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Introduction to Procurement for Public Housing Authorities

Unit 1A. Introduction to Procurement for Public Housing Authorities. Unit 1A – Ethics and Conflicts of Interest in Procurement Activities. Ethics in Procurement. Grantees must have a written Code of Standards - which is included in the Procurement Policy Golden Rule: No Personal Gain!

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Introduction to Procurement for Public Housing Authorities

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  1. Unit 1A Introduction to Procurement for Public Housing Authorities Unit 1A – Ethics and Conflicts of Interest in Procurement Activities

  2. Ethics in Procurement • Grantees must have a written Code of Standards - which is included in the Procurement Policy • Golden Rule: No Personal Gain! • Employees, officers, and/or agents must discharge duties impartially • To ensure fair competitive access to procurement opportunities by responsible contractors • To foster public confidence in the integrity of the PHA’s procurement process

  3. Conflicts of interest… • No employee, officer or agent of the PHA shall participate in the selection, award or administration of a contract paid for from Federal funds if a conflict of interest –financial or otherwise, real or apparent – would be involved. • A conflict arises when any of the employees, officers or agents of a PHA, including their immediate family members or partners, have a financial or other interest in a firm selected for award. • Also includes an organization which employs or is about to employ any of the above listed parties

  4. Conflicts of interest… • The PHA nor its contractors nor their subcontractors may enter into a contract or subcontract in connection with a project under Annual Contributions Contract where any of the following have an interest: • Members/officers of PHA’s governing body • PHA employees in a policymaking position • Public officials, members of local governing body, or State/local legislators • Includes immediate family members of any of the above • Applies to those presently employed/in office and for 1 year following separation from employment/office

  5. Other ethical considerations • Do not solicit or accept gifts, favors or anything of monetary value. • Note PHAs may allow unsolicited gifts of nominal intrinsic value if established in the Procurement Policy • Report suspected anticompetitive practices by contractors to the Executive Director, HUD Field Office and appropriate State/local officials. • Do not disclose confidential information. When in doubt, the PHA’s Contracting Officer should obtain legal advice from their attorney or consult with HUD’s Legal Counsel.

  6. Remember… • Avoid Conflicts of Interest • Maintain a written Code of Standards • The Golden Rule: No Personal Gain! • When in doubt, consult your attorney or HUD’s legal counsel

  7. References • 24 CFR 85.36(b)(3) • PHA Procurement Handbook7460.8 REV 2 - • Chapter 4

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