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University of Houston - Victoria

Office of the Vice President for
Administration and Finance

SECTION: PURCHASING INDEX: E-7
SUBJECT: RELATED PARTY DISCLOSURES

POLICY

Employees of the University of Houston-Victoria shall avoid using their positions for purposes that are, or give the appearance of being, motivated by a desire for private gain for themselves or others, such as those with whom they have family, business, or other ties. University employees shall exercise the utmost good faith in all transactions, activities, and behaviors related to their duties to the UH System, its property, and resources. Faculty and staff in a position to personally benefit from a transaction entered into by the University of Houston-Victoria or other UHS components shall annually complete a disclosure statement regarding related party interests as required by UHS Administrative Memorandum 03.A.17.

DEFINITION

Conflict of Interest: A situation in which there is a divergence between the employee's private interests and professional obligations to the University, such that an independent observer might reasonably question whether the employee's actions or decisions are determined by considerations of private gain, whether financial or otherwise, to the University's detriment. Such a situation may result from consulting or other outside employment, a relationship defined as a related-party interest, or any other relationship that results in a gift or benefit to the employee.

Related Party Interest: A question of fact that results when an individual is in a position to personally benefit from transactions entered into by the University of Houston-Victoria or other System component. Transactions may include, but are not limited to (1) originating purchase requests, influencing purchasing decisions and/or consulting or professional relationships that are created or perceived as creating a conflict of interest.

PROCEDURE

The Related Party Disclosure will be completed annually online as part of UH System mandatory training and reporting process. In the event that online reporting is unavailable, Business Services will coordinate the reporting process using the Related Party Disclosure Form (Attachment A).

Related Party Disclosures are to be completed by all faculty and staff employees within any of the following categories:

(a) employees who have previously disclosed a related party interest;
(b) employees who serve in a supervisory capacity at a department level or higher;
(c) employees in a position to make final purchasing decisions. This category includes all delegated departmental purchasers and ProCard users;
(d) employees having signature authority on any university cost center;
(e) employees who could personally benefit from a relationship or business transaction.

The Business Services Department will initially review disclosure information and notify the Dean or Department head, appropriate Vice President and the President of those employees who may have a related party interest. The Dean or Department head shall inform any faculty or staff member whose outside activity is believed to represent a conflict of interest. Remedial action will be suggested when indicated. Disclosures which indicate potential conflicts of interest will also be forwarded to the UH System Chancellor.

Deans and department heads should, at least annually, discuss related party interests and potential conflict of interest with their employees. Employees are instructed to report in writing to their Dean or Department Head all facts about any activity or transaction and the potential conflicts of interest that may be involved before any such activity or transaction occurs.

Any purchase requisition, delegated departmental order form or ProCard that can be identified as a related party transaction must include the following information and be authorized by the Dean or Department Head, “This is a Related Party Transaction. Reason for this purchase:_______________________”

REFERENCES

UHS Administrative Memorandum, 03.A.17

Approved:

Signature Obtained         09/02/2011
Don Smith, Ph. D.            Date
Interim President

Originating Department: Business Services Department

Next Review Date: August, 2014