It is the responsibility of Washington University and its employees to guard against conflicts of interest that might compromise the integrity and objectivity of the university community.

Washington University Code of Conduct (or download full PDF here)  Code-of-Conduct-2016

Procurement COI Policy (PDF)

Procurement Conflict of Interest Disclosure Form (PDF)

Frequently Asked Questions

Where can I find the University’s Code of Conduct?

On the university’s website for the Office of Compliance page

Is a business in which my spouse has a financial interest ineligible to conduct business with the University?

Not necessarily. However, disclosure of the facts is required.

May I accept a gift certificate for any amount to a restaurant or retailer?

No. Gift certificates are considered cash instruments and may not be accepted.

What should I do if I know other employees have accepted gifts from vendors?

Notify your supervisor.

What should I do if I’m just not sure whether or not I should accept a vendor’s offer of gifts for meals or travel?

Decline the offer and make your supervisor aware of the offer.

May I accept offers from a vendor with which there is no existing business relationship?

It depends on the circumstances. If the offer is a clear attempt to curry favor then you should absolutely decline the offer and notify your supervisor. If you happen to be involved in a meeting with the vendor and that carries over into a normal lunch period, you might consider accepting lunch. But the decision on any future business relationship should be based solely on the company’s ability to meet the University’s requirements for a given product or service and should not be influenced by any extraneous offerings.

Is it ever appropriate for a WU employee to pick up the expense for a business lunch or dinner?

Yes. But check with your supervisor for appropriate approvals in advance if you intend to seek reimbursement from WU.

May I bring my spouse, other family members, or other guests along with me on a business trip at the expense of a vendor?


Should I always inform my supervisor when I accept any gift from a vendor?

Yes, but don’t waste time reporting the acceptance of promotional trinkets such as pens or note pads.

Is there a set monthly or annual dollar amount that is allowable for gifts from suppliers?

Yes. It is $75, annually, for all suppliers combined.