Subject: Requirements Governing Employee Conduct and Conflict of Interest.
Dear Implementing Partners,
This notice serves as a reminder of expectations regarding Implementing Partner and staff conduct, specifically with regards to the requirements governing employee conduct and conflicts of interest.
All Implementing Partners are expected to adhere to good business practices, and should:
- Have a written code of business ethics and conduct;
- Have written standards of conduct for its employees;
- Ensure copies of these standards/codes are available to each employee during the performance of the award; and
- Ensure that all employees adhere to these standards.
Furthermore, all Implementing Partners must have policies and procedures in place to prevent organizational or personal conflicts of interest. Implementing Partners must prevent its officers, employees, or agents from using their positions for personal gain or presenting the appearance of such. A personal conflict of interest is a situation in which an officer, employee, or agent of the organization has a financial interest, personal activity, or relationship that could impair the employee’s ability to act impartially. Organizational conflicts of interest means a situation in which the organization is unable or appears to be unable to be impartial in conducting business. Implementing Partners must have a system in place to identify, address, resolve, and disclose to USAID any conflicts of interest as described as above and in the provisions/clauses below.
Below is a list of requirements per award type for your reference:
Non-US Recipients (Assistance)
- Standard Provision M.11 ‘Recipient and Employee Conduct’
- Standard Provision M.28 ‘Conflict of Interest’
US Recipients (Assistance)
- Standard Provision M.14 ‘Regulations Governing Employees’
- Standard Provision M.30 ‘Conflict of Interest’
Fixed Amount Award Recipients (Assistance)
- Standard Provision M.16 ‘Conflict of Interest’
Contractors (Acquisition)
- 52.203-13 ‘Contractor Code of Business Ethics and Conduct’
- 52.203-16 ‘Preventing Personal Conflicts of Interest’
You are reminded that Implementing Partners employees and consultants are private individuals, are not employees of the U.S. Government, and must not represent themselves as such. Implementing Partners must ensure that its employees are adhering to the regulations referenced above as well as all other terms and conditions of its USAID award.
USAID takes these topics very seriously given the potential risk to our work and foreign policy objectives. Should you have any questions, please do not hesitate to reach out to your respective COR/AOR or OCM point of contact.
