ATTENTION: CO-OP DIRECTORS, CHILD NUTRITION DIRECTORS AND CHILD NUTRITION MANAGERS
School Food Authority
(SFA) operating Child Nutrition Programs are reminded that 2 CFR 200.318(c)(1)
requires entities receiving Federal funds to develop and implement a written
code of conduct designed to govern the performance of employees engaged in
procurement (purchasing). This written
code of conduct must be included in the SFA child nutrition procurement plan
This written code of
employees from soliciting gifts,
employees from travel packages and
employees from other incentives from prospective contractors.
an employee from participating in the selection, award and administration of
any contract to which an entity or certain persons connected to them, have
for Child Nutrition Program operators to set standards when financial interest
is not substantial or the gift is an unsolicited item of nominal value and may
be acceptable (for example: coffee mug
provide for disciplinary actions to be applied in the event the standards are
State Agency (SA) oversight
and monitoring of procurement activities includes a review of the written code
of conduct as well as an investigation of reported real or apparent conflicts
of interest by employees involved in procurement.
Guidance should be
provided to all SFA employees concerning the acceptance of gratuities, favors,
or items of monetary value. Where there
is doubt concerning the appropriateness of accepting gifts, favors, etc. the
employee should consider the following questions:
- How would the public perceive this
action of receiving the gift, favor, etc.?
- Will acceptance of the gift, favor, etc.
possibly influence a future purchasing decision?
SFAs may set standards for situations in
which the financial interest is not substantial or the gift is an unsolicited
item of nominal value (for example: calendar or coffee cup). If the SFA does set standards for these
situations it must be part of the written code of conduct.
The SFA should require
training regarding the “Code of Conduct” for all child nutrition personnel as
well as any other district personnel involved in purchasing for the child
nutrition program. Documentation of this
training activity will be reviewed as part of the Administrative Review conducted
by ADE CNU.
SFAs are reminded of
the procurement resources available on the Child Nutrition Unit website. The link to the procurement resources
If there are any
questions regarding the code of conduct requirement or other procurement
activities please contact the SFAs assigned child nutrition area specialist.
Attachment: SP 09-2015