OGC Conflicts of Interest Policy

Members of the Office of the Vice Chancellor and General Counsel have a responsibility to avoid conflicts of interest and the appearance of such conflicts with respect to the expenditure of University resources on outside attorneys, law firms, consultants, accountants and other vendors with whom OGC conducts, or may in the future conduct, business (collectively, “Vendors”).

In order to maintain the highest standards of business ethics and to avoid even the appearance of a conflict of interest, OGC has adopted the following standards for its own members:

1. Gifts. OGC members will not accept gifts from any Vendors except for gifts of truly nominal value. Gifts include gift baskets, gift certificates, travel, event tickets that do not fit the definition of “business entertainment” in section 3, and any other free goods or services. If a gift of more than nominal value is received without notice or an opportunity to object, the Vendor should be informed that OGC cannot accept such gifts and the gift should either be returned, donated to a charitable cause, discarded (if appropriate), or given to a University employee who is not in a position to influence the University’s decision to purchase goods or services from that Vendor. Additionally, OGC members may purchase the gift item (e.g., event tickets that do not fit the definition of “business entertainment” in section 3) for full value from the Vendor using personal funds.The following standards also apply:
   1. Gifts should not be accepted in return for a business favor.
   2. OGC members will not accept monetary gifts or loans.
   3. The cumulative value of gifts received from all Vendors will not exceed $75 in any 12 month period.
2. Business Meals. While OGC members should not routinely plan business meetings around meals that will be purchased by Vendors, OGC members may accept such meals in accordance with the following guidelines:
   1. University business will be conducted at the meal; this is the primary if not sole objective.
   2. OGC members’ business judgments and decisions will not be influenced by the meal or by the expense involved in the meal.
   3. Such meals should be infrequent in occurrence and modest in price.
3. Business Entertainment. In conducting University business, OGC members may from time to time be invited by a Vendor to attend a sporting event, cultural activity, client entertainment event or dinner, or other entertainment event at the Vendor’s expense. It may be appropriate for OGC members to accept such offers according to the following guidelines:
   1. The Vendor will be in attendance at the event;
   2. University business will be conducted at the event;
   3. OGC members’ business judgments and decisions will not be influenced by the entertainment or the expense involved in the entertainment;
   4. Such entertainment should be infrequent, both with respect to events offered by a single Vendor (not to exceed two such events per calendar year) and overall.
   5. The value of such entertainment shall be reasonable and not excessive;
   6. The offer is from a Vendor with whom the University has an existing relationship and is not made during a time when the Vendor is seeking a new engagement or contract;
   7. OGC members should report participation in any business entertainment event to the OGC business manager, who will maintain records of the frequency and nature of such events.

The standards in this policy are in addition to those set forth in the Washington University Conflicts of Interest Policy. To the extent this policy sets forth a more stringent standard on a subject addressed in both policies, this policy applies.