Faculty, staff, and student employees who make spending decisions, direct sponsored research, supervise employees, or teach students are required to disclose any potential conflict of interest, of which they are aware, in accordance with OSU Policy 4-0130. This policy provides guidance for disclosing certain financial interests if reasonably appearing as related to the exercise of University employee’s duties. The policy presumes that personal financial interests should not influence the performance of University duties, but recognizes that many interests presenting a potential conflict may be permissible if disclosed and properly managed. The policy also describes possible sanctions for noncompliance. Federal conflict of interest laws also may be applicable to those participating in federal grants/contracts or to those employed partly by federal agencies. Thus, this policy overlaps with but does not supplant a University employee’s responsibility under state or federal law, or other institutional policies which may have additional or different prohibitions, penalties or reporting duties.

State ethics rules also provide disclosure requirements and permissible relationships between University duties and other activities and commitments. Oklahoma State Statutes Title 62:257.20 requires employees to be “independent and impartial;” follow established policy in decision-making; refrain from using their position in order to obtain private benefits; and “avoid action which creates the appearance” of using position to “obtain private or inappropriate benefit.” Oklahoma State University employees shall exercise good faith in all purchasing transactions within the level and scope of their authority in their dealings with and on behalf of the University.

Rules Specific to Purchasing Activities

Institutional policy 3-0145 specifically prohibits the University from purchasing equipment, materials, or goods and services from an employee, a member of an employee's immediate family, or from a business in which an employee or a member of the employee's immediate family has an ownership interest unless the purchase is made after public notice and competitive bidding regardless of the monetary value of the purchase or contract. University employees are prohibited from soliciting gifts and must refrain from accepting personal or private gifts, benefits or gratuities for the performance or nonperformance of duties pertaining to their University position.

Controls and Review Processes

Purchasing activities and Conflict of Interest disclosures are reviewed by OSU personnel, A&M Board of Regents Internal Auditing, Office of State Finance, external auditors, and federal agencies in the case of a sponsored program.