Conflict of Interest in Purchasing and Contracting

Senate Bill 20, passed during the 84th Texas Legislature, modified procurement and contracting guidelines for state agencies and institutions of public education.  The UNT System has taken measures to implement necessary business practices to address the provisions established by Senate Bill 20 and Section 2261.252 of the Texas Government Code.

Employees must disclose a Financial Interest if they are (1) Employed by or (2) hold a Financial Interest in, a Business Entity that may bid for, is negotiating, or enters into a contract with the University. Employees must also disclose a Financial Interest if it is known that a family member (spouse, parents, siblings, children, or any individuals residing in the same household) are: (1) employed by or (2) hold a Financial Interest in, a Business Entity that may bid for, is negotiating, or enters into a contract with the Institution.

The requirement to disclose a Financial Interest applies even if the employee has no direct involvement in the endorsement, evaluation, or selection of the Business Entity. Such disclosure is necessary to ensure transparency and maintain trust in the Institution’s procurement processes.

The disclosure must be reviewed to assess any potential conflict of interest and to determine the appropriate course of action to ensure fairness and integrity in the Institution's dealings.

The disclosure must occur at the beginning of employment (new hires), once annually by all employees, and any time a new financial interest arises.

Definitions

For purposes of this disclosure, the term "financial interest" refers to any situation where the employee or any of their family members:

  • Owns or controls, directly or indirectly, an ownership interest of at least one percent in the Business Entity, including the right to share in profits, proceeds, or capital gains; or
  • Could reasonably foresee that a contract with the Business Entity could result in a financial benefit to the employee or official.
  • Financial interest prohibited by this section does not include a retirement plan, a blind trust, insurance coverage, or an ownership interest of less than one percent in a corporation.

The term "employed by" refers to any situation where the employee or any of their family members holds:

  • Any position within a Business Entity that includes receipt of remuneration or other financial benefits including commissions, bonuses, consulting fees, royalties, dividends, loans, or any form of financial assistance that exceeds normal salary and/or wages.
The term "business entity" refers to any organization or individual that engages in economic activities including corporations, partnerships, sole proprietorships, and limited liability companies. It also includes independent contractors and self-employed individuals who provide goods or services in exchange for compensation.

 

New Process

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We have updated that process for how to submit a disclosure. You can submit the disclosure via the online Financial Interest Disclosure form.

 

Instructions for using the online form are available here as a Print Version Quick Reference Guide.

 

 

For questions about Financial Interest (Conflict of Interest) disclosures. contact: conflictdisclosures@untsystem.edu

For questions/assistance with the Financial Interest FORM, contact: jaggaeradmin@untsystem.edu.