NEPN/NSBA Code: DJH 

PURCHASING AND CONTRACTING: CODE OF CONDUCT 

Conflict of Interest 

No employee, officer, or agent of the school unit may participate in the selection, award, or administration of a contract supported by a federal award if they have a real or apparent conflict of interest. 

A conflict of interest would arise when the employee, officer, or agent—or any member of their immediate family, their partner, or an organization which employs or is about to employ any of the parties indicated herein—has a financial or other interest in or a tangible personal benefit from a firm considered for a contract. 

Gifts and Solicitations 

The employees, officers, and agents of the school unit may neither solicit nor accept gratuities, favors, or anything of monetary value from contractors or parties to subcontracts. 

Violations 

Employees of the school unit who violate this code of conduct may be subject to discipline, up to and including termination of employment and, if appropriate, referral to law enforcement. 

Legal Reference: 34 CFR Parts 74 and 80 (Education Department General Administrative Regulations (“EDGAR”)) (for federal awards made prior to 12/26/2014) 

2 CFR § 200.318 (Uniform Administrative Requirements—General 

Procurement Standards) (for federal awards made on or after 12/26/2014) 

Cross Reference: DJ – Bidding/Purchasing Procedures 

DJ-R – Federal Procurement Manual 

GBEA – Employee Code of Ethics 

Adopted: May 22, 2017 

Revised: November 5, 2020