Procurement Plan For Summer Food Service Program Page 8

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G. The SFSP Sponsor must maintain a written code of conduct (7 CFR 3016.36 and 3019.42)
that includes procedures that governs the performance of its officers, employees, or agents
who are engaged in the award and administration of contracts supported by Child Nutrition
Program Funds.
The following conduct will be expected of all persons who are engaged in the awarding and
administration of contracts supported by Child Nutrition Program Funds.
 No employee, officer or agent of the SFSP Sponsor shall participate in the selection or
in the award or administration of a contract supported by program funds if a conflict of
interest, real or apparent, would be involved.
 Conflicts of interest arise when one of the following has a financial or other interest in
the firm selected for the award:
a. The employee, officer or agent;
b. Any member of the immediate family;
c. His or her partner;
d. An organization which employs or is about to employ one of the above;
e. A less-than-arms-length transaction. This is one party’s ability to control or influence
the other party to the transaction. A less-than-arms-length transaction occurs:
i. When a transaction is conducted between related parties, meaning that the
integrity of the transaction could be compromised;
ii. When one party to the transaction is able to control or influence the actions of the
other party.
Examples could include:
1. Hiring the CEO’s brother as a janitor.
2. Purchasing goods or services from a business owned by an officer,
employee, or relative of the Sponsor’s entity.
3. Agreement for computer maintenance between a business and person(s)
who are related to the Sponsor’s employees or board members.
 The SFSP Sponsor, employees, officers or agents must not solicit gifts, travel
packages, and other incentives from prospective vendors/contractors
 The SFSP Sponsor must set standards when financial interest is not substantial or the
gift is an unsolicited item of nominal value and may be acceptable.
 Penalties for violation of the code of conduct of the SFSP Sponsor will be the following
actions: (list appropriate actions for your organization).
a.
b.
c.
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