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Procurement Integrity Policy

Subject: Procurement Integrity

I. General: The University of Denver employees, subcontractors or consultants performing activities under federally sponsored contracts, in compliance with the Procurement Integrity Act and OFPP Act Amendments thereto, shall not, during the conduct of any federal agency procurement of property or services in which they are involved, knowingly:

 

A. make, directly or indirectly, any offer or promise of future employment or business opportunity to, or engage, directly or indirectly, in any discussion of future employment or business opportunity with any procurement official of such agency;

 

B. offer, give, or promise to offer or give, directly or indirectly, any money, gratuity, or other thing of value to any procurement official of such agency; or

 

C. solicit or obtain, directly or indirectly, from any officer or employee of such agency, prior to the award of a contract, any proprietary or source selection information regarding such procurement.

II. Definition:

The term contractor hereby is meant to include Universities and Colleges.

 

A. Procurement Official shall mean any civilian or military official or employee of an agency who has participated personally and substantially in the following activities:

  1) development of acquisition plans;
  2) development of specifications, statements of work, or purchase descriptions/requests;
  3) development of solicitation or contractual provisions;
  4) evaluation or selection of a contractor; or
  5) negotiation or award of a contract or modification to a contract.

 

B. Employee of an Agency shall mean a contractor, subcontractor, consultant, expert, or advisor (other than competing contractor) acting on behalf of, or providing advice to, the agency with respect to any phase of the agency procurement concerned.

 

C. Proprietary Information shall include:

  1) information contained in a bid or proposal;
  2) cost or pricing data; or
  3) any other information submitted to the Government by a contractor and designated as proprietary, in accordance with law or regulation, by the contractor, the head of the agency, or the contracting officer.

 

D. Source Selection Information means information determined by the head of the agency or the contracting officer to be information -

  1) the disclosure of which to a competing contractor would jeopardize the integrity or successful completion of the procurement concerned; and
  2) which is required by statute, regulation, or order to be secured in a source selection file or other restricted facility to prevent such disclosure.

 

III. Requirements/Conditions of Employment

 

A. No University of Denver employee will offer, promise to give, or give anything of value to any government employee for any reason. (The term "government employee" includes other contractors, consultants, experts, subcontractors, or advisors working on behalf of the government.)

 

B. No University of Denver employee shall discuss potential employment with any government employee unless he/she first refers them to the Director of Office of Research and Sponsored Programs (ORSP). The Director will determine whether that person was or is in any way involved in any procurement in which the University was, is, or may be a competing contractor. When determined that the potential employee is not involved, the Director will so inform the University's employee and he/she may then proceed with such discussions unless or until such time that the University learns or suspects the government employee may have been or may become involved in a conflicting procurement.

 

C. When requesting any procurement-related information from a government employee, the University of Denver employees shall ask whether that information may be considered proprietary or source selection sensitive. If so, the University employee must immediately stop all discussions with respect to same. If not, the questions must be documented as having been asked and answered in the negative.

 

D. All potential DRI employees shall sign a certificate (Attachment #1) at the time of discussion of employment with the University of Denver.

 

E. As of January 1995, all current employees of DRI that perform work under federally sponsored contracts shall sign a certificate (Attachment #2) that will be binding throughout the term of their continued employment with the University of Denver.

IV. Violations

Actual or possible violations of any of these guidelines by a government or University employee shall immediately be reported to the Director of ORSP.

V. Deviations

It is the intent of the University of Denver to operate fully within the intent of the Procurement Integrity Act.