Procurement and Contract Services Policy & Procedures Manual
Section 100: Purchasing and Contract Ethics
Effective: 1/4/2010
Revised: 1/8/2019


104-001: Declaration of Conflict or Potential Conflict of Interest

The procurement of goods, services and construction at OSU must be free of the undue influence of outside interests. There may be situations in which financial or other personal considerations may compromise, or have the appearance of compromising, an employee's professional judgment in the execution of any part of the procurement or contracting process. Any conflicts or potential conflicts of interest regarding the procurement or contracting process must be reported to PaCS before making the procurement or executing the contract. Conflicts of Interests regarding the research integrity of a research project or proposal are managed through the Research Office process. Their decision on the conflict of interest relating to research integrity does not mitigate conflicts of interest in the procurement or contracting area.

Employees should promptly disclose any real or potential conflicts of interest by filling out the “PaCS Disclosure of Real or Potential Conflict of Interest” form and submitting to PaCS for review and advice on mitigating the conflict of interest.


104-002: Conflict of Interest for Selection Committee Members

Employees engaged as a Selection Committee Member must first execute the OSU Conflict of Interest Statement before participating in the evaluation or selection of a Contractor or Vendor under a Formal Procurement process.


104-003: Conflict of Interest Violations Pertaining to Use of Federal Funds

In compliance with all applicable Code of Federal Regulations code of conduct requirements, OSU standards of conduct must provide for disciplinary actions to be applied for violations of such standards by officers, employees, or agents of the federal fund recipient.


In cases where it is determined that there has been a violation of OSU Standards or PaCS Policies and Procedures pertaining to Conflicts of Interest PaCS will collaborate with the OSU Office of General Counsel, Office of Research Integrity and Office of Post Award Administration, and in some cases, the Human Resources Department in order to work with the Dean or Department head responsible for overseeing the college or department employee.  In consultation with these departments the Dean or Department head will determine an appropriate disciplinary action for the employee responsible for the violation.  Personnel may be disciplined for violations, including warning, reprimand, or a more severe sanction for cause, up to and including termination.


104-004: Segregation of Procurement and Accounting Functions

See FIS policies for segregation of functions.