ALL ACADEMICS AND STAFF AT UCSD (including Healthcare)

SUBJECT:    Responsible Procurement Practices

This is to reaffirm UCSD s policy for the appropriate conduct of business for faculty and staff who are involved with the purchase of goods and services. UCSD s purchasing policy establishes guidelines to ensure that all purchasing activities are conducted in a manner that fosters and promotes fair and ethical business practices. All faculty and staff who interact with suppliers in the course of their assigned duties should understand and comply with these policies. A copy of this notice is available for future review at http://www-bfs.ucsd.edu/pur/services/pursvcs/ethicsrpp.htm.

Purchasing Conduct and Ethics: First consideration is to be given to UCSD's mission and principles of community; Obtain maximum value for each dollar spent; Decline personal favors, gifts and gratuities; Grant all competitive suppliers fair and equal consideration; Conduct business with potential and current suppliers in an atmosphere of good faith; Demand honesty in sales representation; Receive consent of originator for use of proprietary ideas and designs; Make reasonable effort to obtain equitable settlement of any controversy with a supplier; Accord a prompt and courteous response to all who call on legitimate business; and Foster fair, ethical, and legal business practices.

Please refer to information about Purchasing Conduct and Ethics at http://www-bfs.ucsd.edu/pur/services/pursvcs/ethicscd.htm.

Gifts and Gratuities: It is the policy of the University that all employees shall act with integrity and good judgment and to recognize that the acceptance of personal gifts from those doing business or seeking to do business with the University, even when lawful, may give rise to legitimate concerns about favoritism depending on the circumstances. Further, the policy states that no officer or employee should solicit or accept any personal favor, gift, gratuity, or offer of entertainment directly or indirectly from a supplier that is engaged, or is endeavoring to engage, in doing business with UCSD. A gift is not considered acceptance of modest entertainment such as a meal or refreshments in connection with attendance at professional meetings and similarly sponsored events by industrial, technical, professional or educational associations. Gifts are not considered nominal promotional materials offered by vendors to market their business.

Departmental buyers should report to their supervisor the offer or acceptance of any gift. The supervisor shall confer with the Conflict of Interest Office, the Purchasing Manager and Internal Audit to determine whether acceptance of the gift complies with University policies. Some faculty and staff are subject to additional requirements for financial disclosure and disqualification from making decisions on matters in which they have a financial interest. Refer to Presidential Policies on Gifts and Gratuities http://www.ucop.edu/ucophome/coordrev/policy/12-22-98gift.html, Conflict of Interest Code http://www.ucop.edu/ucophome/ipsp/coitoc.html , and UCSD PPM 200-13 Conflict of Interest Section IV.A.1 http://adminrecords.ucsd.edu/ppm/docs/200-13.HTML

Conflict of Interest - Employee-Vendor Relationship: It is the policy of the University to separate the interests of employees from those of UCSD to prevent preferential treatment in purchasing goods and services. This policy also requires that disclosure be made to the Purchasing Manager when a vendor is an immediate relative and when there is a personal (family) relationship between the employee responsible for procuring goods and services and a vendor. Any decision to initiate a purchase to that vendor must be reviewed and approved by the Purchasing Manager or his/her designee who will coordinate review with the cognizant departmental representative and the Conflict of Interest Office for a determination whether it is in the best interests of UCSD. Refer to http://www-bfs.ucsd.edu/pur/services/INDPTCON.htm#step5 for information regarding the conditions that give rise to employee-vendor relationships.

The Purchasing Manager has the authority to review the facts and circumstances of any employees conduct that may involve non-compliance with these guidelines. In the course of a review, the Purchasing Manger may consult with Human Resources, Conflict of Interest Office, department management and any other applicable sources. Further, should the circumstances be serious enough to warrant an independent investigation, existing policy provides that Internal Audit be notified to potentially conduct an investigation, and that the results would be reported to the Purchasing Manager and/or other department line management.