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Non-Federal entities who apply for and receive Federal financial assistance awards are required to "establish safeguards to prohibit employees from using their positions for a purpose that constitutes or presents the appearance of personal or organizational conflict of interest, or personal gain." [1] During the application process, non-Federal entities disclose in writing any potential conflicts of interest related to the awardfunding opportunity.  If disclosed, the Federal agency may elect to work with the applicant on a mitigation plan as part of the Federal awards terms and  and conditions. Successful applicants agree when accepting the Federal award to disclose any subsequent real or perceived conflict's of interest related to the award during its lifecycle. Failure to do so could result in termination of the award. 

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