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Conflict of Interest in Federal/State Grants - Financial Conflict (Policy)

Office of Origin: Finance
Responsibility: Chief Finance Officer
Original Date Adopted: 10-22-96
Dates Reviewed: 11-22-08, 12-14-17, 1-26-21
Last Date Approved: 1-26-21

Lake Michigan College (the College) will protect Federal and State funded programs from financial conflicts of interest. Accordingly, no employee may participate in the selection or administration of a contract supported by a Federal or State award if he or she has a real or perceived conflict of interest.

A conflict of interest exists when an employee working on the selection or administration a Federal or State funded program has or appears to have the opportunity to influence decisions in a way that could lead to personal gain or give improper advantage to:

  • themselves,
  • any member of her/his immediate family,
  • her/his partner,
  • any entity in which the employee possesses an interest, including an organization which employs or is about to employ the employee, any member of her/his immediate family, or her/his partner.

In addition, employees may neither solicit nor accept gratuities, favors, or anything of monetary value from contractors or parties to Federal or State funded programs.

Employees involved in projects funded by Federal and State grants must sign the Conflict of Interest form annually at the start of each project fiscal year.

Violation of this policy may lead to disciplinary procedures, up to and including suspension, discharge, dismissal, termination, expulsion, and/or legal action.

References: Uniform Grant Guidance (UGG) (2 CFR Part 200)

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