1. SPECIAL ASSISTANT FOR PROJECTS/TRAINING Wynona Bryant-Williams, Ph.D. Child Nutrition Unit

2. What must I do!! Is this ethical?? So much to learn!! This is confusing!! What will happen if I break these rules?? RULES RULES RULES!! Why can’t I except this gift?? Who will know!!

3. PROCUREMENT What is procurement? Procurement is a multi-step process for obtaining goods, products, and/or services at the best possible price

4. WHAT IS THE FIRST STEP IN BEING SUCCESSFUL? PLANNING

5. CODE OF CONDUCT – 7 CFR 3016 7 CFR Part 3016.36 (b) (3) A School Food Authority (local school district) “will maintain a written code of conduct governing the performance of their (SFA) employees engaged in the award and administration of the contract. No employee …shall participate in selection or in the award or administration of a contract supported by Federal funds if a conflict or interest, real or apparent would be involved.“

6. 7 CFR PART 3016.36 (B) (3) (IV) This regulation states: "…employees…will neither solicit nor accept gratuities, favors, or anything of monetary value from contractors, potential contractors, or parties….“

7. WRITTEN CODE OF CONDUCT MUST INCLUDE THE FOLLOWING STRATEGIES: PROHIBIT EMPLOYEES FROM SOLICITING GIFTS

8. WRITTEN CODE OF CONDUCT MUST: Prohibit employees from travel packages

9. WRITTEN CODE OF CONDUCT MUST (CONT’D) PROHIBIT EMPLOYEES FROM OTHER INCENTIVES FROM PROSPECTIVE CONTRACTORS

10. WRITTEN CODE OF CONDUCT MUST (CONT’D) PROHIBIT AN EMPLOYEE FROM PARTICIPATING IN THE SELECTION, AWARD AND ADMINISTRATION OF ANY CONTRACT TO WHICH AN ENTITY OR CERTAIN PERSONS CONNECTED TO THEM, HAVE FINANCIAL INTEREST

11. PRACTICE ETHICAL BEHAVIOR WHAT DO CHILD NUTRITION EMPLOYEES DO WHEN THERE IS NOT SUBSTANCIAL FINANCIAL INTEREST INVOLVED – I.E. CALENDARS, COFFEE MUGS: SET STANDARDS

12. STANDARDS (CONT’D) MUST PROVIDE FOR DISCIPNARY ACTIONS IF STANDARDS ARE VIOLATED

13. APPROPRIATE ACTION MUST BE TAKEN IF 7CFR 3016 IS VIOLATED TEMPORAILY WITHHOLD CASH PAYMENTS PENDING CORRECTION

14. Accountability to Taxpayers Accountability of the effective use of SNP funds to provide nutritious food to enrolled children is of

15. interest to the taxpayer, Congress, and the media. Transparent means that everything done by

16. the SFA must be clear, forthright, and out in the open. Transparency in the procurement process

17. will lead to accountability and cost effectiveness, which are especially important in federally

18. funded programs such as SNPs. Ultimately, the state and local officials who administer these programs are accountable to taxpayers for the way in which they use program funds.

19. WHAT HAPPENS IF I BREAK THE RULES??? Take one or more of the following actions: Temporarily withhold cash payments pending correction of the deficiency

20. CONSEQUENCES FOR BREAKING RULES (CONT’D) Disallow all or part of the cost of the activity or action not in compliance

21. CONSEQUENCES FOR BREAKING RULES (CONT’D) Wholly or partly suspend or terminate the current award for the grantee’s and sub grantee’s program

22. CONSEQUENCES FOR BREAKING RULES (CONT’D) Withhold further awards for the program, or TAKE LEGAL REMEDIES

23. RESPONSIBILITY OF THE SCHOOL FOOD AUTHORITY (SFA) Required to submit a Written Code of Conduct for Employees involved in a Procurement in the Child Nutrition Program as part of the Procurement section of the Agreement between ADE and the SFA for the 2015-16 School year

24. The SFA should consult legal counsel for guidance on necessary board action for implementing this REQUIRED CODE OF CONDUCT

25. GUIDANCE SHOULD INCLUDE: How to respond when: A gratuity – a favor – or item with monetary value is offered

26. When there is doubt concerning the appropriateness of accepting gifts consider the following: How would the public perceive this action????

27. Will acceptance of the gift, favor, etc. possibly influence a future purchasing decision??

28. I understand now!! Following rules is always the right thing to do!!