFLICT.PRO
Approval Date: 07/97
Approved By: President

Conflict of Interest Procedures

Western Illinois University, as a general rule, does not enter into any type of contract with employees or businesses owned by an employee or members of their immediate family. However, when there is an operational necessity to purchase commodities, equipment, or services from an employee or immediate families of employees, prior approval of the President of the University, or his/her designee, is necessary. Prior approval is required in the following instances:

  1. Purchases from an employee or their immediate family (spouse or children).
  2. Purchases from a business of which an employee or their immediate family is a major officer or primary employee.
  3. Purchases from a corporation of which an employee or their immediate family owns in excess of 7 percent of the total income.

There are two types of conflict of interest to be addressed:

  1. A technical conflict of interest (employee or family is not in a position to influence the selection of their firm).
  2. A real conflict of interest (employee is in a position to influence the outcome of the selection of a vendor or an award of contract).

Departments that desire to purchase commodities, equipment, or services from an employee or members of their immediate family must prepare a Letter of Justification and attach it to the Request for Purchase. The department will be required to justify the transaction as "essential" to University operations if the purchase is from an employee. If the purchase is from the employee's immediate family, the department will be required to justify the transaction as "beneficial" to University operations.

If the conflict of interest is technical, the originating department must indicate in the Letter of Justification that the employee is not in a position to influence the selection of their (or their immediate family's) firm. The originating department should attach the justification letter to the Request for Purchase and forward it through the appropriate offices for approval. Once the Request for Purchase is received in the Purchasing Office, it will be transmitted to the President, or his/her designee, for approval of the transaction.

If the conflict of interest is real, or could be perceived as real, the originating department must indicate in the Letter of Justification that the employee is in a position to influence the selection of their firm. The Letter of Justification also requires area vice presidential approval and it must be attached to the Request for Purchase and forwarded to the appropriate offices for approval. Once the document is received in the Purchasing Office, it will be transmitted to the President, or his/her designee, for approval of the transaction. If the transaction is approved, a Purchase Order will be issued and all supporting documentation for the transaction will be filed in the Business Office. If the transaction is not approved, the originating department will be notified and the Request for Purchase will be canceled.