7.7.2 Potential Conflicts of Interest

Policy Statement

In general, a potential conflict of interest exists if an individual, their spouse, father, mother, son or daughter:

• Is, or within the previous three* years was, a State of Illinois employee (including an employee of the University of Illinois System); or
• Holds, or within the previous three* years held, an elected government office (federal, state or local),
• Is, or within the previous three* years was, held an appointed government office (federal, state or local),
• Is, or within the previous three* years was, a registered State of Illinois lobbyist; or,
• Is, or within the past three* years was, compensated by a registered election, re-election, or political action committee,

*Two years in the case of a spouse, father, mother, son or daughter.

and has an ownership interest in, or is entitled to receive distributive income from, the potential vendor in an amount that exceeds a threshold prescribed by law. Individuals are under a continuing obligation to disclose the existence of these relationships for three years (two years in the case of a spouse, father, mother, son or daughter) from the last date of employment, appointment, term, or registration.

Reason for the Policy

This policy is intended to implement Section 50-35 of the Illinois Procurement Code by providing for the identification, review, and resolution of potential conflicts of interest relating to procurements by or for the University of Illinois System.

Applicability of the Policy

This policy applies to all purchases made on behalf of the University of Illinois System or a specific university within the system.

Procedure

The University of Illinois System may not make a purchase from a vendor without prior review and approval if the university either knows or should know that a potential conflict of interest exists.

Potential conflicts of interest can be identified in the following three manners.

• By completion of a Financial Disclosures and Conflicts of Interest form or registration on the Illinois Procurement Gateway, which is required for all purchases of $100,000 or more, and all competitive solicitations;
• By identification of a vendor in a Report of Non-University Activities (RNUA) process (for UIUC, UIS, and System employees);
• By identification of a vendor in the UIC Research process (for UIC employees) or,
• Through common knowledge of a relationship with an individual who has a potential conflict of interest.

When a potential conflict of interest is identified or presumed, the potential vendor must complete a Financial Disclosures and Conflicts of Interest form or register on the Illinois Procurement Gateway. A potential conflict of interest exists if:

• the potential vendor has submitted the Financial Disclosures and Conflicts of Interest form and checked “yes” for any of the questions in Step 4; or, the vendor is registered on the Illinois Procurement Gateway and in Section I – Financial Disclosures & Conflicts of Interest has checked “yes” for any of the questions numbered 5 through 10 and the purchase would not be paid for wholly or in part with funds appropriated by the Illinois General Assembly;
• the potential vendor has submitted the Financial Disclosures and Conflicts of Interest form and checked “yes” for any of the questions in Step 5 or the potential vendor is registered on the Illinois Procurement Gateway and in Section I – Financial Disclosures & Conflicts of Interest and has checked “yes” for any of the questions numbered 11 through 20; or,
• University personnel, through common knowledge, discover or reasonably suspect a potential conflict exists.

If a potential conflict of interest exists, the University of Illinois System should consider alternative sources for supplying the services or supplies. If the services or supplies are not available from other sources, or it is in the University of Illinois System’s best interest to proceed with the proposed purchase, the University may request a conflict of interest review for approval prior to proceeding with the purchase. See Conflict of Interest Review Process.

Forms Used in this Procedure

Financial Disclosures and Conflicts of Interest

Additional Resources

Illinois Procurement Gateway
Conflict of Interest Review Process
Purchase Order Hold Process

First Published: July 2017 | Last Updated: May 2023 | Last Reviewed: May 2023